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3M recognizes that the definition of fluorinated ghg is consistent
with the U.S. EPA definition and that both definitions exempt
materials with a vapor pressure of less than 1 mmHg at 25C.  Please
be aware that the vapor pressure threshold in this definition
raised concerns because EPA also defined, "heat transfer fluids"
and tied the definition of a heat transfer fluid to the definition
of a fluorinated ghg.  The concern, simply stated, is that heat
transfer fluids are used at elevated temperatures so their vapor
pressures at 25C are not indicative of emission potential.  EPA has
recently proposed amending the definition of a heat transfer fluid
to address this concern.  EPA's proposal is attached (pg 56022). 
3M calls CARB's attention to this issue in the event CARB, in the
future, also defines heat transfer fluid.