In March 2021, CARB recognized that its consumer
product regulations have directly resulted in the increased use of
HFC-152a as a regulatorily-exempt aerosol propellant alternative
for hydrocarbon propellants. The regulation the
Board was adopting at that time increased use of HFC-152a in
hairsprays and other aerosol household products in order to reduce
near-term VOC.
While HFC-152a was a good step for reducing local
pollution burdens, HRC-152a is a moderate-GWP intensity
GHG. CARB recognized at the time that the
negative warming effects of increased use of HFC-152a should and
would be addressed in the Scoping Plan Update to potentially
include measures to reduce consumer product GHG emissions to
mitigate this CARB-regulation-driven increase in the use of
HRC-152a.
The draft Scoping Plan appears to not honor this
commitment, as there is no identification in the Plan of any
“technologically and commercially feasible actions to reduce
GHG emissions from consumer products, while maintaining or
improving upon regional air quality
progress”. Indeed, this particular source of GHGs
appears to not be included as a GHG source in the draft Scoping
Plan at all.
Industry is unlikely to introduce HFC-152a
alternatives for aerosol products if CARB doesn’t require
them to do so. Since the large manufacturers that
dominate this industry formulate, advertise, distribute and sell
identical/interchangeable products in national markets, California
requirements generally result in national adoption. The result in
this case is that aerosol products containing HFC-152a propellants
have been sold nationally over the past 30 years.
When considering the potential reductions in GHGs in
addressing HRC-152a propellants in consumer products, any
mitigation would appear to be a relatively small contribution to
the overall Scoping Plan. However, consumer products are unique in
that it is impracticable for large consumer product manufacturers
to make products just for the California market. Therefore,
consumer products manufactured to meet CARB requirements will be
sold nationally (as they are today). National GHG reductions
achieved by such a measure may not be fall into the accounting
performed for the Scoping Plan, but they are real and just as
impactful as GHG reductions that occur within California. They will
only occur nationally if California acts. As manufacturers such as
Proctor & Gamble reformulate hairsprays, dry shampoos, aerosol
body sprays, and a multitude of other aerosol household and
personal care products to meet California requirements, these
reformulated products will be sold nationally.
Such a reduction is meaningful, easily achieved, and
falls squarely on CARB to carry out because of its responsibility
in regulating this problem into existence in the first
place. Please revisit your earlier commitment and find a
way to phase out the use of HRC-152a propellant in consumer
products as rapidly as possible. And please formally
include a commitment to do so in the draft Scoping Plan prior to
its adoption. Please grab what appears to be the GHG
equivalent of “low hanging fruit”.