GS-34, Green GS-36, Green GS-37, Green GS-40, Green GS-41, Green GS-52, Green GS-53, Green Institutional Use. standards.

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1 July 12, 2013 COMMENTING PERIOD RESULTS: Cleaning Products and Adhesives VOC Revision: GS- 8, GS-34, GS-36, GS-37, GS-40, GS-41, GS-52, and GS-53. Green Seal is revising the criteria on volatile organic compounds (VOCs) in the following standards. The commenting period was open from December 4, 2012 through January 18, GS-8, Green Seal Standard for Cleaning Productss for Household Use GS-34, Green Seal Standard for Cleaning and Degreasing Agents GS-36, Green Seal Standard for Adhesives for Commercial Use GS-37, Green Seal Standard for Cleaning Products for Industrial and Intuitional Use GS-40, Green Seal Standard for Floor-Care Products for Industrial and Institutional Use GS-41, Green Seal Standard for Hand Cleaners for Industriall and Institutional Use GS-52, Green Seal Standard for Specialty Cleaning Products for Household Use GS-53, Green Seal Standard for Specialty Cleaning Products for Industrial and Institutional Use These revisions are intended to align the VOC content criteria with the California Air Resources Board (CARB) and to provide consistency across Green Seal s cleaning product standards. These VOC limits set by CARB have been shown to set leadership levels for reduction of air emissions, while stilll allowing functional performance for the product categories that they cover. Another change was to update the methodology cited in the standards to reference CARB Method 310, which expands beyond EPA Method 24. By participating in Green Seal s standard setting process, the following organizations that providedd comments played an important role in Green Seal s effort to encouragee the design, manufacture, and use of environmentally superior products. Their assistance and involvement is greatly appreciated. Participating Organizations: California Department of Public Health Consumer Specialty Products Association New York Department of Health Responsible Purchasing Network and Green Purchasing Institute South Coast Air Quality Management District Toxics Information Project

2 Summary of Changes: Green Seal's VOC criteria now reference the CARB regulatory limits for VOCs, instead of setting specific limits. Exceptions were made for the instances where the previous edition of a Green Seal standard had a stricter limit than the current CARB limit. To better clarify the CARB VOC limits, each Green Seal standard will include a table of the CARB VOC limits with the corresponding product category and effective date. These tables will be updated when the CARB regulations are amended. All VOC limits are now listed in percent by weight and no longer in g/l. Where appropriate, EPA Method 24 has been replaced with CARB Method 310, a newer and more encompassing method. VOC criteria for all standards will be evaluated for ingredients present above 0.01% by weight. Ingredients present in concentrations below this level have been shown to make insignificant contributions to the total VOC content. GS-36, Green Seal Standard for Adhesives for Commercial Use, will no longer include definitions for adhesive types and will instead follow the definitions included in the CARB regulation. General Comments We appreciate this opportunity to comment on Green Seal s Proposed Criterion Revision for GS- 8, GS-34, GS-37, GS-40, GS-41, GS-52, and GS-53 Volatile Organic Compound (VOC) Content Section Revisions that was distributed for public comment on December 4, We have been involved in working cooperatively with the California Air Resources Board (ARB), numerous other states, and the U.S. Environmental Protection Agency on developing VOC regulations for consumer products for more than 20 years. We therefore have an extensive knowledge and understanding of the current VOC regulations in California and elsewhere. We are supportive of the revision of these standards to reference ARB Method 310 in place of EPA Method 24. Method 310 has been specifically developed and maintained for enforcing compliance to the complex regulations in California and elsewhere that limit the content of VOCs in consumer products. Method 24 was determined in the late 1980s to be inappropriate for consumer product compliance determination, and the change to Method 310 is long overdue. It is also important to understand that Method 310 differs fundamentally from Method 24. While Method 24 is composed of several discrete test methods whose results can be used to determine compliance with a standard, Method 310 is an enforcement procedure composed of an openended group of test methods and data collection that is aimed at determining whether a product formulation complies with the complex set of standards and criteria encompassed in the consumer product regulations. Method 310 consists of a number of potential steps, including: An Initial Determination of VOC Content using various tests (including Method 24). Request for (usually confidential) product formulation data. Determination of LVP status of compounds and mixtures. 2

3 Final Determination of VOC Content, which can involve additional standard or customized test procedures ( as necessary to verify the formulation data ) and opportunity by the manufacture to explain discrepancies in test results. It is also important to understand that while it is stated in the applicability section that, Method 310 does not apply to the determination of the composition or concentration of fragrance components in products, the various fragrance provisions have all proven to be enforceable using Method 310. Method 310 therefore can be considered to exclude exempted fragrances from its determination of VOC concentration. It is also important to understand that Method 310, as an enforcement procedure, is only conducted by ARB or other enforcement officials, and is not intended to be conducted by product or ingredient manufacturers. Various analyses in Method 310 may need to be performed by ingredient suppliers (such as the vapor pressure determination and LVP status determination), and product formulators may need to investigate anomalous results from various test methodologies in Method 310, but only regulatory agencies follow its requirements to assure that formulations meet all of the complex requirements of their regulations. In the following sections, we will comment on the Background statement and the various proposals for criterion reviews. Background and Technical Considerations We do not agree with the characterization of VOCs in cleaning products as hazardous chemicals that can cause indoor and outdoor air pollution associated with carcinogenicity and respiratory ailments including asthma. The VOCs used in household and institutional cleaning products are almost universally of very low toxicity and are not in any way associated with carcinogenicity or asthma. The VOC standards being referenced in these Green Seal standards are related to the ability of virtually all volatile organic compounds to participate in outdoor photochemistry that promote (to varying degrees) increased ground-level ozone. We also question the need to review compounds in formulations present at 0.01 percent (%) (100 parts per million) or greater. This is not consistent with ARB s Method 310, which states that, only those components with concentrations equal to or greater than 0.1 percent by weight will be reported. As we noted earlier, we fully support the references to Method 310 instead of Method 24, with the understandings noted above. Footnotes 1. Fragrance provisions requiring enforcement determinations include the definition of the term fragrance, the 2% fragrance exemption, the 100% fragrance air freshener exclusion, and various personal-fragrance-related provisions. 2. Method 310, Section

4 Green Seal thanks you your extensive comments, and particularly for your support in the change to specifying CARB Method 310 in replacement of EPA Method 24 for determining VOC content levels. Green Seal understands that CARB Method 310 was developed as an enforcement tool for regulators to determine compliance with the CARB VOC limits. However, this methodology can also be used by other organizations for determining the VOC content of the product categories included in the CARB regulations. As you have stated, the CARB VOC limits were developed to help mitigate ground-level ozone. Green Seal is concerned with these issues as well as the impacts VOCs have on indoor air quality, where most cleaning products are used. Though we understand that CARB s Method 310 sets evaluation of compounds at the 0.1% level, Green Seal has set the threshold at 0.01%, a more stringent level, to better ensure all volatile components are counted towards the overall VOC content. Our experience from product certification has shown that the 0.01% level is appropriate to ensure that significant volatile ingredients (including those in a fragrance) are counted towards the overall VOC content, while at the same time is not overly burdensome for product manufacturers or the certification process. Green Seal agrees that the cleaning industry has made significant progress in switching over to safer chemicals. However, we stand by our assessment that VOCs in cleaning products have been associated with respiratory ailments. Various sources refute the claim that VOCs in today s cleaning products are almost universally of very low toxicity and are not associated with asthma. Recent peer-reviewed articles 1,2 and a Green Seal review of MSDSs and ingredient labeling show that currently available household, institutional, and industrial cleaning products contain VOCs that are associated with respiratory toxicity and asthma. An example is monoethanolamine, an asthmagen as designated by the Association of Occupation and Environmental Clinics. In addition, VOCs commonly found in cleaning products, such as d-limonene and propylene glycol n-propyl ether, can contribute significantly to inhalation toxicity. Extensive scientific literature exists to document the connection between exposure to cleaning products and prevalence of respiratory diseases, including asthma 3,4. The 1 Bello A, Quinn MM, Perry MJ, Milton DK Characterization of occupational exposures to cleaning products used for common cleaning tasks--a pilot study of hospital cleaners. Environ Health. 8:11. doi: / X Bello A, Quinn MM, Perry MJ, Milton DK Determinants of exposure to 2-butoxyethanol from cleaning tasks: a quasi-experimental study. Ann Occup Hyg. 57(1): Zock JP, Vizcaya D, Le Moual N Update on asthma and cleaners. Curr Opin Allergy Clin Immunol. 10(2): Kogevinas M, Zock JP, Jarvis D, et al Exposure to substances in the workplace and new-onset asthma: an international prospective population-based study (ECRHS-II) Lancet. 370:

5 presence of VOCs in cleaning products is only one part of this effect, and more research is needed to understand it fully. For this reason, Green Seal s cleaning product standards include a number of protective criteria: limits on asthmagens, VOCs, and acute and chronic inhalation toxicity. Green Seal agrees that today s cleaning products are not typically formulated with carcinogenic VOCs. However, VOCs including ethylene oxide and 1,-4 dioxane are present as contaminants and byproducts in commonly-used surfactants, and these VOCs are both carcinogenic and hazardous by other mechanisms, including respiratory inhalation. Green Seal appreciates the role of fragrances in cleaning products, and our standards allow their presence. The modifications to Method 310 that you mentioned are not intended to exclude fragrances from the products, but to ensure that fragrances are included in the evaluation of total VOCs. Green Seal stands by our assessment that fragrances have been linked to health concerns 5. We will, therefore, continue to include fragrances in the calculation of total VOCs, despite their exemption from CARB Method 310. We support the proposal to reference the CARB VOC standards and test methods in Green Seal's standards. This is a practical approach since CARB has already determined that its VOC limits are achievable. It will ensure that VOC limits are strong and dynamic since CARB improves its standards over time as technologies advance. Thank you for your support. We would like to express our support of Green Seal s proposed criterion revision to align VOC limits with existing California Air Resources Board (CARB) regulations. We concur that the CARB Consumer Products Regulation set leadership levels for reduction of air emissions while still allowing for functional performance for the product categories that they cover. It may be more appropriate to reference California Code of Regulations, Divisions 3, Chapter 1, Subchapter 8.5, Article 2, Consumer Products Section than listing CARB Method 310 and a summation based on vapor pressure as acceptable procedures for determining VOC content. Section includes Method 310 and a calculation procedure. Additionally, it provides substantial details for determining Low Vapor Pressure (LVP) exemption status and a calculation process more consistent with the LVP exemption. Furthermore, AQMD and CARB have been in discussions over the acceptability of the LVP criterion, including the 0.1mm Hg vapor pressure exemption, and it is possible that there may be a re-evaluation at some time in the future. 5 Bridges, B Fragrance: emerging health and environmental concerns. Flavour and Fragrance Journal. 17:

6 We support Green Seal s proposal and look forward to a collaborative working relationship in the future. Thank you for considering our comments. Thank you for your response and for the suggestion to reference However, since the Low Vapor Pressure (LVP) exemption issue has not been resolved yet, we will continue to cite the CARB 310 methodology with the current standard language. When AQMD and CARB resolve the LVP exemption issue and incorporate it in the Consumer Product VOC Content regulations, Green Seal will consider updating our standards accordingly. Comment (This comment was submitted as a general comment, and also for each of the 8 individual standards. The comments and the responses have been consolidated here): Green Seal states in its Proposed Criterion Revision document dated 12/4/13 that The current language of the GS-37, GS-52, and GS-53 standards requires all components in a formula be reviewed for their contribution to VOC content. Green Seal is recommending a change to these standards to be consistent with the GS-8, GS-34, GS-40, and GS-41 standards to review only those components that are present at 0.01 percent (%) (100 parts per million) or greater. First of all, it is unclear why Green Seal would want to take a step backwards from the progressiveness of the more recently revised standards to make them consistent with the older, less protective standards. Why not revise the older standards to be consistent with the newer ones? We do not agree with Green Seal s assertion that reviewing components below 0.01% is unwarranted. We are especially concerned with how fragrances could be evaluated under this proposal. Fragrance is described in its GS-37 definition as often a multi-component additive. Fragrances are often comprised of dozens of components. We would like some assurance that each of the components of fragrances be reviewed for their contribution to VOC content since, taken altogether, these components could add up to an amount that might be considered significant. If that is not possible we would like Green Seal to revisit a ban on added fragrance altogether since that is what many stakeholders wanted and argued for during the revision process. Fragrances are a significant contributor to asthma. The Work-Related Asthma Prevention Program in the California Department of Public Health has tracked many asthma cases that were caused or triggered by exposure to fragrances in the workplace. While Green Seal has chosen to not prohibit fragrance from products, there is at least some reassurance under the current standard that fragrance components that are VOCs would count toward the VOC limit and that would help to limit total VOCs. We would not want to see that small assurance removed with the proposed revision. In addition, all the standards should be modified so that fragrances are not exempt from the 6

7 California Air Resources Board Method 310 determination, consistent with the wording in GS- 37, GS-52, and GS-53. Thank you for your comments. Green Seal agrees that cleaning products, particularly their fragrances, may contain dozens of volatile components that contribute to the total VOC content of a product and may contribute to asthma and other respiratory ailments. Unlike CARB Method 310, Green Seal continues to require that fragrances be evaluated toward the total VOC content. Green Seal will add this language removing the fragrance exemption from CARB Method 310 to GS-8, GS-34, and GS-41 to make all of the cleaning product standard consistent. Green Seal shares your desire to ensure the highest level of protection. However, in our evaluation of hundreds of cleaning products for VOCs, we have found that evaluating every minute volatile component below 0.01% does not increase health protection because a product would have to contain a large number of minute ingredients below the 0.01% threshold to affect the overall VOC content. Green Seal has not encountered any product where this occurs and causes a product not to meet the VOC limit criteriawe therefore consider it unwarranted to consider ingredients below the 0.01% level for VOC content. Green Seal will continue to ensure protection by evaluating fragrance ingredients that are present at 0.01% and above in the product. In addition, several Green Seal standards include additional criteria including asthmagens prohibitions and and chronic inhalation toxicity criteria, and these requirements will continue. The CARB VOC method does not include fragrances, and only evaluates compounds present at a threshold level of 0.1%. The VOC evaluation in Green Seal s standards provides additional protection by including fragrances and all components down to 0.01%, a tenth of the CARB levels. It should also be noted that the Green Seal mission to protect human health and the environment is dependent on setting standards that are feasible both for manufacturers and for the certification process. Evaluating VOC levels for compounds present below 0.01% adds a significant burden on manufacturers and the certification evaluation without providing commensurate benefits. For these reasons, Green Seal will continue to use the 0.01% ingredient cut-off level to determine the VOC content of a product in GS-8, GS-34, GS-36, GS-40, and GS-41 and will bring GS-37, GS-52, and GS-53 in line with this level. Green Seal Standard for Cleaning Products for Household Use, GS Volatile Organic Compound (VOC) Content. The VOC content of the product as used shall contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. Additionally, the VOC of the product as 7

8 used for these product categories shall not exceed the following: 1% by weight for bathroom cleaners 3% by weight for glass cleaners By summing the percent by weight contribution from all organic ingredients present in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C According to the California Air Resources Board Method 310 or equivalent. Why are carpet cleaners and general cleaning products now excluded from the standards? It is unclear why the specific limits of 1% for bathroom cleaners and 3% for glass cleaners are retained, since these are the exact current ARB limits for Bathroom and Tile Cleaner and Glass Cleaner. To fully understand our comments, please read our general comments in the General Section. Thank you for your comment. Green Seal is not proposing to change the product categories that are covered under the GS-8 standard. Green Seal will continue to include carpet and general purpose cleaners in the standard. Listing only bathroom and glass cleaner limits in the revised language was in error. To clarify the scope of the revisions and the specific levels for each class of product, Green Seal will include a table that shows each product category and its respective CARB VOC level. The standard will now read: 3.8 Volatile Organic Compound (VOC) Content. VOCs include all organic compounds that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C. VOC content means the total weight of VOCs in a product expressed as a percentage of the product weight. The VOC content of the product as used shall not exceed the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. By summing the percent by weight contribution from all volatile organic ingredients. According to the California Air Resources Board Method 310 (or equivalent), modified to include all fragrances and all volatile organic ingredients 6. 6 Evaluation of the VOC content in this standard includes all fragrances and volatile organic compounds present in the product at 0.01% or more. Evaluation of the VOC content under Method 310 exempts fragrances and all volatile organic compounds present below 0.1%. 8

9 Current CARB regulatory limits for VOCs 7. Product Category Effective Date Limit (%) Carpet cleaners (dilutable) 1/1/ Carpet cleaners (ready-touse) 1 General purpose cleaners 12/31/ Glass cleaners 12/31/ Bathroom/Restroom cleaners 12/31/ Green Seal Standard for Cleaning and Degreasing Agents, GS Volatile Organic Compound (VOC) Content. The VOC content of the product, as used, shall contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. By summing the percent by weight contribution from all organic ingredients present at 0.01% or more in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C According to the California Air Resources Board Method 310 or equivalent. CSPA supports the change from grams per liter (percent weight-volume) VOC criterion to the current ARB regulatory limits for this category. Thank you for your support. For Green Seal Standard for Cleaning Degreasing Agents, GS-34, it appears that these products used for industrial production and maintenance purposes may be subject to air district regulations. In those cases, the standard should refer to Method 24 for VOC content determination. 7 These limits are a reference to the current CARB regulatory limits and will be updated to reflect any amendments made by CARB in the future. 9

10 Thank you for your comments. After further research, we found that industrial degreasing agents used for production and maintenance purposes are not subject to any CARB or AQMD regulations. Therefore, the GS-34 standard shall continue to reference EPA Method 24. The maximum VOC content will be similar to the previous requirement; for clarity, however, the units will be changed to percent by weight, rather than g/l (i.e., 5% by weight instead of 50 g/l). A reference to CARB will be included to allow for consideration of any future CARB requirements for industrial degreasing agents. The standard will now read: 3.6 Volatile Organic Compound (VOC) Content. VOCs include all organic compounds that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C. VOC content means the total weight of VOCs in a product expressed as a percentage of the product weight. The VOC content of the product as used shall not exceed the lower of the following options: 5% by weight. The current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. By summing the percent by weight contribution from all volatile organic components present in the product at 0.01% or more. According to the EPA Method 24, or equivalent. Green Seal Standard for Adhesives for Commercial Use, GS Volatile Organic Compounds (VOC) Content. The VOC concentrations of the product, as applied according to the manufacturer s recommendations, shall contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. The volatile organic content shall be determined according to the Californian Air Resources Board Method 310, or equivalent. Additionally, for specialty applications not defined by CARB, the current regulatory limits of the South Coast Air Quality Management District (SCAQMD) Rule 1168 shall be used. We do not object to the use of ARB limits for products they regulate, and District standards for those products not regulated by the state. Thank you for your comment. 10

11 A few clarifications should be made to the proposed criterion revision. Under Green Seal Standards for Adhesives for Commercial Use, GS-36, adhesives not defined by CARB should be subject to both the VOC limits and test methodologies included in Rule 1168 Adhesives and Sealant Applications ( This would make it clear that the VOC content of adhesives subject to Rule 1168 should use the appropriate test method. Thank you for your comment regarding the determination method for specialty adhesive applications. The language has been updated to reflect the test methodology cited in Rule The standard will now read: 3.5 Volatile Organic Compounds (VOC) Content. VOCs include all organic compounds that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C. VOC content means the total weight of VOCs in a product expressed as a percentage of the product weight. The VOC content of the product as applied according to the manufacturer s recommendations shall not exceed the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. By summing the percent by weight contribution from all volatile organic components present in the product at 0.01% or more. According to the California Air Resources Board Method 310 (or equivalent), modified to include all volatile organic components present in the product at 0.01% or more 8. Additionally, for specialty applications not defined by CARB, the current regulatory limits and determination method of the South Coast Air Quality Management District (SCAQMD) Rule 1168 shall be used. Current CARB regulatory limits for VOCs 9. Product Category Effective Date Limit (%) Aerosol Adhesives (all types) 1/1/95 70 Mist Spray Adhesive (general purpose) 1/1/ Evaluation of total VOCs in this standard includes all volatile organic compounds present in the product at 0.01% or more. Evaluation of total VOCs under Method 310 exempts fragrances and all organic compounds present below 0.1%. 9 These limits are a reference to the current CARB regulatory limits and will be updated to reflect any amendments made by CARB in the future. 11

12 Product Category Effective Date Limit (%) Web Spray Adhesive (general purpose) 1/1/ Mounting, Automotive Engine Compartment, and Flexible Vinyl Spray Adhesive Polystyrene Foam and Automobile Headliner Spray Adhesive Polyolefin and Laminate Repair/Edgebanding Spray Adhesive 1/1/ /1/ /1/ Construction, Panel, and Floor Covering 12/31/ Contact Adhesive General Purpose 55 Contact Adhesive Special Purpose 80 General Purpose Adhesives 1/1/95 10 Current SCAQMD regulatory limits for VOCs 10. Product Category Effective Date Limit (%) PVC Welding 1/1/ CPVC Welding 1/1/ ABS Welding 7/1/ Plastic Cement Welding 1/1/ Adhesive Primer for Plastic 7/1/ Computer Diskette Manufacturing 1/1/ Special Purpose Contact Adhesive 1/1/ Tire Retread 1/1/ Adhesive Primer for Traffic Marking Tape 1/1/ Structural Wood Member Adhesive 1/1/ Sheet Applied Rubber Lining Operations 1/1/ Top and Trim Adhesive 1/1/ These limits are a reference to the current SCAQMD regulatory limits and will be updated to reflect any amendments made by SCAQMD in the future. 12

13 Green Seal Standard for Cleaning Products for Industrial and Institutional Use, GS Volatile Organic Compound (VOC) Content. The VOC content of the product as used shall contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. Additionally, the volatile organic compound content of the product as used for these product categories shall not exceed the following: 1% by weight for restroom cleaners 1% by weight for glass cleaners By summing the percent by weight contribution from all organic ingredients present in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C According to the California Air Resources Board Method 310 or equivalent, modified to not allow the exemption for fragrances specified under Method 310. On January 4, 2013, we called Green Seal to seek clarification on the Proposed Criterion Revision. During this conversation, Green Seal expressed to us that our comments on the standards were helpful and encouraged that we submit them formally. Therefore, as discussed by phone, we are submitting comments on the Proposed Criterion Revision for the Volatile Organic Compound Content Sections of GS-37 and GS-41. Since 2005, New York State's Green Cleaning Program has used the GS-37 and GS-41 standards as a means for determining which cleaning products are approved for use in schools (elementary and secondary) and state agencies. In general, we would be in support of the adoption of "allowable VOC limits set by the State of California's Air Resources Board (CARB), with an exception for product categories where previous editions of Green Seal's standards already set stricter limits." However, as the revised standards are currently written, it is unclear from the text what the applicable VOC limits are for some product categories. For example, under the proposed revisions to GS-37, the allowable VOC limits for general purpose and carpet cleaners will no longer be listed. CARB regulations list more than one VOC limit for each of these categories (depending on whether the product is aerosol or non-aerosol) making it difficult to determine which CARB VOC limits are being adopted in GS-37. There is a similar issue of ambiguity with the proposed revisions to GS-41, which covers "institutional hand cleaners" and "industrial heavy duty hand cleaners." VOC limits for these product categories were not listed in the revised standard and CARB regulations do not use the same product category names. CARB has VOC limits for "heavy-duty hand cleaner or soap" all forms (8%) and non-aerosol (1%). Since the names of the product categories differ between GS-41 and CARB regulations, it is unclear in the text how the CARB VOC limits are being applied to the GS-41 product categories in the revised standard. In a phone conversation about these issues, a Green Seal staff person indicated that CARB VOC limits for non-aerosols, which are more stringent than CARB VOC limits for aerosols and equally or more stringent than allowable VOC limits in the current Green Seal standards, would be adopted in the revised standards. We agree with this approach. However, we recommend that Green Seal list allowable VOC limits for each product category in the standards in order to 13

14 maintain transparency. As presented in the current proposed revisions, removing the categoryspecific information from the standards, while referring generically to CARB VOC standards when product category names differ between the two sets of standards, ultimately reduces clarity. Green Seal should also make it clear in the standards that aerosol products are not permitted under GS-37 and GS-41. GS-37 states that aerosol cans are prohibited. However, GS-37 currently has a definition for "aerosol packaging" which is only referred to in Annex D, Item G (addressing products containing microorganisms in spray packaging, which is itself confusing). We recommend that GS-37 clearly prohibit all aerosol packaging. GS-41 does not currently make any reference to aerosols, while the proposed analogous CARB VOC standard (heavy-duty hand cleaner or soap) includes separate standards for aerosol and all forms products. We recommend that GS-41 clearly prohibit all aerosol packaging. Thank you for your comments. Currently, aerosol products are prohibited from the GS-37 Standard. Any mention of aerosol packaging in the definitions of Annex D was mistakenly included and will be deleted. We thank you for your comments about the confusion regarding product categories and their VOC limits due to different nomenclature between Green Seal and CARB. In order to clarify which CARB limits are cited, Green Seal will include a table that shows each product category and the VOC content level. The standard will now read: 3.9 Volatile Organic Compound (VOC) Content. VOCs include all organic compounds that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C. VOC content means the total weight of VOCs in a product expressed as a percentage of the product weight. The VOC content of the product as used shall not exceed the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. For glass cleaners the VOC content for the product as used shall not exceed the lower of the following options: 1% by weight. The current CARB regulatory limit. By summing the percent by weight contribution from all volatile organic ingredients. 14

15 According to the California Air Resources Board Method 310 (or equivalent), modified to include all fragrances and all volatile organic ingredients 11. Current CARB regulatory limits for VOCs 12. Product Category Effective Date Limit (%) Carpet cleaners (dilutable) 1/1/ Carpet cleaners (ready-to-use) 1 General purpose cleaners 12/31/ Bathroom/Restroom cleaners (all forms) 12/31/ These comments appear to me to be quite sensible. Thank you for your comment. As noted earlier, it is unclear why the 1% restroom cleaner limit is retained, since it is equivalent to ARB s limit for Bathroom and Tile Cleaners. We remain highly concerned that the 1% VOC limit for glass cleaners allows only very light duty glass cleaners. Glass cleaners can provide usage critical to consumer safety, such as automotive windshield cleaning. When ARB proposed a 1% limit for glass cleaners a few years ago, we were able to demonstrate that such a low limit could jeopardize consumer safety; the result was that ARB adopted a 3% limit for glass cleaner. We continue to object to the requirement in this standard that Method 310 results be modified to not allow the exemption for fragrances specified under Method 310. Fragrances (along with colorants) perform important functions in supporting safe use, including providing evidence that the appropriate product is being used at the proper dilution. We believe that Green Seal should support appropriate use of fragrances in these products and be consistent with ARB and other authorities regulation VOCs in consumer products. Thank you for your comments. Green Seal realizes that the specification for restroom cleaners was done in error and it has now been removed. 11 Evaluation of the VOC content in this standard includes all fragrances and volatile organic compounds present in the product at 0.01% or more. Evaluation of the VOC content under Method 310 exempts fragrances and all volatile organic compounds present below 0.1%. 12 These limits are a reference to the current CARB regulatory limits and will be updated to reflect any amendments made by CARB in the future. 15

16 Since the issuance of the 4 th edition of the GS-37 Standard in 2008, Green Seal has certified hundreds of glass cleaners that have met the 1% VOC content limit and still demonstrated effective performance. Because of the requirement to demonstrate effective performance, the lower VOC limit for glass cleaners should not jeopardize consumer safety. As a mission-based organization, Green Seal strives to ensure the highest feasible level of health and environmental protection. Green Seal stands by our assessment that the 1% level ensures a higher protection than the 3% level, while still being achievable. Green Seal will, therefore, continue to specify the 1% VOC content limit for glass cleaners. Green Seal recognizes the value of fragrances in cleaning products, and does not exclude them in our standards. However, due to Green Seal s concern that VOCs and fragrances may contribute to poor indoor air quality and respiratory ailments, Green Seal will continue to include fragrances in the calculation of total VOCs, despite their exemption from CARB s Method 310 determination. The language of the standard now reads: 3.9 Volatile Organic Compound (VOC) Content. VOCs include all organic compounds that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C. VOC content means the total weight of VOCs in a product expressed as a percentage of the product weight. The VOC content of the product as used shall not exceed the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. For glass cleaners the VOC content for the product as used shall not exceed the lower of the following options: 1% by weight. The current CARB regulatory limit. By summing the percent by weight contribution from all volatile organic ingredients. According to the California Air Resources Board Method 310 (or equivalent), modified to include all fragrances and all volatile organic ingredients Evaluation of the VOC content in this standard includes all fragrances and volatile organic compounds present in the product at 0.01% or more. Evaluation of the VOC content under Method 310 exempts fragrances and all volatile organic compounds present below 0.1%. 16

17 Current CARB regulatory limits for VOCs 14. Product Category Effective Date Limit (%) Carpet cleaners (dilutable) 1/1/ Carpet cleaners (ready-to-use) 1 General purpose cleaners 12/31/ Bathroom/Restroom cleaners (all forms) 12/31/ Green Seal Standard for Floor-Care Products for Industrial and Institutional Use, GS Volatile Organic Compound (VOC) Content. The VOC content product as used shall contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. Additionally, the VOC content of stripper products, as used, shall not exceed 7% by weight for the least recommended amount of dilution (suitable for heavy buildup). By summing the percent by weight contribution from all organic ingredients present in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C According to the California Air Resources Board Method 310 or equivalent. We continue to believe that the 12% limit for heavy-duty stripping is more appropriate than the 7% limit in this standard, GS-40. Thank you for your comments. Since the 7% limit was set in previous editions of the GS-40 Standard, Green Seal has certified numerous floor stripper products that demonstrate effective performance. As a mission-based organization, Green Seal strives to ensure the highest feasible level of health and environmental protection. Green Seal stands by our assessment that the 7% level ensures a higher protection than a 12% level, while still being achievable. Green Seal will, therefore, continue to specify the 7% VOC content limit for floor stripping products. The standard language will read: 3.6 Volatile Organic Compound (VOC) Content. VOCs include all organic compounds that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C. VOC content means the total weight of VOCs in a product expressed as a percentage of the product weight. 14 These limits are a reference to the current CARB regulatory limits and will be updated to reflect any amendments made by CARB in the future. 17

18 For floor finish products as used the VOC content shall not exceed the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. For floor finish strippers, the product as used shall meet both of the following criteria: For the greatest recommended amount of dilution (suitable for light to medium buildup), the VOC content shall not exceed the current CARB regulatory limit. For the least recommended amount of dilution (suitable for heavy buildup), the VOC content shall not exceed 7% by weight or the current CARB regulatory limit, whichever is lower. By summing the percent by weight contribution from all volatile organic ingredients. According to the California Air Resources Board Method 310 (or equivalent), modified to include all fragrances and all volatile organic ingredients 15. Current CARB regulatory limits for VOCs 16. Product Category Effective Date Limit (%) Floor polish or wax (floor finish) Floor wax stripper (non aerosol), dilution for light or medium buildup Floor wax stripper (non aerosol), dilution for heavy buildup 1 1/1/ /1/ Evaluation of the VOC content in this standard includes all fragrances and volatile organic compounds present in the product at 0.01% or more. Evaluation of the VOC content under Method 310 exempts fragrances and all volatile organic compounds present below 0.1%. 16 These limits are a reference to the current CARB regulatory limits and will be updated to reflect any amendments made by CARB in the future. 18

19 Green Seal Standard for Hand Cleaners for Industrial and Institutional Use, GS Volatile Organic Compound (VOC) Content. The product shall not contain VOCs in excess of the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. By summing the percent by weight contribution from all organic ingredients present in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C According to the California Air Resources Board Method 310 or equivalent. On January 4, 2013, we called Green Seal to seek clarification on the Proposed Criterion Revision. During this conversation, Green Seal expressed to us that our comments on the standards were helpful and encouraged that we submit them formally. Therefore, as discussed by phone, we are submitting comments on the Proposed Criterion Revision for the Volatile Organic Compound Content Sections of GS-37 and GS-41. Since 2005, New York State's Green Cleaning Program has used the GS-37 and GS-41 standards as a means for determining which cleaning products are approved for use in schools (elementary and secondary) and state agencies. In general, we would be in support of the adoption of "allowable VOC limits set by the State of California's Air Resources Board (CARB), with an exception for product categories where previous editions of Green Seal's standards already set stricter limits." However, as the revised standards are currently written, it is unclear from the text what the applicable VOC limits are for some product categories. For example, under the proposed revisions to GS-37, the allowable VOC limits for general purpose and carpet cleaners will no longer be listed. CARB regulations list more than one VOC limit for each of these categories (depending on whether the product is aerosol or non-aerosol) making it difficult to determine which CARB VOC limits are being adopted in GS-37. There is a similar issue of ambiguity with the proposed revisions to GS-41, which covers "institutional hand cleaners" and "industrial heavy duty hand cleaners." VOC limits for these product categories were not listed in the revised standard and CARB regulations do not use the same product category names. CARB has VOC limits for "heavy-duty hand cleaner or soap" all forms (8%) and non-aerosol (1%). Since the names of the product categories differ between GS-41 and CARB regulations, it is unclear in the text how the CARB VOC limits are being applied to the GS-41 product categories in the revised standard. In a phone conversation about these issues, a Green Seal staff person indicated that CARB VOC limits for non-aerosols, which are more stringent than CARB VOC limits for aerosols and equally or more stringent than allowable VOC limits in the current Green Seal standards, would be adopted in the revised standards. We agree with this approach. However, we recommend that Green Seal list allowable VOC limits for each product category in the standards in order to maintain transparency. As presented in the current proposed revisions, removing the categoryspecific information from the standards, while referring generically to CARB VOC standards when product category names differ between the two sets of standards, ultimately reduces clarity. 19

20 Green Seal should also make it clear in the standards that aerosol products are not permitted under GS-37 and GS-41. GS-37 states that aerosol cans are prohibited. However, GS-37 currently has a definition for "aerosol packaging" which is only referred to in Annex D, Item G (addressing products containing microorganisms in spray packaging, which is itself confusing). We recommend that GS-37 clearly prohibit all aerosol packaging. GS-41 does not currently make any reference to aerosols, while the proposed analogous CARB VOC standard (heavy-duty hand cleaner or soap) includes separate standards for aerosol and all forms products. We recommend that GS-41 clearly prohibit all aerosol packaging. Thank you for your comments. Changing this standard to prohibit aerosol packing is out of the scope of this revision. Green Seal will take this into account in the future when a more comprehensive revision of GS-41 is undertaken. We thank you for your comments about the confusion regarding product categories and their VOC limits due to different nomenclature between Green Seal and CARB. To clarify which CARB limits are cited, Green Seal will include a table that shows each product category and the VOC content level. The standard will now read: 3.8 Volatile Organic Compound (VOC) Content. VOCs include all organic compounds that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C. VOC content means the total weight of VOCs in a product expressed as a percentage of the product weight. For industrial heavy-duty hand cleaners, the VOC content shall not exceed the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. For institutional hand cleaners, VOCs shall not exceed the lower of the following options: 1% by weight. The current CARB regulatory limit. By summing the percent by weight contribution from all volatile organic ingredients. According to the California Air Resources Board Method 310 (or equivalent), modified to include all fragrances and all volatile organic ingredients Evaluation of the VOC content in this standard includes all fragrances and volatile organic compounds present in the product at 0.01% or more. Evaluation of the VOC content under Method 310 exempts fragrances and all volatile organic compounds present below 0.1%. 20

21 Current CARB regulatory limits for VOCs 18. Product Category Industrial heavy-duty hand cleaners or soap Effective Date 1/1/2005 (12/31/2013) Limit (%) 8 (1) We support the revisions proposed for GS-41. Thank you for your support. Green Seal Standard for Specialty Cleaning Products for Household Use, GS *Volatile Organic Compound (VOC) Content. The VOC content of the product as used shall contain no more than the current regulatory limits of the Air Resources Board for the State of California (CARB) for its product category. For product categories not regulated by CARB, the VOC level shall not exceed 1% by weight. Additionally, the following shall apply: CARB VOC requirements for glass cleaners shall apply to optical lens cleaning products CARB VOC requirements for motor vehicle wax, polish, sealant, or glaze products shall apply to motor vehicle dressing products CARB VOC requirements for bug and tar removers shall apply to chewing gum remover products By summing the percent by weight contribution from all organic components present at 0.01% or more in the product that have a vapor pressure of greater than 0.1 mm mercury at 1 atm pressure and 20º C According to the California Air Resources Board Method 310 or equivalent, modified to not allow the exemption for fragrances specified under Method 310. We continue to object to the arbitrary 1% VOC limit included in this standard for products not regulated by the ARB Consumer Product Regulation. This provision arbitrarily eliminates the ability of many superior safe and effective products from certification. It is unclear why the provision regarding motor vehicle dressing products is retained, since all of these products appear to be regulated in the Consumer Product Regulations as Automotive Wax/Polish/Sealant/Glaze or Rubber/Vinyl Protectant. We also continue to object to the requirement in this standard that Method 310 results be modified to not allow the exemption for fragrances specified under Method 310. As we noted 18 These limits are a reference to the current CARB regulatory limits and will be updated to reflect any amendments made by CARB in the future. 21