CSPA Comments on CARB Survey Data Expands VOC Emissions Inventory Corrections
March 30, 2016
This week, staff from the California Air Resources Board (CARB) has confirmed that based on CSPA comments, they would be expanding corrections to its VOC emissions inventory.
Earlier this month, the CSPA Air Quality Committee submitted comprehensive comments to the California Air Resources Board (CARB), relating to CARB’s draft proposals on how to correct data reported in the 2013 Consumer & Commercial Products Survey to update the state’s volatile organic compound (VOC) emission’s inventory. The CARB proposals provided for review included: 1) a list of ingredients reported with proposed VOC classifications; and, 2) a list of categories proposed to be corrected for alternative fates that do not involve all of the VOCs being emitted to the air during product use. CSPA comments urged that numerous ingredients were improperly categorized as VOCs and that the amounts of VOCs that have alternative (non-air) fates were far greater than proposed.
CSPA comments identified 65 of the 553 ingredients as being incorrectly categorized regarding their status as VOCs, low-vapor-pressure-VOCs (LVP-VOCs), or various types of non-VOCs. CSPA comments also identified 39 additional product categories that should be corrected for alternative fates in addition to the 55 categories that CARB had proposed. CSPA also identified additional types of alternative fates to add to the two identified by CARB (down-the-drain and combustion), and urged that the proposed inventory corrections by increased based on specific data from relevant fate studies.
CARB staff confirmed last week that based on CSPA comments, and the additional data they conveyed, they would correct the VOC status for most of the 65 ingredients identified by CSPA, and added eight product categories to the list to be subject to fate corrections in the eventual inventory update. CARB staff asked for additional studies to make the further fate adjustments CSPA recommended. CSPA will be working with partner associations across the consumer products industry to design and fund further studies to quantify the alternative non-air fates of VOCs and LVP-VOCs in a broad array of other product categories.
CARB staff also informed CSPA last week that the first use of the corrected 2013 Survey data will be used as the basis for VOC Fees that are paid by consumer products companies each year whose use of VOCs in products results in VOC emissions in the state exceeding 250 tons annually.
For further information, or to get involved in these efforts, please contact Senior Science Fellow D. Douglas Fratz at dfratz@cspa.org or 202-833-7304.
This week, staff from the California Air Resources Board (CARB) has confirmed that based on CSPA comments, they would be expanding corrections to its VOC emissions inventory.
Earlier this month, the CSPA Air Quality Committee submitted comprehensive comments to the California Air Resources Board (CARB), relating to CARB’s draft proposals on how to correct data reported in the 2013 Consumer & Commercial Products Survey to update the state’s volatile organic compound (VOC) emission’s inventory. The CARB proposals provided for review included: 1) a list of ingredients reported with proposed VOC classifications; and, 2) a list of categories proposed to be corrected for alternative fates that do not involve all of the VOCs being emitted to the air during product use. CSPA comments urged that numerous ingredients were improperly categorized as VOCs and that the amounts of VOCs that have alternative (non-air) fates were far greater than proposed.
CSPA comments identified 65 of the 553 ingredients as being incorrectly categorized regarding their status as VOCs, low-vapor-pressure-VOCs (LVP-VOCs), or various types of non-VOCs. CSPA comments also identified 39 additional product categories that should be corrected for alternative fates in addition to the 55 categories that CARB had proposed. CSPA also identified additional types of alternative fates to add to the two identified by CARB (down-the-drain and combustion), and urged that the proposed inventory corrections by increased based on specific data from relevant fate studies.
CARB staff confirmed last week that based on CSPA comments, and the additional data they conveyed, they would correct the VOC status for most of the 65 ingredients identified by CSPA, and added eight product categories to the list to be subject to fate corrections in the eventual inventory update. CARB staff asked for additional studies to make the further fate adjustments CSPA recommended. CSPA will be working with partner associations across the consumer products industry to design and fund further studies to quantify the alternative non-air fates of VOCs and LVP-VOCs in a broad array of other product categories.
CARB staff also informed CSPA last week that the first use of the corrected 2013 Survey data will be used as the basis for VOC Fees that are paid by consumer products companies each year whose use of VOCs in products results in VOC emissions in the state exceeding 250 tons annually.
For further information, or to get involved in these efforts, please contact Senior Science Fellow D. Douglas Fratz at dfratz@cspa.org or 202-833-7304.