On July 31, HCPA submitted comments to the California Air Resources Board (CARB) on their preliminary draft summary of the 2013 and 2014 Consumer & Commercial Products Survey data. HCPA’s staff and Air Quality Committee reviewed and discussed the preliminary draft summary data and supplemental materials, detailing an overview of the 491 product categories which over 1,500 household and commercial product manufacturers, formulators, and marketers participated in, providing CARB with product sales and chemical formulations for over 300,000 products sold in California. HCPA raised concerns with CARB staff about a number of our members’ products that had been recategorized. We asked that CARB work with our members and review the labels of the products in these categories to ensure proper recategorization of all products.
It is critical to ensure that this data is as accurate as possible since it will shape future volatile organic compound (VOC) regulations. Companies spend significant time and resources to develop new formulations to comply with VOC regulations, which in addition to being reasonable and feasible, should be based upon the most accurate data possible.
HCPA has been working with CARB staff on their Consumer Products Regulation since the 1980s.