Manager, Technical Evaluation Section
Stationary Sources Division
1001 I Street
PO Box 2815
Sacramento, CA 95812
Dear Ms. Takemoto,
The scientists and public health advocates of Environmental Working Group strongly support the California Air Resources Board’s continuing efforts to improve air quality for all Californians. The proposed 2008 amendments to CARB’s Consumer Products Regulation contribute to this goal through both more health protective volatile organic chemical (VOC) standards for a variety of previously regulated product classes, and the addition of VOC standards for new product classes, including odor removers, auto and tire cleaners, windshield water repellants, personal care astringents, toners, and products used after shaving, and floor spray buff.
We write to encourage CARB to take this opportunity to establish stronger standards regarding professional cleaning products, paint and lacquer thinners, and multipurpose solvents. In addition, we request that CARB outlaw dibutyl phthalate when establishing standards regarding nail coatings. Finally, we urge the Board to carefully consider the toxicity of potential substitutes that industries will use in replacing high VOC compounds, to ensure that air quality and public health protections are maintained as companies transition away from the VOCs targeted in these amendments.
The South Coast Air Quality Management District has recommended establishment of three new product categories, Industrial and Institutional (I&I) General Purpose Cleaners, I&I General Purpose Degreasers, and I&I Glass Cleaners. Based on extensive research, including product testing of readily available low-VOC alternatives, SCAQMD has found a 1 percent by weight VOC content limit to be “commercially and technologically feasible,” and to meet the requirement of Health and Safety Code 41712, which calls for regulations that maximize feasible VOC reductions.
Reducing the levels of volatile chemicals in professional cleaning products will reduce outdoor exposures to a number of toxic chemicals and byproducts. We note as well the likelihood of a significant improvement to public health due to improved indoor air quality, an important, additional benefit that would stem from CARB’s actions in this area.
Industrial and institutional cleaners are used in a variety of public settings encountered by Californians every day. Exposure to these products can contribute significantly to health conditions in school children and workers throughout the state. For example, two recent surveys of asthma in the health care industry indicate a strong link between exposure to housekeeping chemicals and both the development of this debilitating condition in adulthood (Delclos et al. 2007), as well as the onset of an asthma attack (Pechter et al. 2005). Therefore, we call on the Board to adopt the SCAQMD recommendations for 1 percent by weight VOC limits for I&I General Purpose Cleaners, I&I General Purpose Degreasers, and I&I Glass Cleaners in the 2008 amendments to the Consumer Products Regulation.
The 2008 amendment lists two consumer product categories, Paint and Lacquer Thinner and Multipurpose Solvent, as under consideration for future regulation. We ask that CARB establish health protective VOC limits to these product categories now, based on the availability of low-VOC alternatives.
Industries within the South Coast Air Quality Management District have already achieved compliance with a 2.5 percent by weight VOC limit through use of safer products. Unfortunately, hobbyists and home-based businesses continue to have access to high-VOC products. These consumers are likely to be less educated about the health hazards associated with high-VOC products, and in addition may lack ready access to appropriate safety gear, resulting in a more significant public health concern due to intense exposure. We urge the Board to implement appropriate health protective standards for Paint and Lacquer Thinner and Multipurpose Solvent, given successful industry transition to low-VOC alternatives in Southern California.
Regarding the consumer product category of Nail Coatings, which may be regulated pending peer review of the updated Maximum Incremental Reactivity method, we join with the California Healthy Nail Salon Collaborative to request that CARB ban dibutyl phthalate (DBP) from all such products. Recent epidemiological studies of ordinary Americans link body levels of DBP metabolites with reduced levels of sperm motility and concentration, and alterations in hormone levels in adult men (Duty et al. 2003, 2004, 2005). A recent study of 134 births found marked differences in the reproductive systems of baby boys whose mothers had the highest DBP metabolite measurements during pregnancy (Swan et al. 2005). Further research documented decreased testosterone levels among baby boys exposed to these metabolites in their mother's breast milk (Main et al. 2006).
Despite these disturbing findings, the Board has been reluctant to implement health standards concerning DBP, given that exposure is assumed to occur largely indoors. However, a CARB study measuring indoor and outdoor levels of phthalates around homes in Riverside, CA detected quantifiable levels of DBP in outdoor air, though at lower levels than present inside homes (CARB 1992). Outdoor air surrounding nail salons using products containing DBP would undoubtedly have substantially higher levels of this chemical, levels that could justify removal of this chemical from Nail Coatings through the Consumer Products Regulation.
While many cosmetics companies have chosen to voluntarily remove DBP from their nail care products, only outlawing DBP can assure that this chemical is not included in future formulations. We ask the Board to protect the health of all Californians by establishing safety standards that result in reduced exposure to this contaminant from indoor and outdoor air sources.
Finally, we ask that CARB carefully investigate the toxicity of alternatives to the high-VOC chemicals currently in use in the consumer products listed in this amendment, to assure that substitutions made by industry to meet the VOC limits do not result in harm to public health. A pertinent example is that of the recent phase-out of chlorinated solvents in specific products. Lacking appropriate safeguards based on such an analysis of alternate chemicals, use of n-hexane as a replacement has led to high exposures and significant health effects in auto workers in California (MMWR 2001). We therefore urge the Board to implement a strategy to prevent this type of misstep in the future, in products regulated through either VOC weight limits, or the Maximum Incremental Reactivity method.
We thank CARB for its efforts to protect human health and the environment from the effects of toxic air contaminants. We look forward to working with the Board to improve the upcoming amendment to the Consumer Products Regulation.
Rebecca Sutton, Ph.D.
Environmental Working Group
1904 Franklin St., Suite 703
Oakland, CA 94612
CARB (California Air Resources Board). 1992. PTEAM: Monitoring of phthalates and PAHs in indoor and outdoor air samples in Riverside, California. Final Report, Volume II, Contract No. A933-144. Available at: http://www.arb.ca.gov/research/abstracts/a933-144.htm#Section
Delclos GL, Gimeno D, Arif AA, Burau KD, Carson A, Lusk C, Stock T, Symanski E, Whitehead LW, Zock JP, Benavides FG, Anto JM. 2007. Occupational risk factors and asthma among healthcare professionals. American Journal of Respiratory and Critical Care Medicine 175:667-675.
Duty SM, Silva MJ, Barr DB, Brock JW, Ryan L, Chen Z, et al. 2003. Phthalate exposure and human semen parameters. Epidemiology 14(3): 269-277.
Duty SM, Calafat AM, Silva MJ, Brock JW, Ryan L, Chen Z, et al. 2004. The relationship between environmental exposure to phthalates and computer-aided sperm analysis motion parameters. Journal of andrology 25(2): 293-302.
Duty SM, Calafat AM, Silva MJ, Ryan L, Hauser R. 2005. Phthalate exposure and reproductive hormones in adult men. Human reproduction 20(3): 604-610.
Main KM, Mortensen GK, Kaleva MM, Boisen KA, Damgaard IN, Chellakooty M, et al. 2006. Human breast milk contamination with phthalates and alterations of endogenous reproductive hormones in infants three months of age. Environmental health perspectives 114(2): 270-276.
MMWR (Morbidity and Mortality Weekly Review). 2001. n-Hexane-related peripheral neuropathy among automotive technicians - California, 1999-2000. Morbidity and mortality weekly review 50(45):1011-3. Available at: http://www.cdc.gov/mmwr/preview/mmwrhtml/mm5045a3.htm
Pechter E, Davis LK, Tumpowsky C et al. 2005. Work-related asthma among health care workers: surveillance data from California, Massachusetts, Michigan, and New Jersey, 1993-1997. American Journal of Industrial Medicine 47:265-275.
Swan SH, Main KM, Liu F, Stewart SL, Kruse RL, Calafat AM, et al. 2005. Decrease in anogenital distance among male infants with prenatal phthalate exposure. Environmental health perspectives 113(8): 1056-1061.