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                           DISCLAIMER
This report has been reviewed by the Emission Standards Division
of the Office of Air Quality Planning and standards, EPA, and
approved for publication.  Mention of trade names or commercial
products is not intended to constitute endorsement or
recommendation for use.   Copies of this report are available
through the Library Services Office (MD-35), U.S. Environmental
Protection Agency, Research Triangle Park NC 27711, or from
National Technical Information Services, 5285 Port Royal Road,
Springfield VA 22161.
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                                   CONTENTS


1.0     Introduction	  i"1


2.0     Symposium Speakers	  2-1


        Dav One.  November 14.  1989


        2.1  John O'Connor,  Deputy Director
             Office of Air Quality Planning and Standards
             U.S. Environmental  Protection Agency

             Opening Remarks	  2-1


        2.2  John Calcagni,  Director
             Air Quality Management Division
             Office of Air Quality Planning and Standards
             U.S. Environmental  Protection Agency

             Overview of VOC Regulatory Programs and the Nonattainment
             Problem	  2-1


        2.3  Bill Harnett
             Emission Standards Division
             Office of Air Quality Planning and Standards
             U.S. Environmental  Protection Agency

             Status of the Clean Air Act Amendments	  2-7


        2.4  Brock Nicholson
             Chief, Policy Development Section
             Air Quality Management Division
             U.S. Environmental  Protection Agency

             Possible EPA Control Strategies for Consumer Products	  2-12


        2.5  Ralph Engel, President
             Chemical Specialties Manufacturers Association

             Industry's View of Regulating Consumer Products	  2-14
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                           CONTENTS
                          (Continued)
2.6  John Chamber!in
     Office of Policy, Planning, and Evaluation
     U.S. Environmental  Protection Agency

     Use of Market-based Approaches to Reduce VOC Emissions
     from the Use of Consumer Products	  2-23
Dav Two. November 15. 1989
2.7  James Weigold, Deputy Director
     Emissions Standards Division
     Office of Air Quality Planning and Standards

     Opening Remarks	  2-31

2.8  Dean Simeroth
     Chief, Criteria Pollutants Branch
     California Air Resources Board

     California Regulatory Activities	  2-32


2.9  Ted Wernick
     Gillette Medical  Evaluation Laboratory

     Reformulation and Safety Testing - Their Timing and
     Costs	  2-38

2.10 Ted Davis
     Acting Assistant Director, Division of Air Resources
     New York Department of Environmental Conservation

     New York Regulatory Activities	  2-46


2.11 Edward Heiden, President
     Heiden Associates, Inc

     The Socioeconomics of Regulating Consumer Products	  2-51


2.12 Sandra Chen
     Supervisor, Bureau of Engineering and Regulatory
     Development
     New Jersey Department of Environmental Protection

     New Jersey Regulatory Activities	  2-59


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                                   CONTENTS
                                  (Continued)

        2.13 Michael  Kosusko
             Organics Control  Branch
             Air and Energy Engineering Research Laboratory
             U.S. Environmental  Protection Agency
             EPA Research Toward Reduction of VOC Emissions from
             Consumer Products	  2-65

3.0     Work Group Summaries	  3-1

        3.1  Personal Care Products	  3-1
        3.2  Household Care Products	  3-4
        3.3  Automotive Products	  3-8
        3.4  Household Pesticides	  3-11
        3.5  Adhesives and Sealants	  3-15
        3.6  Aerosol Paints	  3-20

4.0     Agenda and Attendees	  4-1
        4.1  Agenda	  4-2
        4.2  Product Category Work Groups	  4-4
        4.3  List of Attendees	  4-6

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                              1.0  INTRODUCTION

     The failure of at least 66  metropolitan areas in the United States to
attain the National Ambient Air  Quality Standards (NAAQS) for ozone by
December 31,  1987,  is one of the major environmental  issues currently faced by
the Environmental Protection Agency (EPA).   Over 100 major metropolitan areas,
representing  one third of the U.S.  population, are exposed to excessive levels
of ozone.  In addition, the EPA  announced in July 1989 that 37 additional
areas are now violating the ozone NAAQS as  a result of high 1988 measured
ozone concentrations.  Consequently,  the EPA is developing regulatory
strategies to control emissions  of volatile organic compounds (VOC's) and to
further reduce ozone levels in the ambient  air.
     The EPA's strategy for controlling ozone focuses primarily on control of
VOC's that react in the presence of sunlight and other pollutants to form
ozone.  During the last dozen or so years,  the EPA has developed regulations
for major industries that release VOC's to the atmosphere.  The EPA has  also
implemented regulations for automobiles, whose exhausts  are a major source of
VOC emissions.  Most of the remaining sources of VOC emissions are small or
dispersed and have been categorized as area sources.  Area sources of VOC
emissions include, but are not limited to,  solvent cleaners, commercial  dry
cleaners, sites where  architectural surface coatings are being applied,  and
commercial and consumer applications of a wide range of  products containing
solvents.  Estimates of VOC emissions from area  sources  indicate that they
comprise a major emissions source.  Thus, the EPA has targeted area sources
for regulation.
     One measure being investigated by the EPA to address  the ozone
nonattainment problem  is the development of control  techniques and regulations
to reduce VOC emissions from the use of a variety of consumer products.   In
order to determine the nature of consumer products as a  source of  VOC
emissions and to examine the possible emission controls  applicable to consumer
products, the EPA  is undertaking an examination  of the formulation, use,  and
emissions potential  of these products.
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     On November 14 and 15, 1989, the EPA held a Symposium on "Regulatory
Approaches for Reducing VOC Emissions from the Use of Consumer Products."  The
objectives for the symposium were the following:

     1.   Communicate to the consumer products industry that the EPA is
          considering approaches for regulating VOC emissions from the use of
          consumer products.

     2.   Initiate a dialogue among the EPA, the States, and the consumer
          products industry.

     3.   Provide a forum for discussing the views of the industry, the
          States, and the EPA regarding the implementation of alternative
          control measures and regulatory approaches to reduce VOC emissions
          from the use of consumer products.

     4.   Develop agreements for continued  industry and State participation  in
          the EPA's investigations of approaches for reducing VOC emissions
          from the use of consumer products.

     Approximately 100 different companies  and trade associations  involved  in
the consumer products industry were contacted and  invited to participate  in
the symposium.   State regulatory agencies currently involved in the regulation
of consumer product VOC emissions were also invited.  A list of participants
and their affiliation is found  in Section 4.0.
     The symposium consisted of a combination of industry and government
presentations, and work group sessions.  There was one work group  for  each  of
six product categories: household care products, personal care products,
automotive products, household  pesticides,  adhesives and sealants, and aerosol
paints.  Each work group was composed of one  industry and one government  co-
chair, and approximately 10 representatives from industry and government.
Work group members were generally  individuals with expertise or knowledge
pertinent to regulation of  their specific product  category.  Each  work group
also accommodated  an audience of approximately  25  interested observers,  with

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limited participation of the observers at the discretion of the individual
work groups.  The groups addressed regulatory issues and questions as they
pertain to their respective segments of the consumer products industry.
     These proceedings include the industry and government presentations made
during plenary sessions (Section 2.0) and summaries of each work group's
discussion and recommendations (Section 3.0).  The plenary session
presentations have been transcribed from tape recordings; the work group
sessions have been summarized by the work group recorders and circulated to
work group participants for comment.
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                           2.0  SYMPOSIUM SPEAKERS

DAY ONE, NOVEMBER 14, 1989

2.1  JOHN O'CONNOR, Deputy Director
     Office of Air Quality Planning and Standards
     U.S. Environmental Protection Agency
     Opening Remarks
     The Symposium on Regulatory Approaches for Reducing VOC Emissions from
the Use of Consumer Products is a unique opportunity for initiating a dialogue
between the EPA, State agencies, and the consumer products industry.  This
symposium is particularly important as the EPA begins to evaluate possible
regulatory approaches for reducing emissions of VOC.  The timing of this
meeting  is also very opportune.  Right now, the EPA  is  in the midst of Clean
Air Act debates; this  issue will be discussed later  in  the morning.   In the
United  States, there is a very widespread nonattainment problem with  respect
to the  Ozone Standard that is going to require that  some unusual measures be
taken.  The EPA's  goal for the last ten years has been  to reduce VOC
emissions, and essentially all effort has focused on the regulation of large
major stationary sources  and automobiles.  The remaining source categories  to
be examined are small, widely dispersed sources.  That  is the reason  for
sponsoring this symposium today.  The EPA must begin to address consumer
products as an area  source for VOC emissions.   [Mr.  O'Connor went on  to
discuss the Research Triangle Park area and describe the functions  of the
various EPA offices  in this area.]

2.2  JOHN CALCAGNI,  Director
     Air Quality Management Division
     Office of Air Quality Planning and Standards
     U.S.  Environmental  Protection Agency
     Overview of VOC Regulatory  Programs and  the Nonattainment  Problem
     The idea for  this symposium predates  the EPA's work  on  the Clean Air Act.
Last year  the EPA  became  aware of  a number  of concerns, concerns  of our  own,

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concerns of the States, and concerns of the Chemical  Specialties Manufacturing
Association.  In general, there was a fear that the EPA was vulcanizing the
rule-making process for consumer and commercial solvents, that individual
States were taking individual approaches and developing rules; there appeared
to be a need for national involvement in a development of a regulatory
structure in this area.  As an agency, the EPA does not have a lot of
experience or background in the regulation of this industry, and it was
generally felt that, before moving into any kind of active program, the Agency
would need a lot more  information.  This symposium is the start of the
information gathering  process.  The EPA has conducted some research for
development of an information base, but sponsoring this symposium  is a novel
way for the EPA to begin the process of developing a regulatory structure.
The consumer products  industry  is  a very diverse industry, one that probably
does not think of itself in the same way that  EPA thinks of industries.  Many
present at this workshop have not  dealt with one another and  are not
accustomed to being grouped together.  The EPA hopes to  informally gather
information and begin  dialogue.   It  is also hoped that  industry will gain  an
understanding of the regulatory approaches the EPA is considering, and get a
look at the proposed Clean Air  Act amendments.   In addition,  this  symposium
will include a discussion of the  efforts of  individual  States that are moving
in this area, and give some  background as  to why the  EPA thinks this  is  an
area which  requires regulation.
     The EPA hopes  that industries will cooperate  in  the search for better
regulatory  solutions.   Regulatory solutions  have typically been  "we are  from
Washington  and we  are  here to  help."   We  realize that  none of you  look forward
to regulation, but  if  we work  together in  this kind  of  forum, we  can  come  up
with the best  possible solution in terms  of  how  to regulate in  an  efficient
and  effective  manner  that  achieves our objectives  and maintains your  goals,
without hamstringing  you unnecessarily in  areas  where we have no  need to
 impact you.   EPA hopes to  develop some agreements  to continue after this
meeting to present and share ideas, develop new  concepts,  and develop further
the  concepts  that are nurtured here at these sessions.
      For the  purposes of this symposium,  we would  like to have a few
 assumptions for the dialogue that will go on today.   We do not mean to
 preclude your ability to raise these issues at other forums.   But in order to

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make our time more useful, there are certain assumptions we would like to work
within.  The first assumption is that we are talking of a Federal regulatory
structure and the best way to go about it.  Debates on whether or not there
ought to be Federal regulation in this area will probably not be very useful
today.  You will have your opportunity to discuss that issue at length before
the EPA reaches a rulemaking stage.  The other area where the EPA would like
to limit discussion concerns reactivity and product substitution.  Development
of strategies related to reactivity will detract from what the EPA is trying
to accomplish at this symposium.  We want to begin with the assumption that we
are looking at the reduction of the VOC's to be used in products, and pursue
the alternatives along those lines.  Once again, the EPA does not want to
preclude your ability to raise these issues in other forums, and your
involvement here does not mean that you accept those concepts.  For the
purposes of moving forward, however, and developing a regulatory structure
over the next two days, we would like to use those assumptions  in the work
group discussions.
     With regard to the format, EPA has contacted a number of  industry
representatives and we particularly want to thank Ralph Engel  for serving as
liaison.  Each morning session will consist of presentations from Federal and
State government officials.  Afternoon sessions will be broken  into six work
groups.  The work groups will be:  personal care products, automotive
products, adhesives and sealants,  household care products, household
pesticides, and spray paints.  Each group will be co-chaired by one government
and one  industry representative, and approximately ten people  have been
assigned to each group based on their specific expertise and knowledge.   In
addition, other interested observers and participants can  attend the work
group  sessions.  The primary function of the work groups  is to  address
regulatory  issues  and questions that may pertain to the specific segments of
the consumer product  industry.  There is an appendix to the background paper
that was sent to you, and  it has nine questions on  it.  These  questions  should
be used  as  a focus for discussion.  At the  end  of the second day, each work
group  will  report  a summary of the findings of  the entire  group.
      In  conclusion, the EPA would  like to personally thank all  of you  for your
interest, not just in attending this symposium, but also your  interest  in
working  with us  in developing a regulatory  structure for consumer solvents  and

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consumer products as we proceed in the future.

Overview of VOC Regulatory Programs and Non-Attainment Problems

     Ozone is not directly emitted by consumer products.  The precursors to
ozone formation, hydrocarbons and nitrogen oxides, are released in urban areas
at the approximate ratio of 5:1 hydrocarbons to nitrogen oxides.  Major
sources of VOC are industrial, automotive, some natural sources, and consumer
solvent products.  With regard to oxides of nitrogen, power plants and
automobiles are responsible for about 90% of the emissions.  Oxides of
nitrogen are emitted as NO, and react with hydrocarbons.  NO converts to N02
fairly quickly, with a half-life of about one-half hour.  The key compound in
the reaction is N02.  N02 generally reacts with hydrocarbons consistently over
a three-hour period, peaking  in the middle afternoon.  Other factors that
affect the peak of ozone concentrations are heat and sunlight.  The higher the
sunlight, the higher the heat, and the higher the concentrations of oxides of
nitrogen, thus the higher the  afternoon ozone peaks.  The peak  tends to rise
in early afternoon and drop off late  in the afternoon as the plume  is
transported out of the area.   Those who live in the  northeast  corridor will
recognize that residual ozone  from one day  can participate  in  a second day
reaction and a third day reaction  as  the  air mass moves up  the  East Coast.
Thus, emissions of hydrocarbons  in Virginia could impact ozone  levels  in  two
or three days  as  far north  as  New  York City and Boston.  The EPA  has measured
plumes of ozone more than  200  miles over  the ocean.   We have measured
exceedances  in Acadia  National Park that  are attributable  to plumes from
Boston and New York City.   So as you  see, these plumes  can  move quite  a
distance  and cover  a large  geographic area.
      On  the west  coast,  the ambient ozone standard  of 0.12 ppm is exceeded  on
the  average  about 100  days  every year.   The Northeast corridor has between  25
and  35  days  that  exceed  the ambient  standard,  with  the rest of the country
 (with the exception  of Houston)  exceeding the  standard for 5 to 10 days per
year.  This  should  give  some relative sense of the  degree  of seriousness  of
the  problem.   With  regard  to the magnitude  of  these peaks; a plot with a
 summation of 274 sites is  an approximation  of  the EPA's design value.
 [Mr. Calcagni  then  showed  slides depicting  historical ozone trends in  the

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United States and non-attainment areas.]  The ambient standard of 0.12 ppm is
not to be exceeded more than once per year on a three-year average.  The key
message here is that even as a national average, we are not achieving the
standard.  Over half the monitors in the country are showing violations, and
many of them are showing violations that are 2-1/2 times the standard.
     To give another sense of where the violations are occurring, the EPA has
prepared a map that shows the non-attainment areas.  In general, populated
areas probably have an ozone exceedance.  The areas that are not showing
exceedances at this point in time are marginal.  Kansas City is marginal, but
the Gulf Coast area, Houston, southern California, the Northeast corridor from
Washington up to Maine, and the Lakes area around Chicago probably have ozone
violations.  With regard to the sources of VOC, this is a relatively
ubiquitous pollutant.  If a production process  involves a petrochemical, VOC
will be emitted.  Approximately 35% of VOC emissions are from mobile  sources.
These motor vehicle losses are from the evaporation of hydrocarbons from the
carburetor and the gas tank, as well as exhaust emissions.  Presently,  about
two-thirds of the automotive emissions are from evaporative losses of
gasoline.  About 9.6% of VOC is emitted from the  industrial category.   This  is
the major  100 ton source.
     Area  sources account for 29.5% of the inventory,  including  solvents from
numerous products, degreasers, dry cleaners, consumer/commercial products,
industrial maintenance solvents, and paints that  are used  in coatings.   Other
area sources  include gasoline facilities  and service stations.   To give more
information on the consumer products sources,  the  consumer  sector  of  the area
sources encompasses 7% of the total.   Though 7% sounds like a  small number,
the Agency is faced with controlling industrial source categories  that  might
include  1  or  2%  in aggregate contribution.  The Clean Air Act  established
automotive tail  pipe emission standards and ambient  air quality  standards  for
the criteria  pollutants.
     The EPA  has conducted  a lot work  on  the health  effects following ozone
exposure.  At ambient ozone  levels, adverse effects  can be  measured  in  healthy
people.  Unlike  most regulated pollutants, the ambient Ozone  Standard does not
have a  safety factor of  10  built  into  it.  At  ambient  levels  normal,  healthy
people  can show  effects.  Tests  in California  indicate that some of  these
effects, particularly those  in children,  are likely  to be  irreversible.

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Research conducted from 1978 to 1985 has shown that ozone is a very potent
chemical which can have a very adverse affect on the lungs.   Existing
regulatory pressures indicate tightening of the standard, not relaxing of it.
     The Clean Air Act is structured such that the EPA is required to
establish an ambient air quality standard for ozone, and individual States are
required to develop and adopt attainment plans, called state implementation
plans or "SIP's".  In general, States have primacy in the adoption of
regulation.  The Clean Air Act originally established attainment dates from
1975 to 1977.  These dates were revised in 1977 to 1982 and 1987, primarily
1987.  The 1987 deadline has now passed, and the Clean Air Act is being
revised once again.  In the next presentation, Bill Harnett will talk about
the proposed Clean Air Act revisions and some of the implications, but
generally, we are looking at a maximum of 20 years, generally on the order of
10 years for most parts of the country, to attain the Ozone Standard.  In the
1977 Amendments, the Clean Air Act established some minimum requirements for
extension, including transportation measures and an  inspection maintenance
program.  The intent of Congress was to take a number of measures  that they
know to be effective and  insist that they be done,  but give States time  to
achieve attainment.  This attitude should prevail  in the amendments  of 1989-
90.
     In terms of mobile  sources, the average of emissions from  all cars  has
come down  quite  significantly  for hydrocarbons  and  carbon monoxide.   Prior to
1981,  there  was  a  major  difference between the  standards and  what  the average
new  car would achieve.   Since  1981,  newly manufactured  vehicles  have been  very
clean.  The  average  of all  cars, however,  is  still  higher because  the typical
vehicle on the  road  is  10 years old.   By the year  1991,  however, most of the
fleet  will have  turned over.   A six-year fleet  average  is typical,  and it
takes  10  to  15  years to  get the old  cars off  the  road.   By  1991,  the major
benefits  of  the motor vehicle program will  largely have been  accomplished.
     The  EPA expects a major upturn  in the  total  VOC emissions  unless
additional  controls  are  placed on  stationary sources.   The  motor vehicle
 inspection program is an example  of a regulatory  program that has directly
 affected  the public in  a way that  is very  visible to them.   The EPA has  also
 published a  number of Control  Techniques Guidelines.  These serve as templates
 for the States  to use in adopting  regulations for certain industrial

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categories.  The States can adopt different regulations, but generally the EPA
tries to ascertain whether a given State has a unique situation before it is
allowed to vary from the EPA's Control Techniques Guideline.
     While the EPA has seen some major reductions in the motor vehicle program
and in the industrial source category, there are other potential reductions
that have yet to be achieved.  The consumer solvent area is one area where
significant attention is expected in the next three to five years, and that is
the reason for this symposium.  VOC emission controls will be applied more
effectively to existing sources, to a wider variety of sources, and to the
smaller sources categories.  And as we look forward to the future, VOC control
will become increasingly more stringent as we move into our regulatory
programs.  With regard to consumer solvent programs, it must be kept  in mind
that a number of States have already moved to control this area source.
New York, New Jersey, Texas, and California have all addressed  regulations  in
these areas because of litigation and commitments  in their State plans to  show
attainment.  The current Clean Air Act Amendments  specifically  mention
consumer solvents as  an area for the  EPA to study  and to regulate.   In some of
the later bills, the  EPA is directed  to move directly to regulation with
relatively tight dates.  A report is  to be completed in two years, and in  many
cases regulations are to be addressed  in three years.   In conclusion, there  is
significant pressure  to regulate  in this area, and even  if the  Clean  Air Act
Amendments do not pass, the litigation  structure  is  such that we may  see  50
states moving independently to  adopt  some  rules on sources  in these
categories.

2.3  BILL  HARNETT
     Emissions  Standards Division
     Office of  Air  Quality Planning and Standards
     U.S.  Environmental Protection Agency
     Status of  the  Clean Air Act Amendments
     The  EPA's  analyses are  starting  to show  that  the VOC  inventory  from
mobile  sources  and  large stationary sources  is going to account for  less of
the  total  VOC  inventory  in the  future,  while  the  VOC contribution  from  small
sources  and consumer products will  increase over  time.   The  EPA studies  and
the  Office of Technology Assessment studies both  show this  trend.   The picture

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that is emerging, and it is emerging in the bills that are coming forth, is
while there is still more pressure to keep tail pipe emissions down, at some
point the EPA will have to look at sources not previously addressed.  The
problem that exists, however, is that not a lot is known about the
significance of consumer products in the emissions inventory, or what can be
done to reduce emissions.
     On the Federal level, there are two bills proposed right now; one  in the
House and one in the Senate.  They have slightly different provisions related
to consumer solvents.  The House started with the President's Bill (H.R. 3030)
that requires a two-year study on consumer products and VOC emissions.  At the
end of the study the EPA is to develop regulations as appropriate.  The bill
has since been marked up in a Subcommittee and passed on to the Commerce and
Energy Committee.  At the present time, Committee Chairman John Oingell does
not want to bring  it in to the full Committee for mark up until after the
first of the year.  In the Senate, they moved  in their own direction with
Bill No. 1630 that deals only with the nonattainment problems and with  motor
vehicles.  Their provision  is also for a two-year study, followed by
regulations within one and two years with  an overall mandate to reduce
consumer solvents  or reduce national emissions from consumer solvents down  to
3% reduction of  the current  inventory.  Senate Bill 1630 has been marked up  in
the Subcommittee.   In July, when the President's proposal came out, the House
moved quickly to push the  President's bill through Committee mark-up.   The
Senate was waiting  to develop  its own bill.  The EPA had hoped that the Senate
would also use the Administration vehicle.   It  is easier for the  two  parties
to come together if they accept the  same base.  The Senate did not  accept  the
base, so now there are a lot of differences  to be worked out.  It  is  George
Mitchell's hope  that the Senate bill will  come to a vote before they  break  for
Thanksgiving.  Mitchell  definitely wants to  address  it  before they  break for
the year.  There has been  pressure  on John Dingell to do the  same,  to get  the
bill out to  the  floor  and  get  a vote on  it this year  and  attempt  to work out
their differences.   One  of the  reasons  that  the  President  hoped  to  sign a  bill
 in January  1990  was to welcome  in  the decade of  Clean Air.   Now  they  want  to
 sign  it  on April  20,  1990,  the  twentieth  anniversary  of the  first Earth Day.
 It  is  not  clear  when  the two parties will  get into  Conference  Committee;  the
 original estimates were  six months  to  a year.   The  EPA  is  hopeful  that,

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because of an election year, they will be able to get it out early.  This
Administration clearly wants the bill.  There are no issues included that will
clearly prevent its being signed.  It seems possible to still work something
out and soon, but a lot depends on how Congress moves.  In the past, the
biggest holdup has been that John Dingell of Michigan is the Chair of the Full
Committee and Henry Waxman from California is the Chair of the Subcommittee;
getting any kind of agreement on motor vehicle tail pipes was impossible.
     Consumer products are of interest because the percent of the  inventories
is growing in the nonattainment areas, and the concern is that too little is
known about what can and cannot be done to reduce those emissions.  For this
reason both proposed bills mandate that the EPA first initiate a study and
establish a dialogue with industry.  The purpose of this symposium is to start
gathering information.  It  is clear  in the Senate bill that regulations will
be mandated, that something will be  regulated, and some reductions will be
achieved.  The EPA has no preconceived notion of what percentage of reduction
we are going to get out of  the consumer products inventory.   In any case, the
EPA will have a mandate to  look at the consumer products VOC  emissions and  to
develop regulations.   Industry is encouraged to regularly coordinate with the
EPA and to find out the status of development.  The EPA will  be very
forthcoming with the materials we prepare, and as we  proceed  through the
system, there will be  formal stages  for various reviews.

Question:  What exactly is  the 3% that  is  talked about  in the Senate Bill and
how does  it  relate to  consumer products?

Bill Harnett:  What  it amounts to  is an  inventory  of  10,000,000 to 12,000,000
tons of VOC  emitted  annually in  the  United States  in  nonattainment ares.  The
Senate bill  requires that EPA achieve  sufficient emission reductions from the
consumer  products area to reduce the future  inventory by three  percent,  taking
into account future  growth.  Three percent is  somewhere between 300,000  to
360,000 tons per year.

Question:  Does that  include the emission  inventory  estimates;  does  it  include
Reid vapor pressure  (RVP)?
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Bill Harnett:  There are two potential  Reid vapor regulations.  One is 10.5,
and the one specified in the Administration's Bill is 9.0.  Right now that is
not accounted for in the inventories.
Question:  Why is one of the ground rules of this symposium to ban any
discussion of photochemical reactivity?

John Calcagni:  We have been involved since 1970, early 1960's actually, in
California's rule 66 on various attempts to use photochemical reactivity.
Photochemical reactivity's primary contribution is changing the rate of
reaction, the rate of formation, which allows the emissions plume to move into
the second and third day of reaction.   We have found with second and third day
reactions that relative rate of conversion, unless you are talking of
converting into a fluorocarbon, at which time it will go  into the stratosphere
and react, still contributes in second and third day reactions.  Our research
is  indicating that in the Northeast corridor, particularly where we are  seeing
three and four day reactions, reactivity shifts are not a particularly
effective way of reducing VOC.  The EPA recognizes that a number of people
have disagreements with us on that debate, and the issue  should be pursued as
a scientific debate with EPA scientists.  However, it appears likely that, as
we move  into an inventory management system, and  as all States are pushing
toward reducing inventories, VOC reductions, not  substitutions, are the  likely
phases of regulation we are going to proceed with in the  next few years.  The
EPA does not want to hamper efforts to show that  considering  reactivity  is  an
appropriate  approach, but we hope to focus on ways to manage  regulation  of  VOC
and reduce emissions.

Question:  Is the consumer products category included under the definition  of
a "moveable" stationary source?
Bill Harnett:  No,  it  is not.   Only the  section  on consumer  products  is  meant
to  deal  with products  that emit VOC in use.

Question:   [Inaudible]

Bill Harnett:  Generally,  the  States would much  prefer  a  national  regulation.
It  (a)  saves them time and resources,  and  (b)  ensures consistency across the

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country.  In some areas, however, both because of the magnitude of the problem
and their attitude towards the ozone problem, they do not want to wait on the
Federal government.  Authorities in these areas will be more aggressive and
they will want to address the problem quicker than the EPA might allow for in
the bill.

Question:  Is EPA going to get more accurate quantification of the VOC
inventories, so that in calculating the 3% we have a better number to deal
with?

Bill Harnett:  The answer is probably not, though if we are forced to at some
point, we will have to try to fine tune them.  The EPA, however, is not
backing the use of that percentage.  The Administration has also made it clear
that it would prefer not to have that in there.  You can measure percent of
total  inventory, but you really cannot go out and measure to show that you
have achieved a percentage reduction.

John Calcagni:  In the EPA's attempts to conduct the inventories in the early
1980's, we assumed 3.6 pounds of VOC per capita, which  is an appropriate
number for commercial solvents.  In the mid  1980's, the EPA invested a
significant amount of research  in developing a national inventory, and more
closely examined this category.  At that time, we evaluated one category  in
particular, aerosol cans, and found one billion pounds  of VOC per year
emitted, which  is  about four pounds per capita, just from aerosol cans.   In
general, 7.7% of the inventory  translates to about 6.8  or 6.9 pounds per
capita of VOC emitted.  The EPA has little confidence  in this number, and we
are  very concerned that the Senate bill may  lock  in a  particular number.
Question:   [Inaudible]

John Calcagni:  The EPA  is aware that biogenics do  play a role.  One way  of
looking at ozone  is that  it is  nature's scrubber:   it  is the way that nature
removes hydrocarbons from the atmosphere.  The biogenics were present before
any  significant rise was  seen in ambient ozone levels.  Biogenic VOC
contributions must be taken into account, and different controls of oxides of
nitrogen in combination with VOC control may be necessary.

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Question:  [Inaudible]

John Calcagni:  It is the general feeling on the part of most States that they
want national rules in these areas.  There are areas in California, in
particular, and some in the Northeast corridor that are concerned that the EPA
will miss many dates, that the EPA will not regulate very quickly.  The EPA
does not have a good track record on making dates, and most States currently
do not want to be precluded from regulation, should the Federal government not
move aggressively or not move sufficiently expeditiously to help them solve
their air quality problems.  As long as the States must achieve attainment,
they want every tool in the arsenal that is possible.

2.4  BROCK NICHOLSON
     Chief, Policy Development Section
     Air Quality Management Division
     U.S. Environmental Protection Agency
     Possible EPA Control Strategies for Consumer Products
     Conceptually, regulatory programs are discussed  in terms  of  specifying
requirements directly  at the point of  regulation.  This has traditionally
consisted of Control Technology  Guidelines for  stationary sources, for
example, and these guidelines are  usually fairly  specific and  point to  a
particular emission  point.  This  is  sometimes referred  to this as  "command  and
control".  Command  and control  is  a  traditional regulatory approach.   In  the
area of  consumer  and  commercial  solvents, however, the  classic approach is  not
necessarily  the only approach that could be  used.  While the command  and
control  approach  may have  appropriate  application here,  another general
category to  consider is the incentive  or market-based approach.
      In  dealing with regulation,  the EPA obviously needs to  consider  the  point
of regulation.  Some of the regulatory options  will  obviously  overlap in
certain  situations.   Traditionally,  command  and control  regulation has focused
on the  point of emissions.   For consumer  and commercial  solvents,  the
emissions  occur during product  use,  so the  person in the home  using  a spray
can,  for example,  is the one  that should  be regulated.   Obviously, there are a

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lot of implications there.   On the other hand,  there may very well  be some
control  techniques that could be employed and directed at the end user.
     The next step is the retailer.  Again, there might be some advantages for
regulating on this level, but there may also be a lot of disadvantages.   One
consideration, of course, is the efficiency of administering a regulation.
The same situation may exist for a distributor, except that efficiency in
administering a rule may be increased, for example, by dealing at the
distribution point.
     Efficiency may also be increased by working with the formulators,
packagers or manufacturers.  A packager may purchase a product in bulk and
repackage it.  A formulator may create a product from raw materials, and
package and distribute the product.  Finally, solvent suppliers may be the
most upstream point of regulation.  The most efficient regulatory approach may
be to identify the solvent going into a product line, or to an industry, or to
a company.
     Another conceptual approach, one that is market-based, might allow a much
wider opportunity for flexibility on the regulated community.  But no matter
how we conceptually develop a regulatory program, or at whom we direct that
program, it must be enforceable.  There are various approaches that would
achieve this  in different degrees.  Given the level of enforcement that the
EPA is capable of, and given the ability to administer the rules, a rule must
be effective.  It  is also  important that the results of a program be
quantifiable  so they can be measured.  The regulation must be logical and
clear so that people understand the specifications of the program.  In a
sense, the simpler, the better.  The regulation should not require massive
calculations, investigations, and an audit team to determine compliance.  A
regulation must also be politically acceptable.  In addition, recordkeeping
and averaging time must be considered; some of the representatives at this
symposium have been in many lengthy discussions with the EPA concerning
averaging time in other areas.  Obviously, the point of control has to be well
considered, along with geographic area of coverage.  Geographical location
determines seasonal effects.  For example, will products sold  in Minnesota be
treated the same as products sold  in southern California?  Special exceptions
such as hospitals and emergency situations must also be considered.
     The concept of command and control and the market-based approach are not

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always distinct from one another.   Some command and control  options might be
product limits on VOC content or weight limitation.  These limits could be
directed at various points of control:   the manufacturer,  the distributor or
the formulator.  A market-based approach might be viewed as a means to provide
an incentive to limit emissions, but perhaps with less specificity than
allowed under the command and control program (less directed toward a specific
product or a specific manufacturer).
     The market-based approach might also take the form of solvent allotments.
This would theoretically give the regulated community freedom to meet an
overall goal without having a specific command and control style of program
dictated.  Incentives are another way to administer the market-based approach,
perhaps as fees.  But they do not necessarily have to be trades or bubbles in
order to be market-based.  Permits are perhaps one way to help administer such
a program.  Percent reductions may apply across an entire industry or company.
In conclusion, there are lots of combinations of regulation, and EPA's
objective  is to explore all of the possibilities available.

2.5  RALPH ENGEL, President
     Chemical  Specialties Manufacturers Association
     Industry's View of Regulating Consumer Products
     The Chemical Specialties Manufacturers Association (CSMA) has a
membership of  more  than 400 firms engaged  in  the manufacture, formulation,
distribution and  sale of household  pesticides,  including  antimicrobial
products,  automotive specialty  products, detergents  and cleaning compounds,
personal care  products, and polishes and floor  maintenance  products,  all  of
which  are  used in the household or  for institutional  and  industrial  use.   Many
of these products are formulated and packaged in both  aerosolized  and  non-
aerosolized form.   Most are marketed nationally.   In  addition, CSMA  leads an
industry coalition  which  includes the  Cosmetic,  Toiletry  and Fragrance
Association  (CTFA)  and  the Soap  and Detergent Association (SDA),  addressing
the  issues relating to  consumer  and commercial  products.
      CSMA  and  a  number  of  its  member companies,  several of  whom  are  present
here today, welcome the opportunity to interact at this meeting  to discuss
volatile  organic compounds as  they  relate  to  consumer and commercial  products.
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You should be aware that commercial  and consumer products could include
architectural coatings, traffic coatings, and aircraft and marine products and
the like, but these products will  not be addressed here today, nor are they
represented in our total mix.  CSMA's membership interest is grouped into the
following divisions: antimicrobial division, the aerosol division, the
detergent division, the industrial and automotive products division, pesticide
division (home lawn and garden pesticides), polishes and floor maintenance
division, and commercial and residential services.  Our members join the
Association as a whole and participate in the divisional interest which best
fits the needs of their product mix.  A "chemical specialty" is a chemically
formulated product manufactured from basic chemicals or chemical compounds and
used without further processing by household, institutional, and industrial
consumers.  The word "specialty" distinguishes this finished product from the
basic chemical and chemical compounds from which it is mixed or compounded.
     The products contemplated in proposals to reduce emissions from
commercial and consumer products are not a particular type or class, but cover
a universe of commercial, household, and personal care uses.  They  include
personal care products such as shaving cream and mouthwash, deodorant,
perfume, shampoo, and sunscreen; home care products such as window cleaner,
furniture polish, floor wax, laundry detergent, and kitchen cleaner; auto care
products such as carburetor cleaner, anti-freeze and windshield de-icer; and
vital health care products such as disinfectants, sterilants,  insecticides,
and medicines.  In short, they may even  include some beer, wine, and alcoholic
beverages.   In all, we are speaking about  a segment of our economy  that
produces well over 700,000 products and provides some 30 billion dollars to
our Gross National Product (GNP).  These are products that make all of our
lives run more efficiently and conveniently.  The contributions made by this
industry to the overall quality of American life are  immeasurable.

Clean Air and Effects on Consumer Products

     These products cannot be viewed in the same way  as other  emission
sources.  Commercial and consumer products are an entirely new and  unique
subject for clean air regulation.  This  is a category that cannot be dealt
with by traditional approaches or control  strategies.   Its contribution to

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ozone is not at all  clear,  and at this point there is no reliable database
from which to determine its contribution,  or to determine now to approach
these small sources  of emissions with any certainty or knowledge of whether
control  is feasible  at all.  The Office of Technology Assessment (OTA) of the
United States Congress confirms this in its comprehensive study "Catching Our
Breath:   Next Step for Reducing Urban Ozone," published in July of this year.
The OTA found that in the area of consumer products, any emission estimates
are subject to potentially large uncertainties.  The OTA also concluded that
it is not clear whether an attempt to control emissions from this source will
be either technically or economically feasible.  In short, investing huge sums
and causing great dislocation, may be pointless.  In fact, because control
technology  information is so lacking for the category, OTA excluded consumer
and commercial products from its otherwise thorough analysis of emissions
reduction potential  and cost.  The few studies that exist assessing the
feasibility and impact of controlling volatile organic compounds emissions
from consumer and commercial products have,  for the most part, been undertaken
by the  industry.  These studies  indicate that the societal impact of  control
on consumer and commercial products would be enormous.   In late  1986,  a  study
was conducted by Heiden Associates for the  industry to determine the  cost of
reducing VOC content to 50%  in underarm products  in California.  The  study
concluded  that the direct  cost to remove VOC emissions range from $49,000 to
$98,000 per ton.  This was based on data which  included,  among other  things,
reformulation costs,  incumbent safety testing,  plant  shutdown  and retooling,
process changes, and other miscellaneous costs. Furthermore, a study  by  Dr.
Gary Whitten of Systems Application,  Inc.  investigated the impact of  underarm
spray products propellants on  urban  smog formation  in  California's  South Coast
Air Quality Basin.  This study indicates that mandatory  VOC  reduction in these
products would have a  negligible,  if  measurable,  effect  on the concentration
of ozone  in the lower  atmosphere.   The urban airshed  model used  as  the basis
for the study  has prioritized  the  effectiveness of  controlling multiple small
sources on both a total  impact basis, which combines  reactivity  and the weight
of the  emissions, and  on a per unit  impact  basis, which  normalizes  the smog
 impact  to  show the  control effectiveness  per ton.
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     Are Not an Acceptable Control  Strategy

     Current legislation submitted by the Administration authorizes the EPA
Administrator to employ a system of fees as a method of controlling VOC
emissions from consumer products.  It was mentioned as one of a large group of
control processes.  CSMA submits that any generic, unfettered provision
authorizing EPA to assess fees carries too high a potential to become simply a
revenue-raiser unrelated to ozone attainment, and is likely to be viewed by
the courts as an unconstitutional delegation of Congressional power to tax.
Economic incentives are useful for controlling emissions for consumer
products.  However, they raise the specter of governmental regulation on the
amount of products that may be sold, and carry with them the potential for
seriously interfering with the marketability of consumer products.  Their
usefulness is obviously very limited.

Consumer Impact

     Regulation of consumer products will  have an enormous direct  impact on
consumers.  Because of their cost, solvents  are used  today at  a very  low
concentration level, or only  in  products for which  there  is  no practical
alternative.  Therefore,  any regulation  requiring elimination  or major
reduction of solvents will result  in the disappearance  from  stores  of many
useful  and necessary products.   The monetary cost to  consumers will  also be
great.   One category of products that  could  be virtually  eliminated by
controls,  if they are  illogically  handled,  is  aerosols.   Any proposed
regulations could result  in loss of nearly two to three billion  aerosol  unit
sales  in the United States alone each  year.  Besides  denying consumers
a considerable  choice,  it would  translate  into a  loss of  some $8  billion  in
sales  by American retailers.
      If valuable  consumer products are arbitrarily  removed from  the
marketplace, consumers  will have to  rely on professional  services  to replace
the effectiveness and  efficiency of  existing products.  The  same  jobs that the
consumer had done inexpensively would  now cost much more  to  have  done by
professionals.  And even  the  professionals would  be required to  find

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alternatives that would cost them more in labor and materials.  These costs
certainly would be born by the consumer.   Some examples are in order to
illustrate these hidden, but very real,  costs.
     An important product category is total  release insecticide.  These are in
the form of room foggers with constant release lock valves which spray a
continuous fog and effectively fumigate a room or an entire home.  A single
consumer application of this product costs approximately five dollars.  In
order to achieve the same insect control  after adoption of a proposed control
measure, a consumer would have to contract with a commercial pest exterminator
for fumigation.  Each application would cost between 80 and 100 dollars.
Imagine that problem in the inner cities of our country.
     Aerosol sprays are increasingly common where automotive supplies are sold
or in any garage where maintenance work is done.  Aerosols provide ease and
economy in normal automotive maintenance procedures.  For example, using a
spray cleaner, dirt, gum, and carbon deposits are removed from an engine
carburetor and an automatic choke.  The carburetor throat is easily reached by
an extension tube on an aerosol can.  Gasoline additives used for non-aerosol
carburetor cleaning are simply not as effective as direct spray.  A 13-ounce
spray can costs 3.25 dollars.  The shop costs for a complete overhaul and
carburetor cleaning of  a typical recent model car is $169.00; and this does
not take into consideration the amount of VOC spewing out of the tail pipe
because of the clogged  or dirty carburetor.
     For these reasons, we oppose any attempt to reduce VOC emissions from
consumer and commercial products without a thorough consideration of  societal
impact, technological feasibility, and economic effects.  We further  believe
that such consideration just may result  in a  final determination that such
regulations are not very cost effective, or that ozone  concentrations are  not
significantly reduced.  However, CSMA welcomes any and  all  credible efforts to
determine whether these products play a  part  in ozone formation.  Let us not
prejudge any  studies that may be done.   And let us not  write  regulations,
mentally or on paper, to meet artificially contrived deadlines.  Mr.  Bush  can
wait just a few more months  to  sign  the  Clean Air Act  if  it is  rationally
concluded.
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      End vs.  Product Regulation

     Clean air regulations have all  generally focused on the waste end
emissions of major sources of pollution in our society.   Consumer products
cannot be viewed in the same way as  traditional  sources.  The Clean Air Act up
to this point has regulated waste emissions and not end-use consumer products
created for the benefit of society.   The regulation of consumer products
raises many different issues.  Instead of controlling valueless waste, these
regulations will be directed at products themselves.  These benefits have to
be considered as part of any regulatory decision.  Utility plants, for
example, may need bigger and better scrubbers, but they will not be closed
down.  Thus, utilities may be forced to shoulder a heavy and possibly
unjustifiable financial burden, but will continue to be viable.  Cars may
require more effective catalytic converters or other devices, but no one  is
advocating banning their sale.
     Because emission control devices cannot be placed on consumers
themselves, the only means available to control emissions from the products
they use  is to alter these products if technology is available, or to
eliminate them from the marketplace.  Alternative technology does not now
exist for many of these product formulations.  Therefore, the consumer and
commercial solvents  industry  is faced not  just with an  increased financial
burden today, but with the impossible task of quickly reformulating many
thousands of products.  It would obviously be unacceptable for government to
require  reformulation of medications (many of them contain VOC),
disinfectants,  insecticides,  and sterilants,  and a whole host of other
consumer products, for clean  air purposes  without making sure that the
reformulated products or  substitutes will  be  effective.

Interstate Commerce

     Most consumer products  that are marketed nationally rely  upon the  freedom
of movement traditionally and constitutionally  accorded to  interstate
commerce.   If  anything should move  freely in  the marketplace,  it  must be  these
many products  that are such  an important  part of modern life.   It  is  essential

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that any regulation of emissions from commercial  and consumer products not
erect unnecessary barriers to the free flow of commerce.   Therefore, there
must be consistency of regulation in a national marketplace.  At the very
least, any Federal program should take particular care not create incentives
for states to adopt different or obstructive requirements for commercial and
consumer products.  Manufacturers, marketers, and distributors of commercial
and consumer products simply cannot contend with patchwork, state-by-state,
clean air regulation schemes.

CSMA Recommendations

     Because of the lack of data on the contribution of VOC emissions from
consumer products to ozone formation, and the economic and  societal impact of
reducing VOC emissions, any specific action to control emissions at this time
is truly without justification.  For this reason, we support an approach that
would ensure that the appropriate path to minimizing VOC emissions from
consumer products is technically, environmentally, and commercially
acceptable.  Regulation efforts which are based on unproven assumptions, old
data, myth, and rhetoric are  inappropriate for this  industry or frankly, this
Nation.

Comprehensive Study of Consumer Products

      The non-attainment section of  the Administration's  Clean Air  Bill  before
the  Congress directs  the  EPA  to study and analyze the  subject of emissions
from consumer products for  a  two  year period.  CSMA  strongly believes this
period  is  insufficient.   As  noted  earlier,  the OTA  study,  "Catching Our
Breath," concluded  that very  little is known  about  either  the ozone
contribution or  control technology for consumer  products.   The  agency has  said
the  same today.   For  this reason,  OTA excluded consumer  products altogether
from its emission reduction  potential and  cost analysis.   A Federal court  in
New  York,  in reviewing a  State Implementation Plan  revision regulating
consumer products,  concurred  with New York  State Department of  Environmental
Conservation's  assertion  that no  valid data exist to regulate these products;
and  they were  limited to  three categories.   The  Court further agreed  with  the

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need for a four year study to gather the appropriate data.
     The CSMA believes that the best approach is a comprehensive four year
study that is conducted by the EPA.  During the first year, consumer products
should be defined and a complete emissions inventory of the approximately
700,000 products should be compiled.  After the inventory is established, a
study would is needed that would, at a minimum, identify the following:
consumer solvent contribution to the ozone formation; alternatives for
reducing VOC emissions from products; economic and commercial feasibility of
such methods and alternatives; net environmental, health, and societal impacts
and/or value of such methods and alternatives.  The study, in addition, would
assess and evaluate such other issues associated with volatile organic
compound emissions from consumer products as they are identified during a
protocol development process.
     The study required by the protocol could be complete  in approximately 36
months after the protocol has been developed.  At the end of that study,  if
the Administrator at the EPA finds that the regulation of VOC emissions of any
consumer product is beneficial and commercially and technologically feasible,
then such regulations could be rationally promulgated.

National Consistency

     There must be consistency of  regulation  in a national marketplace,  since
consumer products are marketed nationally.  The CSMA believes that the goal  of
regulation  in  a national marketplace can be accommodated  with regional
necessity.  Under certain compelling and extraordinary   circumstances, States
could  adopt additional controls  after  a finding of  need  has  been made.
Current Clean  Air Act provisions relating to  mobile sources, motor fuels  and
aircraft make  such an accommodation  now.  Moreover,  during the  development of
Federal regulation,  the  States ought to be called upon to suspend their  own
efforts to  adopt or  enforce  standards  relating  to emissions  from commercial
and consumer products.   The  CSMA believes that  this not  only appropriate,  but
imperative, with regard  to consumer  products  clean  air regulation.
Inconsistency  could  well lead  to the destruction  of a national  distribution
system relied  upon by this  industry, but more importantly, relied upon by
every  industry in this entire  country.

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Conclusion

     In closing, CSMA would like to publicly object to the assumptions for
dialogue for this symposium.  We came with an open mind to sit down at the
table and have a level playing field.  As far as our industry is concerned, we
are here on that basis.  We do not want any issues taken off the table now or
later.  There should be room for discussion of all areas.  So as far as I am
concerned, as far as CSMA is concerned, the three assumptions in this package
should be put aside for now.
     Also, something that occurred a couple of hours ago is of importance.  On
September 20, 1989 a Court settlement was signed between the EPA, Illinois,
Wisconsin, and now Michigan.  It was accepted by the Court last week.  The
settlement is an agreement to put off a Federal Implementation Plan to
regulate a whole host of emission sources until September 1994.  The EPA  and
the States are to participate in a $12 million air quality study which  is  to
be a photoreactive grid modeling study.  While doing that study, there  are
interim control measures established  in that agreement which do not  include
consumer products, again because of  the lack of data and the lack of  impact
analysis.
      Finally, CSMA believes that,  in  the area  of  commercial and consumer
product regulation, we have all benefited from the  inquiries and analysis
which  have been made  by both government and  industry over the last year or so.
Industry  and  government are more  aware of the  need  to  proceed with care,  and
all of us  are a bit more  sensitive to the complexities  involved  in any
regulation of emissions from this  category.  We appreciate this opportunity to
present our  views concerning the  appropriate strategy  for establishing  a
national  program for  achieving  ozone attainment and will  indeed work with you.
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2.6  JOHN CHAMBERLIN
     Office of Policy,  Planning,  and Evaluation
     U.S. Environmental Protection Agency
     Use of Market-based Approaches to Reduce VOC Emissions from the Use of
     Consumer Products
     The EPA hopes that, by defining the term "market-based approach to
regulation", industry will be able to identify issues of concern that EPA
should be aware of as they explore approaches to obtain reductions in VOC
emissions from consumer products.  In addition, the EPA would like to share
some preliminary information on the consumer products industry structure for
some product categories of concern.
     The EPA is interested in market-based approaches partly because this
philosophy  is now central to the Administration's proposed legislation for the
Clean Air Act.  For example, some of the provisions regarding acid rain now
allow and encourage utilities to implement the lowest cost reduction
techniques to meet prescribed limitations in their S02 emissions.  They may do
so by use of control technology, or they may switch fuels, and they may even
buy and sell credits for additional reductions achieved or bank them for
future use.  This reliance on the free market  is a substantial change from the
prescriptive philosophy that has been the hallmark of pollution regulation.
And this market philosophy carries over to the VOC emissions from consumer
products.  Again, the Administration's proposal requires a report to Congress
that should consider alternative regulatory approaches to those products,
including fees, marketable permits, and auctions.  Moreover, the proposed
language of the Bill specifically exhorts the  EPA to consider economic
incentives  in its regulatory approach.
     The EPA is interested in these approaches because they may have
advantages  both for  industry and the EPA over  the exclusive use of traditional
command and control  regulations.  For example, the 1977 Clean Air Act
prescribed  that all  utilities had to install scrubbers, regardless of their
current emission rates.  The EPA now believes  marketplace approaches would
allow firms the opportunity to respond more flexibly, depending on their
individual  circumstances, and to save money in the process.  Bottom  line
incentives  may also  spur compliance.  Incentives may also encourage

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innovations to obtain additional  emissions reductions for future use or sale,
aspects lacking in traditional  command and control  approaches.   Finally,  from
the EPA's perspective, they have  the potential  to ease the knowledge-intensive
burden of traditional approaches  which typically require very detailed
knowledge of either a product or  a production process or the performance of
technology.
     Market-based approaches generally fall into two categories: charges or
permits.  A charge or a fee system basically imposes a direct cost on a
product for emitting pollutants to the atmosphere.   Implicitly, a fee system
focuses on limiting the cost that society  is willing to pay to abate
pollution.  It foregoes certainty about the amount of emissions reductions.
On the other hand, permits specifically limit the amount of emissions to the
atmosphere.  Permit systems focus on limiting the amount of pollution society
is willing to accept and forego certainty  about the cost of obtaining those
reductions.
     Fees and permits have advantages both for the regulators  and the
regulated.  A system of fees can provide an  immediate bottom line for any
reductions in emissions.  Fees can encourage further efforts to reduce
emissions while also providing a degree of predictability to the regulated
industry  about potential compliance costs.   Fees do not  impose technological
constraints on control measures.   There is freedom to explore  alternative
control methods.   Similarly, permits provide a quantifiable  limit on
emissions, allow  the regulated industry to buy and sell  allocations
(potentially lowering the total cost of compliance), rely on markets  instead
of government to  set  the price of those permits, and have the  potential  to
provide  incentives  to be  innovative  in production, product,  or control
technology.
      Fees and permits,  as characterized  in this  example,  raise a  lot  of
issues.   For example, how do you  set  the  initial fee  charge?  How does  one
quantify  those reductions that result  from that  fee?  Who gets the  money?
When  is  that charge adjusted and  how  often?   Similarly,  there  are  issues that
arise with a  system of  permits.   How  is  the  initial  amount  of  that  permit
established?   How are they  distributed?   If  you  are  going  to run  a  permit
system,  how do you assure that there  is  a fair market with  lots of  buyers  and
sellers so hoarding or  monopoly  situations do not  result?  What is  the  life of

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a permit?  What is the area in which the permit operates?
     The EPA has a general  set of concerns regarding all  regulatory
approaches.  These same concerns also apply to market-based approaches.
First, how would the EPA go about quantifying the emissions reductions
achieved with a fee or a permit system?  Second, what are the administrative
problems, especially recordkeeping problems, that are associated with setting
up either a fee or permit system; and how are they different from other kinds
of recordkeeping requirements that your firms presently face?  Finally, with
either fees or permits, what are the compliance and enforcement problems both
from  industry's perspective and EPA's perspective?
     The market approaches, using a fee or a permit, are not necessarily
exclusive of one another.  For example, a permit could have a cap or a ceiling
on emissions with a fee for its issuance to cover the administrative cost, and
perhaps a fee in excess of that cap, in effect, a penalty.  Alternatively, one
could couple a market permit with traditional approaches.  One could have a
permit with a cap plus a mandatory annual percentage decrease  in emissions.
Those of you who are familiar with the Agency's phase-down of CFC's are  in
fact  looking at exactly that kind of system.  Obviously, there are many  other
possible combinations.  The EPA  is interested in hearing industry's ideas
about what those combinations might be.
      To the EPA, the consumer products  industry structure  is extremely
interesting because of its implications for the choice of  the regulatory
approach.  There are literally thousands of consumer products  in the
marketplace, with millions, possibly tens of millions, units sold annually.
The  individual emissions from these units are small, but in aggregate  they are
large.  Putting aside the questions about the inventory, the EPA's estimate  of
VOC  emissions is approximately 154,000 tons a year.  We  agree that direct
control at the point of emission to the atmosphere  is totally  impractical,  if
not  infeasible.  And similarly, control at  the  point of  retail sales  seems
inefficient.  However, as one moves back  in the distribution chain, the  number
of points  of control diminish substantially.  Based on  information from
various trade publications, the  EPA estimates that  there are approximately  100
manufacturers of window and glass cleaners, about  200 for  all  purpose
cleaners,  and about 400 for room deodorizers  and disinfectants.
Alternatively, consider the aerosol paints  category.  Again, the number  of

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products and the number of units sold is likely to be very similar to those
for household care products.   The EPA estimates aggregate annual  emissions at
about 159,000 tons.  However,  as one moves back in distribution chain, again,
the picture is quite different.   Based on information from trade association
sources, it is estimated that there are approximately 25 formulators aerosol
paint.  That makes a substantial difference in the way one thinks about how
one might regulate, if one chooses to do so, in this area.
     The point of these two examples is simply that the better the EPA
understands the consumer products industry and its products, the better we can
tailor the fit of the regulatory approach to industry's needs.  We do not
believe that "one size fits all" is the best approach.  The EPA is truly
interested in exploring alternative approaches.  As the number and diversity
of these sources  increase, the problem grows almost unmanageable.
Question:  There appears to be a lot of thought given by the EPA speakers to
the determining of fees or permits or charges and collecting the money.  But  I
haven't  heard what would happen to that money and how it would benefit  the
reduction of VOC emissions.  Can you please tell me what would happen to the
money?

John Chamber!in:  We don't have an answer  to that.  In  one  of the  earlier
versions of the Clean Air legislation, the language said  something about money
accruing at the Treasury, to be used by  EPA for  future  research  and
development.  There  are possibilities to rebate  these kinds of revenues to  the
 industry so the money doesn't  necessarily  have to  leave the industry.   There
are  questions about  how one goes  about returning those  revenues  to the
 industry,  if  the charges  are based on the  unit of  VOC content  in a product.
You  don't  want  to  be collecting revenues on the  one hand,  and  just giving  it
back on the other.   That  accomplishes nothing.

 John Calcagni:   The  acid  rain  bill  under consideration  has a remarkable system
 of permits in it.   Under  that  system,  the  utilities  are each issued an
 allocation of sulfur emissions that  the  EPA then manages in terms by
 establishing  a trading  system and a market.   Utilities  are also free to trade

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those allocations at whatever price the market will  bear.   In discussion of
fees, the EPA is concerned with finding one that's revenue neutral.  We're not
in the business of balancing a budget.

John Chamberlin:  Fees can operate in two different ways.   With a permit
system, one could charge a fee for the permit, and the cost of that fee would
presumably be nothing more than the administrative cost of running a permit
system.  That doesn't really generate revenues;  that just covers the
administrative costs of a permit.  Alternatively, one can run a fee system
based on the content of the product.  First, we're going to have to decide
what that charge is.  This type of fee does have the potential for raising
revenues.  Those revenues could go into an industry fund for further research.
They would not necessarily have to go to the Agency.  We haven't decided  in
any way what happens to those revenues.  In fact, one of the sticky issues  in
talking about a fee system that generates revenues that is not as John  said,
'revenue neutral',  is how to use the revenues.   It's something that the EPA  is
sensitive to.

Question:  What has the Agency learned from the  experience with the CFC
regulations.  In particular, how are those fees  going to be applied or  used,
and how might that  relate to the consumer products  issues?

John Chamberlin:  My understanding  is that that's a permit-base system, not  a
fee-base system, where allocations to the manufacturers are being  reduced over
time.  The amount of CFC-containing product that can be produced  is being
curtailed.

Question:  Would you explain how the  permit concept would  apply to consumer
products.  For  stationary  sources,  a  permit is  usually  issued  to  control  a
particular facility, but there  is  no  limitation  on  what products  can  be
produced.  Are  permits for  consumer products  permits for  a particular product
line,  for VOC's generally,  or  for  a specific  product?   How would  it work?

John Chamberlin:  One approach would  focus  on the manufacturer.   Each
manufacturer  is  allowed  a  certain  number of pounds  of VOC  per  thousand units

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of consumer product.  These allotments are tradeable;  they are a right to
emit, if you would, and you can emit, you can keep the allotment for growth,
you can sell it to a competitor, you can swap it within your firm, you can
sell it to somebody who is not a competitor.  It becomes a market-based
system.  Another approach would focus on formulators,  or solvent suppliers,
depending upon the nature of the product.  The CFC program is an example where
the supplier is regulated.  All of these approaches are on the table, and we
are actively exploring these sorts of approaches.
     The EPA is finding that, because of the potential for the CFC prices to
rise, industry is seeing an opportunity for new products, improved products;
they're looking upon it as an advantage, as an opportunity to make some
improvements and to take advantage of business opportunities.  For the ozone
non-attainment issue, some of the same philosophy may prevail in  industry.
This is not necessarily something being  imposed upon  industry, so much as an
opportunity to make some new products, and  see some improvements  not only  in
the product, but also in the environment.

Question:   Is there any plan for standardizing testing of VOC content of
products?

John Chamberlin:  Historically, the  EPA  has been  in the business  of  providing
test methods.  Rather than a generic method, we may be able  to work  out
inventory records,  and assume  that what  you buy  is what you  emit.  The EPA
will bring  this  issue to  the attention of  the test and methods people.

Question:   Just  a  comment:   there have been some  parallels drawn  between  acid
rain and CFC  issues.  Those  two issues both involve long-lived  atmospheric
species.   It doesn't matter  where S02 is emitted, whether  it's  Indiana,
Illinois,  or Kansas, or what have you.   CFC's are also  long-lived.   However,
the point  of emissions of VOC  is  very important,  whether it's in  an  attainment
area or a  non-attainment  area  must  be a  consideration.

John Chamberlin:   Very true;  the  issues  of geographic location,  and  of
reactivity are important.   The EPA  has invested heavily in a photochemical
dispersion model  in the  Northeast called the Rondette exercise.   As  I

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indicated earlier,  we do find that the dispersion occurs beyond the urbanized
areas.  And there is a question as to whether transport from outside the
Standardized Metropolitan Statistical Areas (SMSA's)  are indeed also
contributing to non-attainment.  With regard to reactivity, the models we do
run differentiate between species.  They consider the characteristics of each
of the species in evaluating, on an area-wide basis,  what the potential
impacts would be of different reactivities.  Those features are built into the
EPA's evaluation techniques.  I will tell you that we're having difficulty in
showing attainment with our models even with maximum technologies.
     Those of you who remember Rule 66 will recall that there weren't any
substitutes for stains and creosotes.  The EPA defined boundaries where sale
of creosote was legal; for instance, outside Route 128 in Boston sale of
creosote was legal, and inside it was illegal.  The EPA does not want to
create that situation in the consumer product market, where there are
artificial boundaries with high solvent products on one side, and low solvent
products on the other.  The EPA recognizes this as a concern.

Question:  I believe that a good definition of VOC is necessary.  The
California Air Resources Board (CARB) staff defines VOC differently than the
emissions control laboratory at the  University of California at Riverside.
For CARB's purposes, carbon monoxide  is not a VOC, methane  is not a VOC; but
it still  is a volatile organic compound, and both of these  contribute to ozone
formation.  Is the  EPA defining VOC's differently that on  the basis of
volatility.  Another definition which came up at CARB meeting addresses  high,
medium,  and low volatility VOC's.   Does volatility make any difference  or  is
it just  a question  of time?  Most  organic  compounds do have some  kind  of vapor
pressure;  Whether  a compound  has  a  higher or lower vapor  pressure might make
a difference of a couple of  hours,  but,  in either case, the compound will
eventually go  into  the  atmosphere.   With regard  to EPA's definition of
volatile  organic compounds,  many  of  you  have dealt with state  regulations  that
have  different regulatory structures.  Some of them have a tenth  of millimeter
of mercury as  an exemption  cut point.  Others have specifications of  certain
chemicals.  We have attempted  to  standardize the definitions throughout the
states.   The  states are  presently all going through a  regulatory  process.  One
of the  issues  we've looked  at  in  California  is how they define  VOC's.   There

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will probably not be a vapor pressure limit in the state regulations.  We have
found that certain high boilers with low vapor pressures are, in fact, get
emitted in the air as an aerosol and do eventually convert to a volatile
organic compound.  Compounds in printing inks are an example.  California will
not exempt those compounds.  Our definition is quite broad.  It exempts
methane and ethane, certain chlorof1uorocarbons, and methylene chloride, as
being nonreactive.  In addition, carbon monoxide (CO) would not be included,
metallic carbonate would not be included, and carbon dioxide (C02) would not
be included.  These compounds are not organic in nature.  They do participate
in photochemical reaction processes.  We have found that CO does in fact play
a role, but it's not a very active compound and this would be incorporated
into our modeling.  But virtually all other compounds that are typically
considered organic are covered.  There isn't a long list of exemptions, nor do
I anticipate expansion of that list.  Virtually everything has some
photochemical reactivity under atmospheric conditions that would occur during
two and three days of transport.  In general, it is a broad definition, and
getting broader, as opposed to getting narrower.
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DAY TWO, NOVEMBER 15, 1989

2.7  JAMES WEIGOLD
     Deputy Director
     Emission Standards Division
     Office of Air Quality Planning and Standards
     Opening Remarks
     The initiation of this process exemplifies what has become something of a
change  in the way the EPA has been operating.  This has been a gradual change
that has been taking place, and it is gaining in momentum.  The EPA wants to
encourage consultation and communication, not only with the regulated
communities, but also with the State and local agencies that have to carry out
the rules.  In a way, that was a hole in the way the EPA operated in the past.
We have been working actively, certainly at OAQPS, in the last year and a half
to try to improve our relations with State and local agencies that are
responsible for improving air quality and dealing with  industry.  The EPA has
not only worked more closely with State and local agencies, but we have also
begun to negotiate regulations.  We worked closely with the woodstove industry
and promulgated regulation for the control of emissions from woodstoves.  The
EPA is currently involved with the chemical  industry in negotiating rules for
controlling equipment leaks.  In addition, the EPA's new administrator Bill
Reilly puts great stock in the need to work cooperatively with  industry, and
he has called some nine companies to deal with the issue of air toxics
emissions,  including GE, DOW, and Exxon.  He met with them  in August and asked
them for cooperation; they agreed and said it is a problem we are going to
have to work on together.  The EPA is in the process of working with those
companies as they develop plans for voluntary pollution reductions.
     This process is similar.  The EPA wants to meet with representatives from
State and local agencies and  industry to create a more  effective program.  The
EPA needs the cooperation of  industry and their expertise to do  it well.  It
is hoped that industry will see this as an opportunity  to get  into the
process.  If the Congress should pass a law that says the EPA will produce a
report  in two years and produce a regulation  in four years, and  industry is
not part of the process, they run the risk of getting regulations that are not

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the most effective from their standpoint.
     If there are long protracted delays,  you will  also run the risk of having
a proliferation of State regulations that  will be difficult to deal  with.
Different states may have different definitions of VOC and different labeling
requirements.  The EPA hopes that the consumer products industry
representatives will have the sense to participate, and the ability to get
their views into the process early.
     The discussions that will take place  today will include the technical
issues and alternative control measures, including changes in the method of
application, product reformulation, and product substitution.  Dean Simeroth
of the California Air Resources Board (CARB)  is going to describe California's
consumer products control plans.  Ted Davis from New York will discuss New
York's efforts to reduce VOC emissions from air fresheners, disinfectants, and
insecticides; and Sandra Chen will describe New Jersey's program.  From
industry, Ike Emery of Helene Curtis will  talk about VOC's in consumer
products and the functions that are involved  in propellant solvents, active
ingredients, carriers for the active  ingredients, and the associated problems.
Ted Wernick of Gillette Medical Evaluation Laboratories will discuss the  time
and costs associated with reformulating and safety testing of products.   Ed
Heiden of Heiden Associates will discuss the  economic  implications as well as
the social effects of regulating consumer products.

2.8  DEAN SIMEROTH
     Chief, Criteria Pollutants Branch
     California Air Resources Board
     California Regulatory Activities
     In  California  a solvent  is defined as a  carrier  vehicle  for  applying
solids,  a propellant binder,  active  ingredient, or  a  cleaning  agent.  Over 90%
of the population  in California lives  in nonattainment  areas.   In terms  of
emissions,  solvents account for about  830 tons per  day out of 1900  tons  per
day for  total  non-vehicular sources.   Our vehicular  sources  emit  another 1900
tons per day.   Consumer  product emissions are about  230 tons  per  day,  and
other  surface  coatings  (basically  industrial-type  surface  coatings)  emit about
320 tons per day.
     The California Clean Air Act  was passed  last  year and will  become

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effective January.  It requires us to reduce total emissions contributing to
ozone nonattainment by 5% a year, both NOX and volatile organic compounds.
CARB was given authority over consumer products for the first time, so the
individual Air Quality Management Districts do not have to adopt their own
regulations.  The districts were not preempted from adopting regulations,
however, if we adopt a rule, the only thing that they can adopt is exactly the
same rule.  The Air Resources Board must, however, assure that the regulations
are necessary and technologically and commercially feasible.
     For non-consumer products such architectural coatings (specifically
exempted in the California law), industrial coatings (320 tons per day
emitted) and industrial solvents the Air Resources Board does not have direct
authority.  Three committees with the local air pollution control districts
were established to deal with these solvent use categories.  There are a total
of sixteen committees working on various control measures in California.  The
Air Resources Board works with the committees to come up with a concept, and
there is a minimum of three workshops with industry and the interested public.
If a concept is approved by the ARB's governing board, it is then distributed
to the districts with our strong encouragement to adopt what we have
developed, since they have participated  in the development.
     For consumer products, a public hearing, rather than a public meeting,
was held because the Board is adopting actual regulations, and we have the
enforcement authority.  For non-consumer product categories, we will be
working on regulations for aerospace, automobile refinishing, marine coatings,
polyester resin in wood products, and wood furniture.  Next year we will be
looking at industrial/commercial application of adhesives, architectural
coatings, general organic solvents, cleanup solvents, and add-on control
technology.  In addition, the Air Resources Board is sponsoring research and
is involved in support activities.  For transfer efficiency test methods for
coating application techniques, we are revisiting our test method for
voluntary organic compounds in coatings.  We are looking at technology that
exists for automobile refinishing, and investigating the potential uses of
economic incentives.
     For consumer products, our emission inventories total about 230 tons of
VOC per day.  Personal care products are thought to emit about 80 tons a day;
automobile and industrial sources emit about 80 tons a day; and household

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products are thought to emit about 50 tons per day.   The Air Resources Board
is looking at the regulations that have been adopted by the other States and
is working actively with other States.  The ARB is looking for regulations for
personal care products by July 1990, household products by January 1991,
automobile/industrial products by July 1991, aerosol paints (suggested control
measure) by July 1991, pesticides regulations by July 1992.
     Last week the Air Resources Board adopted the regulation for
antiperspirants and deodorants.  Final adoption will occur when the
administrative process is complete and another public comment period is held.
Basically, any supplier, retailer, or manufacturer will be affected.  ARB has
added some definitions to address propellants, solvents, solids, and active
ingredients.  There will be administrative requirements, labeling requirements
on each unit, and annual reporting requirements for units sold  in California.
There will be some exemptions; for example, products manufactured for sale
outside of the state are exempt.  Colorants and fragrances up to 2% by  volume
are exempt.  We precluded anything that has already been  identified as  a toxic
air contaminant through our toxics program, including fluorocarbons.
     The plan will be  implemented in  phases.   In phase  I we put a cap on
existing levels of the VOC content.   Phase  II will mean a 20% reduction.  The
Board changed the date for the 20% reduction from January 1, 1994 to
January 1, 1992.  Another 60% reduction of  emissions, for an overall 80%
reduction from antiperspirants/deodorants,  will translate to slightly over
four tons per day emissions reduction.  The Board approved a final compliance
date of January 1, 1995, and added a  clause stating that  if, by January 1,
1994, any manufacturer submits a plan for reformulation to non-VOC propellants
and includes key dates  in their plan, they  will have until January 1, 1999  to
comply  for the aerosol products.  The plan  also establishes reporting
requirements for progress towards the January  1,  1999 date.
     In conclusion,  the Air Resources Board is addressing  a wide variety of
different source categories  including motor vehicle fuels  and motor vehicles.
We feel this plan  is only going to  be successful  if  it's  a cooperative  effort
between the Air Resources Board, our  local  districts,  industry  and the
affected  public.

Question:   Is  the  exemption  for ethanol  in  existing products  a  generic

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exemption or for specific products.   Take hair sprays as a generic example.
Dean Simeroth:   The only thing we've adopted so far for ethanol  is the
antiperspirant/deodorant regulation.  So there is no regulation specifically
for hair sprays.  But for antiperspirant/deodorant products, a new product
would be precluded from having ethanol in the non-aerosol form; the aerosols
can have up to 10%. VOC in new products.

Question:  In development of the California regulations, you have looked at
the correlation between VOC content and emission rates or emission reduction.
It seems that a reduction in VOC content is not necessarily directly
relatable to emission reduction, in that you can reduce your VOC content,
increase the product use, and have no net reduction or conceivably an increase
in emissions.  To what extent have you dealt with that in your standards?

Dean Simeroth:  To the extent that we're able to foresee how industry is going
to change, our  intent is obviously to have a net reduction  of emissions.  One
of the things that has kept us from proceeding with the hair spray regulation
is the concern that a shift from aerosols to other forms of hair  spray  (that
may have an even higher alcohol content) may  inadvertently  cause  an  increase
in emissions.  This  issue came up during adoption of our architectural  coating
regulations last May.  Our final conclusion was that we had no evidence that
regulations were going to result in  increased emissions.

Question:  You  had an entry on your time line of a date of  December  1989 for
determining the feasibility of a generic aerosol regulation?  Could  you
explain  that little bit?

Dean Simeroth:  What we're looking  at  is something  similar  to what we have
done for architectural coatings (architectural coatings  have a general
standard of 250 grams per VOC per liter  of  coating minus water).  Within that
regulation there are about 30 categories which have  higher  limits.   Likewise,
for aerosol regulations there would  be  some type of  general standard, and each
individual category would have an  individual  limit.  Generic  is  probably too
strong a word.
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Question:  Could you comment on the decision to exempt products manufactured
for export from the State of California, given the fact that this a national
problem?

Dean Simeroth:  Unfortunately, we don't have authority for any state other
than California.  If products are not going to be used within the state we
feel there would be need to regulate them.  The manufacturing process would be
regulated under other authorities, usually local district authorities within
the State.

Question:  Have you been able to come up with any figures on the cost to the
consumer per ton of VOC reduction, financial cost and cost  in less desirable
products?

Dean Simeroth:  We estimated  that  the annual cost for the antiperspirant/
deodorant regulations will  be two  to four million dollars per year.  The
increased cost  per aerosol  unit  is estimated to  be  20 to  50 cents  per  unit.

Question:  You  prioritized  both  by type of  product  and  to some  degree  by  type
of  VOC.   Do  you have a  technological  justification for that prioritization
process,  and  do you  have a  plan  for  measuring  the  impact  of each of  the steps
 in  the  priority process,  both in VOC reduction  and  in  impact on ozone
production?

Dean  Simeroth:   A  lot of these processes are simultaneous,  so in our initial
 prioritization we  looked at the categories  whose emissions  we felt were
 technically feasible to control.  Pesticides are last because we recognized
 we're going to have to  deal with the FIFRA process to address pesticides.  In
 terms of the technology impact on the  individual products,  that will be done
 as we complete the regulation development.   One extreme possibility is that,
 if we get into regulation development for a product category and discover that
 regulation is not feasible for one reason or another, we may just drop the
 regulatory process. Our requirement for adopting a regulation  is to examine
 environmental and economic impacts.  When we   iopted the antiperspirant/
 deodorant regulations,  we  looked  at ozone depletion, global warming,

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economics, the existing alternative product forms, and the potential for
development of new aerosol propel 1 ants. In terms of actual ozone reduction, we
have a network of 100 ozone monitors.  We usually look at the three-year
averages for overall impact on ambient ozone concentrations.  In terms of
photochemical reactivity, the Board's policy is to look at mass reductions of
VOC's first, and then we start exploring how we can shift the reactivities.

Question:  [Inaudible.]

Dean Simeroth:  Usually there are so many regulations being adopted in any one
year that there's no way to really see the impact of a single regulation.  If
a single regulation reduces emissions of four, or five, or ten tons of VOC out
of 3800 tons, it will be hard to  see an impact.  The industry had Science
Applications International Corporation (SAIC) do an analysis, and they found
that a two ton reduction  in the South Coast would be a 0.006% reduction  in
ozone.

Ralph Engel:  The California Air  Resources Board's cost estimates for
reduction were $0.50 to $1.20 per pound, while CSMA's cost  studies  showed
between $1.64 and $12.67 per pound.  For aerosol underarm products  in
California,  that translates out to about $30 million additional costs
annually.  And in addition, each  manufacturer will need to  complete their  own
laboratory formulation, safety testing, and manufacturing modifications  at
significant  capital  and development  costs of several million as well.

Question:  You said  that  one of the  reasons that  pesticides will be addressed
last  is that you recognized that  you would have to deal with FIFRA  problems.
Why are disinfectants, which are  also  FIFRA products,  included  in the
household products  category  instead  of with the pesticides?
Dean  Simeroth:   It  was an  arbitrary  classification  into  that category.   We
recognize that disinfectants fall  under FIFRA  as  well, and  this will  have  to
be considered  in the process.

Question:  Just  recently,  the ARB has  taken away  exemptions for HCFC's.   Is
that  something that the  Board did contrary to  the suggestions  of the  staff,

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and if so, why?

Dean Simeroth:  The Board,  in my opinion,  never does anything contrary to the
suggestions of staff.  The Board recognized the political  impact of the ozone
depletion problem in California, and they set a standard that no compound with
an ozone depleting potential  greater than 0.00 can be used.

2.9  TED WERNICK
     Gillette Medical Evaluation Laboratory
     Reformulation and Safety Testing - Their Timing and Costs
     As many of you know, since 1978 consumer products were banned from using
fully hydrogenated chlorofluorocarbons as propel 1 ants for aerosol products.
The concern, of course,  is that the CFC's were contributing to the depletion
of the protective ozone  layer.  The ban was  instituted by the EPA, the Food
and Drug Administration  (FDA),  and the Consumer Products Safety Commission
(CPSC).   Industry turned to existing alternatives, namely butane,  isobutane,
and propane.  Ozone depletion by CFC's is still an  issue.  In addition,
Federal,  State, and local governments are concerned about tropospheric ozone
formation.   In order to  further reduce the amount of ozone depletion  by CFC's
without contributing to  an increase of ozone in the troposphere,  a chemical
industry  consortium  has  developed  a series of HFC's (hydrofluorocarbons).
Information  released by  the manufacturers of these  products  leads us  to
believe that they may  be usable in consumer  products.   However,  the  safety of
these  new products has not been determined.
      The  purpose of  today's  presentation  is  to  demonstrate the  nature and
extent of toxicological  investigations that  are needed  to  establish  the  safety
of consumer  products utilizing  new propellants.   It must be  established  that
the products are  safe  for  the men  and women  who manufacture  them and safe  for
the men,  women,  and  children who  use  the  products.
      Basically,  a  consumer product is made  up of three  components,  the active
 ingredient,  the  vehicle, and the  propellant  that is needed to get the product
out of the can.   Perfumes  and colorants  are  added for aesthetic reasons.   The
development of each  of these components  must include a safety evaluation of
the individual  ingredient.   The manufacturers of consumer  products are
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responsible for the safety of the final product.  The components, when mixed
together, may have additive or synergistic effects.  Therefore, the nature and
the extent of testing cannot be determined for a product until a formulation
is developed and preliminary tests are conducted and evaluated.  The
obligation to substantiate the safety of products and ingredients is both a
moral and legal one.  The Toxic Substances Control Act and the Food and Drug
Act both require substantiation of the safety of new products before they are
marketed.
     The development of consumer products with a new propel 1 ant is basically
divided into four phases.  The first phase is the development and testing of
the new propel 1 ant.  The second phase is the laboratory formulation or product
development; the third phase is safety testing of the final formulation and
preparation for marketing.  And of course, the last phase would be the market
research, manufacture, and distribution of the new product.  Some of the
phases must be conducted sequentially.  Other phases may be conducted either
simultaneously or may overlap each other.
     The first phase, the development and testing of the propellants, is now
in progress as the chemical industry consortium  is already  investigating
certain propellants.  These propellants are mainly for blowing agents and
refrigerants.  The results of these studies are expected to be available
sometime in 1994.  And it will probably take another year or two for this data
to be published and peer reviewed in the toxicology or medical journals.  The
information provided by these evaluations will provide basic data needed to
develop and safety test a line of consumer products.  Consequently,
toxicological investigations and product development cannot begin until 1994
at the very earliest.  However, recently it was learned that the propellant
HFC-134a, one that most likely could be used in consumer products, has not
begun its two year toxicology studies.
     The next phase after the evaluation of the propellants, the formulation
phase, involves selection of the valve to determine the spray rate or the
spray pattern of the product; can size and can strength also have to be
determined.  Then stability testing, compatibility of the can with the
product, and efficacy testing are required.  Preference tests with human
subjects obviously cannot begin until animal studies at least have been
initiated and evaluated.

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     The third phase is the actual  safety testing.   First, toxicity studies
are conducted.  Dermal  toxicity tests determine if  a new product absorbs
through the skin.  Inhalation toxicity of these products is also evaluated.
Animals are exposed appropriately to the new products,  and then observed for a
period of approximately 14 days.  Animals are examined for convulsions,
respiratory rate changes, agitation, body weight changes, and survival.
Animals that survive are sacrificed at the end of the observation period and
are also examined grossly and microscopically.  Primary irritation studies are
also conducted to determine the effects of a single application to the skin,
and to the eye.  Respiratory irritation studies determine whether or not a new
product would cause upper or lower respiratory irritation.  Sensitization
tests determine whether or not the products will cause sensitization or an
allergic response.
     Tests are also conducted to determine the potential for carcinogenicity.
These begin with the standard Ames test.  And then, depending on the results
of the Ames test, information from suppliers, the medical literature on the
propellants, and the vehicle and the active  ingredients,  in vitro tests may
also be conducted.  The testing for acute toxicity, irritation, sensitization,
mutagenicity, can be conducted  simultaneously.  This would take an eight-
month period.  The cost, depending on the types of tests, would be between
$40,000 and $80,000 per product.
     A subchronic test  is then  conducted to  determine longer term effects  and
target organ toxicity,  and to delineate exposure levels for the chronic or
lifetime study.  The duration of the subchronic test  is approximately  three
months.  Animals are examined for an additional three-month period to
determine  if  any of the effects observed are reversible.  The exposure level
used  in the subchronic  test  is  usually based on the acute  studies, the
information we've received from the  suppliers,  and the medical  literature  on
other components  in the product.  Changes  in body weight,  food  consumption,
behavior,  and  survival  are observed.  Complete  blood  and  urine  analyses,  blood
chemistries,  and  pathological examinations  are  run on all  animals  that die
during the course of the  study  and  those that are  sacrificed during  the end of
the  three-month  exposure  period, or after  the three-month observation  period.
And  of course,  all  the  data  are subject  to  statistical  analysis.   The  time
required for  this phase is  12  to  14 months,  and the cost  is  approximately

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$200,000 per product.
     Chronic toxicity is the next phase.   The objective here is to determine
the effects of each exposure level,  to determine a no observed effect level,
and to determine a margin of safety, that is, the margin between the exposure
level during product use and the level where no observable effects occur.  The
duration of this test is generally 24 months.  There are three exposure
levels:  low, middle and high,  and a control level.  The exposure levels are
based on the information derived from subchronic studies and medical
literature, and human exposure is taken into consideration.  Here, the same
types of observations as in the subchronic study are conducted, along with an
evaluation of tumor development.
     A true carcinogenicity study or a lifetime study with the product is
conducted.  At this time, we can also conduct teratology studies.  The
objective of a teratology study is to determine the effects of exposure of
pregnant animals to consumer products on the embryo, fetal viability, and
development.  The animals are exposed at various levels,  and a maximum
tolerated dose is used as the highest exposure level.  Sacrificed animals are
examined for such things as body weights, clinical signs of toxicity,
viability of the pups, fetal weights, gross observation, examination of serial
sections of pups, skeletal examination to determine the effect on the long
bones, and the effect on the various organs.  The estimated time for the
teratology studies  is 12 months, and the costs are approximately $150,000 per
product.
     The reproductive phase can also be conducted.  In this phase of the
study, we determine the effect of a product on three generations of animals.
The animal of choice  is generally the rat; the first generation  is mated from
that generation, a  second and a third generation.  We keeping exposing the
animals at this time, and keep mating them to determine the effects.  We
determine mating indexes, fertility indexes, live birth weights, 24-hour
survival, 4-day survival, and 21-day survival.  Animals are examined for
malformations when  possible, and a  statistical analysis is conducted as well.
The time required for this phase is 12 months, but it can be run
simultaneously with the teratology  study and chronic toxicity  study.  The cost
for this study is approximately $270,000.
     The final phase  is market research, manufacturing development, and

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distribution of the product.  In market research, consumer use studies are
conducted to determine the effects and the feelings of consumers.  This study
cannot be started until a sufficient time has elapsed in the longer term
studies to assure the safety to the consumer.  Procurement and installation of
manufacturing equipment must be done when the company has a feeling of
certainty that the tests will come out satisfactorily.  The final stage is
production and distribution.  The time period required for this phase is
roughly 30 months.  It must be emphasized that the time and costs that are
mentioned throughout this presentation assume that no problems arise.
     In summary, the purpose of this presentation was to demonstrate the
extent and nature of toxicologic  investigation needed to establish the safety
of aerosol consumer products involving new propel1 ants.  The tests described
range from those that evaluate acute toxic effects,  irritation, and skin
sensitization to chronic  toxicity, carcinogenicity,  assessment of reproductive
toxicity, and teratogenicity.  While several tests can be carried out
simultaneously, the starting point would be when the  propellant  is made
available and the formulation  is  identified.  It is  projected that the total
minimum time needed to complete these  studies is approximately six years.
Assuming that propel 1 ants and  the safety data for these propel 1 ants would  be
available for 1993, the earliest  that  industry could  possibly have a new
product on the market  is  1999.

Question:   [inaudible]

Ted Wernick:  The  total cost for  the  safety  testing  portion  of a product  would
be approximately  $1.5  million  per product.

Question:   How  much of this testing  is just  an ongoing  process,  looking  at
existing  product  improvements  and looking  for new  products?   Are some  of the
costs  you presented basically  costs  that  reflect this ongoing in-house
capability?   You  must  have  some funding for  this as  part  of  your normal
business.   Can  you separate these costs from having  to replace a whole line of
products?

Ted  Wernick:   Of  course there  are ongoing R&D and ongoing toxicological

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evaluations.  This discussion concerns a brand new ingredient, one that has
never been used before.  We're talking about an ingredient that hasn't even
been released.  I must emphasize that these are the tests that we anticipate
will have to be done.  Once the chemical industry releases the information, we
may decide that more testing or less testing is required.  Some monies are
always available, and we are all looking to have a better product, one that is
new and improved.  But when it comes to a brand new ingredient, it's hard to
say.

Question:  Could you comment on other factors besides the VOC  issue?  You
mention animal testing for example; there's a strong movement  for animal
rights and possible requirements for changing some of those tests from 1993 to
the year 1999.  What kind of impact, would you expect that to  have on both
timing and costs?

Ted Wernick:  It could have a very significant impact.  The most  serious
impact may be sabotage from extreme animal rights groups.  In  fact, the FBI
has labeled one of the groups, the Animal Liberation Front, as a  terrorist
organization.  They have done a fair amount of damage to  a number of
universities.  And if they hit a place where one of our  studies  is being
conducted, on the last day of a two-year study, there would be a  tremendous
impact.  The rat becomes exceedingly more and more valuable each  day of the
study.  Otherwise, I don't believe that any of the laws  or regulations that
the animal rights people are trying to  implement will impact  this type of
investigation.  But  I could be wrong.

Question:  Regarding hair sprays and antiperspirants  in  the aerosol
formulation,  if we use our hypothesis that testing has been conducted on the
HCFC's, chronic testing, things of that nature, and  it comes  up  clean, are you
saying that you'll have a tiered approach for the actual  formulated products?
Are you still going to.conduct chronic  testing  if  it has  been  done on the
active ingredient and the propel!ant already?

Ted Wernick:  That would depend on the  results of the subchronic  and acute
studies.

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Question:  It's a tiered approach.   You're going to start out with the acute
and mutagenicity?

Ted Wernick:  We would have to, definitely.

Question:  Is it true that not too much chronic testing being done on
formulated products on a routine basis?

Ted Wernick:  You're right.  However, we have to keep that option open.  I
tried to emphasize that each sequential step determines the need for
subsequent steps.

Question:  If we assume the test results are in by 1994, you estimate that  it
would be 1999 before the product would be released?

Ted Wernick:  Yes.

Question:  Is that assuming that you would have to go through the whole range
of testing?  If you stopped at the acute or subchronic portion, would that
subtract from that point?

Ted Wernick:  Of course.   But we can't commit to anything  until we have the
data.  We haven't  had the  first sample of  any new  propel 1 ant.

Comment:  [Don  Strubach, DuPont].  Those  of you who  attended  the  EPA/Industry
CFC Ozone meeting  in Washington on October 10-11,  1989 must  realize  that  it is
extremely unlikely that HCFC's will  be permitted for nonessential  aerosol  uses
by the Agency.   In addition,  I would like  to comment that  our company has  no
plans to make  HCFC's  available for  such  aerosol  uses.

Comment:   [Leonard Drell,  Demert  &  Dougherty].   To my knowledge,  this so-
called consortium is  greatly  a figment of the  imagination.  If there were a
valid consortium,  there would have  been  invitations to the people now in  the
propellant  business  to  join them.   To my knowledge,  no one in the hydrocarbon

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propellant business has been invited into this consortium, and there seems to
be a decision that hydrocarbons are to be abandoned.  Part of the purpose of
the investigation of propel 1 ants is to improve the species of hydrocarbon and
finding out more about hydrocarbons.  Much of the regulatory approach has been
to assume that all hydrocarbons are the same.  They are not; and another
assumption is that they are really a factor in ground-level ozone.  They can
be made less a factor.  I think that giving this industry and this audience an
assumption that there's a problem that may or may not be real, is not a good
service, and I don't know of any major marketer who's making plans based upon
a new propellant.  I really think they should look at improving the present
propel 1 ants.

Question:  Please comment on the amount of testing that is done, from a safety
perspective, that is associated both with product safety  as well as protecting
yourself against tort law or liability law requirements.  Also, are there some
EPA representatives who would like to comment regarding this  issue?  How can
we minimize our future liability?

Ted Wernick:  Let me try to answer this the best way  I can.   I have been a
toxicologist since 1956, and I have never worked for  a company that has asked
me to test a product to assure that we wouldn't be  sued.   I was always given
the assignment to make sure that our products are safe for  the people that
manufacture them  and safe  for the people that use them.   So as far  as
conducting a test to protect myself from liability,  I have  never designed or
conducted a test  for that  purpose.  The final responsibility  of toxicologists
is to assure the  safety of  our products.

Jim Weigold:   I  find  it hard to believe that  EPA would be able to tell anyone
that  they will be  immune from  suits.
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2.10 TED DAVIS
     Acting Assistant Director,  Division of Air Resources
     New York Department of Environmental Conservation
     New York Regulatory Activities
     Representatives from New York really appreciate the opportunity to share
information at this type of symposium.  To start with, I want to explain how a
consumer/commercial solvent program got into the N.Y. state implementation
plan.  As you may know, the Clean Air Act Amendments of 1977 required a two-
step approach for non-attainment areas.  A plan was submitted for ozone in
1982.  The wording of those programs that could be implemented were intended
to result in some ozone reductions, but they did not demonstrate attainment of
the ozone standard.  Unfortunately, the EPA proposed to disapprove that plan
in 1983, so we prepared another plan  in 1984 that  included five extraordinary
measures.  Those were measures that went beyond what we and the EPA believed
were reasonably available.  These measures included stage two gasoline  station
controls, reasonable available control technology  on small sources, auto body
refinishing controls, controls on architectural coatings, and lastly,
controls on consumer/commercial solvents.  However,  in submitting that  plan,
New York put some conditions on it.   First, we  requested that the EPA publish
its proposed Stage  II control technology guidance  document.   It was released
in a draft form  in  1979.   Second, we  asked that the  EPA get the oxidant model
working, so that before any final decisions are made, we can  predict what  is
expected to happen  with air quality.   Third, we wanted to assure tri-state
consistency with New Jersey, New  York,  and Connecticut.  None of these
conditions have  been fulfilled.   In the  current plan  we  assume  that  in
commercial/consumer solvents, the 6.3 Ib per capita  number that was listed in
AP-42 would be reduced  to  4.0.  That  is  roughly a  13,000 ton  per year
reduction.
     After approval of  the SIP, the  EPA initiated  the first  of  several  SAIC
studies.   It was done  during  1985-1986 and  its  purpose  was  to check  the
emissions  and  the  emission factors  that were being used  for
consumer/commercial  solvent categories.   This  study covered  New York,  New
Jersey,  and  California.   The  SAIC study confirmed  the f  :  per capita  figure
for  the New  York Metropolitan  area,  although the  categories  were  somewhat

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different from those in the AP-42.  A second SAIC study addressed emission
reduction techniques.  It was done in 1987 and covered only New York and New
Jersey.  The highest emitting product categories identified in the first SAIC
study, air fresheners, disinfectants, and insecticides, were studied in more
detail.  This study considered such changes as reformulation, change in
application method, substitution, and banning.  The second study included no
recommendations, and both New Jersey and New York concluded that the results
were not usable.
     Next we were sued in Federal court, with NYDEC and a few citizens' groups
opposing the EPA and New York State.  We were sued on the grounds that we had
failed to implement four of the five extraordinary measures, despite the fact
that the SIP never made a commitment to implement any measure until the other
conditions were met.  There was a similar suit in New Jersey.  They had a few
more measures that were not in the New York SIP; the only measure excluded was
reasonably available control technology (RACT) for four small sources.  The
court order took over a year to negotiate, and it concluded that we would
implement the Stage II program, the auto finishing program, and the
architectural coatings program.  We have developed regulations for those
categories and implemented them.
     However, we dropped all the other VOC programs in order to get them done.
So even the small source RACT program fell by the wayside.  We also agreed to
implement part of the consumer/commercial solvent regulation for the three
categories identified in the SAIC study.  The Part 235 regulations cover air
fresheners, disinfectants, and insecticides and require product registration,
a complete study, and full compliance by January 1, 1997.  More specifically
in the registration area, it applies to all VOC-containing products in the
three categories, and the registration had to be completed by September 1 of
this past year.  Registrations are slowly trickling in, and we have about 300
companies and 3,000 products registered thus far.
     The registration process also required a commitment to initiate a study.
If there was a consortium of manufacturers that represented 75% or more of the
volume in the three categories, then they could agree to conduct a joint
study.  Studies must be approved by July 1 of 1990.  The rule also required
that all the study protocols be submitted for approval by the 1st of January,
1990.  CSMA will submit a study protocol on behalf of at least 75% of the

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volume.  If a product is riot registered, there is a sales prohibition
commencing January 1 1990.  Shelf studies will probably be conducted to see if
there are unregistered products.   Manufacture date is not the issue; if a
product is registered, that it can be sold.  Each study had to be designed so
that a 25% reduction in VOC emissions, in tons per year, not ounces per jar,
would occur by 1997.  The study had to commence no later than July 1 of 1990
and be completed by January, 1994.  We expect to act on protocols in the
spring, and have them completed by the first of July.  For those companies
that are registered but have unapproved or disapproved protocols, the sales
prohibition would apply some time next summer.
     We are still studying the consumer/commercial solvent categories.  About
a year ago, we held the Saratoga Workshop and concluded the Saratoga
Agreement.  It was an agreement among the NESCAUM States - that's all of New
England, New York, New Jersey, and California, and Texas - that we would study
various consumer/commercial solvent categories.  Spray paints, all-purpose
cleaners, hair care products, adhesives, underarm products, windshield washer
fluids, and aerosol cans will be examined.  Air fresheners, disinfectants,  and
insecticides are also  included.  The  insecticides category  is expanded to
include all the pesticides.  Schedules were assigned to these categories.   New
York will study the spray  paint, the  all-purpose cleaner, hair care  product,
adhesive, air freshener, disinfectant,  and the pesticides/insecticides
categories.  New Jersey will also  review the  last three categories.
California will conduct a  study of underarm products,  and Texas  will  examine
windshield washer  products.   In the  first  year,  and  the first year  is  ending
shortly, we hope to be  in  a position  on  hair  care products,  underarm products,
and windshield washers, arid to be  able  to  make midcourse  adjustments on  the
ones that were already  in  our regulation.  Two years  is the deadline for spray
paints,  all-purpose cleaners, and  adhesives.  The  three-year study is for
aerosol  cans.
      In general, without  EPA  action  soon,  it  is  expected  that  amendments to
Part  235  will  start covering  other product categories.   If  the  EPA wants to
supersede the  states  in these  areas,  that  probably should happen soon.
Otherwise, we  will be in  the  rulemaking process  once again.  It is expected
that  we will  allow the same schedules in any new proposals  as  we have allowed
 in the past.

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     The study that New York is conducting is being handled by Pacific
Environmental  Services (PES).  It began in October of 1988, and we expect a
draft report in late August, 1990.  This study covers six product categories
identified in the first SAIC report as high emitters.  The study is a complete
inventory and reviews  VOC reduction options.  The study has been expanded to
include other parts of New England, and a draft is expected in February, 1990.
It will show the various options, what kind of emissions reduction could be
expected from them, and give guidance on how to further regulate if necessary.
The court agreed that insignificant sources emitting less than 100 tons per
year could be eliminated from consideration.
     In conclusion, it may be helpful to share the New York perspective,  it
was stated yesterday that the consumer/commercial category was 7% of VOC
emission on a nationwide basis.   In the New York metropolitan area it's 13%
based on 1987 data, and expected  to be 15% in 1990.  This  increase is not
necessarily due to increased emissions, but rather because of reductions  in
other elements of the emission inventory.  In 1970 the consumer/commercial
category was 6% of the New York metropolitan  inventory.  The New York
metropolitan area  includes New York City, Long Island, and the two counties
just north of the city.  From 1970 to 1987 the total VOC  inventory has
decreased from 625,000 tons  to 298,000 tons.  A 55%  reduction has occurred and
there  is discussion of a further  75 to 80% reduction.  Programs have already
been implemented for motor vehicles,  industrial sources,  and architectural
coatings.  These programs have been and are  being  implemented, and many are
being reexamined.  There is  discussion of a  stringent emission package  to
further reduce automotive emissions.  Our conclusion is that reductions in
consumer/commercial contributions to  high ozone are  an integral part of the
solution.  Whatever happens  in Congress or with the  EPA,  it  is hoped that
existing State programs will not  decelerate.
     We have discovered that industry needs  time however,  and that the  best
solutions will come out of an  industry/government  partnership that will need
time to develop.   There are  some  technical questions that  must first be
addressed.  The sampling methods  for  determining compliance, particularly from
aerosols, have not been developed.  An active emission  inventory  has not  been
developed.  We need to know  the  role  of VOC  substitution  before we can  make
decisions.  Consumer  satisfaction and consumer acceptability must  also  be

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assured.  And finally, we have to be very careful  concerning the environmental
and health consequences of what we propose.

Question:  You said that the New York City area has had a 55% reduction in
their VOC inventory since 1970.  What is the resulting ozone drop?

Ted Davis:  The design value for ozone has maybe gone done by approximately
one-third.  For a rule of thumb for the New York area, for every percent VOC
inventory reduction you get about 1/2 of a percent decrease in ozone.

Question:  In the development of a mandate for a reduction study, how do you
address the formulator who has a product that contains 100% VOC, and that VOC
is the active ingredient?

Ted Davis:  From our perspective, if there is still 100% VOC content but
consumers could use less of the product to get the desired effect, that would
still be considered a reduction in the amount of VOC emitted.  This would
still conform with the  intent of the regulation, which is to reduce hot summer
day and seasonal emissions.  We are not looking at an absolute reduction  in
content,  instead we are looking at a reduction in emissions.

Question:  [inaudible]

Ted Davis:  One thing not mentioned was that we would probably allow a
reduction program  in  place of  a study  if  somebody could demonstrate  a  25%
reduction in emissions.

Question:  The  1987 SAIC  study didn't  provide  any reliable  information, and
the  1985  SAIC  study also  had  some significant  problems  in  its  inventory.   I
question  the relevance  of any  data  from  the  1985  study.   Even  if the data were
correct  in 1985, there  are major  product  categories  in existence now that were
barely  created  in  1985.   It's  a constantly changing marketplace.  In addition,
the  1985  SAIC  study was based  on  no  accurate formulation  information,  very
little  accurate sales information,  and regional differences  in  the use of the
products  were  not  taken into  account.   The best data  in  the  study may  be

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within an order of magnitude.

Ted Davis:  It's still the best study we had, it basically started the ball
roll ing.
2.11 EDWARD HEIDEN President
     Heiden Associates, Inc.
     The Socioeconomics of Regulating Consumer Products
     Heiden Associations was retained by CSMA to conduct an economic impact
study of the cost of VOC removal for underarm products in the state of
California.  The products discussed at this symposium are in everybody's
closet, bathroom, garage, and kitchen.  The whole household lifestyle could be
affected.  No comprehensive figures on the total amount of consumer spending
involved have been published yet but it will be considerable.  For just four
categories, hair spray, antiperspirant/deodorant, shaving cream and
fragrances, shipments were worth $2,000,000,000 based upon 1980 data. These
figures are more than double that now for shipments, and consumer spending is
a 2- or 3-fold multiple.  Many products are involved, including, personal
products which have already been mentioned, household products, waxes,
starches, and laundry products, furniture polish, veterinary products like pet
sprays, paints, insecticides like flying insect sprays, automotive products,
cleaners, and even miscellaneous products like artificial snow and bird
repellant.  There are very few regulatory possibilities, and many of them
will, in one form or another, require suppliers to reformulate their products,
particularly focusing on aerosols.  This may also be true for non-aerosol
products, such as antiperspirants and deodorants. The impact will be large in
terms of costs for dealing effectively and efficiently with this regulation.
     The following is a review of the costs and some of the impacts that are
likely to arise.  There are two kinds of costs:  costs on businesses and
suppliers, and costs that affect consumers.  There are several categories of
business costs and many of them are quite large.  The first is capital costs
that reflect abandonment of line, or conversion of an existing aerosol line to
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a non-aerosol  line for manufacturing.   This is a fairly large capital  cost
item and will  affect many of these products.
     Second are R&D and marketing costs associated with reformulation of each
type that doesn't need particular content specification.  There are a good
many of these types of costs, and they are large and more exhaustive than you
might imagine.  They include such things as in-house laboratory testing to
determine the technical feasibility of product formulation and reformulation;
packaged screening studies to meet reformulated product profiles; adjustments
in container size and type and valve delivery rate; small-scale animal
toxicity studies; large-scale process testing; process compatibility; plant
manufacturing test runs, and so on.  In some cases, large-scale toxicity and
human irritation studies must be conducted.  Safety and efficacy studies; mass
production scale-up, consumer acceptance studies; and development of
advertising and marketing strategies, are required.  In-house marketing  staff
and out-of-house advertising agencies will be affected  in having to conduct
controlled distribution test marketing, develop new lithography mechanicals,
and conduct engineering assessment of equipment needed  for full-scale
manufacturing  (including plans for changes and plant and manufacturing  line
configuration).  In addition, decisions must be made in management analysis  as
to whether or  not to  introduce the new product. The key thing about many
segments of the  consumer products  industry,  including  some of the most
important ones,  is that there are dozens of combinations of  products.    Within
a single line  these combinations  are based on variations  in  product  size,
product type  (whether  it's  a standard  or a non-standard product, for  example),
the type of container,  and  appearance.  These are marketing  costs that  have  to
be applied  in  the context of a large number of product combinations.   Thus,
R&D marketing  costs are likely to  be extremely  significant.
      The third type of cost is the  replacement  cost  for the  hydrocarbon
propellant  to  create  an acceptable  non-VOC alternative.  In  connection with
the California study,  one major  manufacturer  indicated that, compared to an
upcharge  in  the propellant  cost  estimated  at  about  $0.26  per pound  for
hydrocarbon,  the upcharge for developing  an  acceptable VOC  alternative would
be  $1.00 to $5.00 per pound.  It was  also  estimated that  this would add, on
 the  average,  between  $.33  and $2.13,  using adjustments for  weight  and content
 of  container in the underarm area,  to  the final  consumer cost.   So replacement

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cost is likely to be substantial.
     The fourth category of cost involves changes in distribution
requirements.  One of the things found in the California study was that firms
would find it very difficult, if not impossible, to respond on a California-
only basis in terms of aerosol reformulation for underarm products.  Many of
the survey respondents, covering the majority of output for the underarm
antiperspirant and deodorant segment, indicated that they simply would not be
interested, and from an economic standpoint would not be able to separately
distribute products to California.  Under separate state-by-state regulatory
requirements a new set of costs would be added for distribution, storage, and
inventory costs.  New transportation requirements, changes in storage space
requirements, changes in company owned warehouses, separation of inventories,
and the need for clerical staff to monitor distribution and direct wholesale
and retail accounts, will all be additional costs.
     The fifth category, and an extremely important one, is the economic loss
that is associated with capital that will no longer be productively employed.
This includes the loss of aerosol cans, valves, plastic components,
ingredients, concentrates, propellants, and the loss of capacity to produce
those.  These are not just hypothetical losses, this is capital that  is  in
place and contributes directly and  indirectly to the gross national products.
This is a very significant loss, and it is recognized as such in the  impact
work that was done  in connection with the CFC aerosol reduction and ban.  The
costs will amount to well over a billion dollars  if you total up all  of  the
lost processes.  Obviously, we don't have the data or the scenarios yet, but
this is going to be an extremely significant category of cost.
     This is also a real economic loss as measured by and reflected by job
loss and  in reduced capacity.  There is also a potential cost in terms of
foregoing alternative research opportunities.  A good deal is heard about the
need to  develop an acceptable alternative to hydrocarbons.  No one at this
stage knows how much, but that effort represents lost opportunity  costs  in
terms of other kinds of R&D efforts that could have been undertaken.  This
could be an extremely significant component.
     Turning to consumer costs, what we know from the cost increments that
will occur from the business standpoint is that consumers are going to pay
significantly higher prices for aerosol delivery, if they're going to have

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them at all.   Some firms in our California survey said they would simply
respond by cutting out the production of aerosols and turn to non-aerosols.
Those firms that stay with aerosols will be reformulating them, and costs will
be reflected in significantly higher prices for consumers.  Also, we can
expect significantly higher prices for non-aerosols.  Although this is not as
definitive, there might well be a demand shift toward non-aerosols.  There
will again be some cost of reformulation involved, and both of these factors
will tend to increase the price of non-aerosol.
     Increased prices for both aerosol and non-aerosols with take place
against the backdrop of some equity considerations.  One  issue that is
extremely important to an economist, in addition to losses, efficiency, and
direct cost, is the distributional equity of costs and economic arrangements
dealing with a regulation.  Many affected consumers in attainment areas will
be forced to pay for these costs, but will derive no benefit.  Regulatory
approaches that are designed to address this issue, have  their drawbacks.
This equity issue is one of the key  issues.  It  is a very difficult problem
and one that is of enormous importance  in the  regulatory  impact area.
     Another dimension to be considered with aerosols  is  the  issue of  their
convenience.  Why do consumers like  them?  A good many consumers, we found  in
our California study, are real fans  of  aerosol delivery.  Practically  25% of
total  underarm products are in the form of aerosols,  and  this  had been a
fairly stable percentage over time.  We did a  small scale survey, not  a
statistical one, of California consumers with  respect  to  why  they liked
aerosols  and why they continued to purchase them even  though  they have
significantly higher price  per application than  non-aerosols.  The responses
included  quicker drying time and  allergic  potential to non-aerosols.   A number
of  responses  involved possible clothing stain  problems.   So  underpinning  the
tendency  in the marketplace to vote  with  the  pocketbook  for  aerosols  is the
issue  of  convenience.   For  many of  these  products,  the issue is  functional
usefulness  as well  as convenience.   A survey  of  users of these products might
find  a high concern for usefulness  to go  along with the  convenience.  But
again, we don't  have  specific  data  in this area, but  we  are talking  about a
loss  of  usefulness  as well  as  a  loss of functionality.
      The  last  issue which  we  found  in the California study was that  if
regulations  occurs  state-by-state,  some of the consumers in our survey

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indicated that they might take advantage of availability in other areas to
bring aerosols products back into California.   This issue can be troubling in
terms of achieving goals of reduced emissions.  Roughly 40% said that if they
were somewhere else and had the opportunity, they would purchase an aerosol
can that was banned in California.
     There are other impacts as well that cannot be looked at as rigorously.
First there is the impact on small business which is one that cannot be
neglected.  This impact is part of the fabric in the loss of economic value
for the upstream vendor industry that we talked about earlier.  In particular,
there is a group of individuals called contract fillers who fill the requests
of the formulators.  There are a lot of these contact fillers out there, and a
lot of them have very specialized, one-on-one relationships with
formulators/marketers.  They have been, if you will, in commercial marriages
for many years.  Fillers for aerosol underarm products specifically mentioned
that there is a very strong possibility that they would be forced out of
business.  The applicability goes well beyond underarm products in this case.
An impact on employment is also likely.
     There are other impacts that could be  important such as possible changes
in the competitive structure of this  industry.  Changes  in the competitive
role that contract fillers play may possibly change the competitive fabric and
market relationships in them. Possible loss in trade advantages may also occur
for some products.  It could well be that regulation will create a situation
where these products become non-competitive, thus reducing our price advantage
relative to countries that don't have these requirements, and changing  the
terms of trade.  That is a policy decision  that would have to be taken  into
account  in making  regulatory decisions.
     The point  is  that there are a  number of very  important  impacts.  We can't
possibly know what they all are or  could be.
     Any study of  the potential regulatory  agenda for reducing hydrocarbon
emissions has to take a look at the candidate for that regulation  from  the
standpoint of economic  impact as well as from the standpoint  of ozone
reduction.  An emissions  inventory  for purpose of rational decision-making  is
not enough.   It must be accompanied by an economic  inventory  or an economic
impact assessment.
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Question:  When you were mentioning the costs,  it struck me that there would
be significant loss of jobs, sales, and business opportunity associated with
excess industry capacity.  If you're talking about modified products,
reformulated products, it's not as if those products are necessarily going to
disappear or a whole gamut of products would disappear.

Ed Heiden:  No, it's certainly true that you would have new value added, in
the other sectors, but of course, you may have that at significantly higher
cost.  The point is however, that you will be losing what used to be a source
of employment and economic value whose capacity can not be converted.  If this
was convertible capacity, you would certainly take that into account, although
you'd still have the extra resource cost of conversion.  But we're talking
about capacity that could not potentially be earmarked for substitutes in the
event of severe restrictions on aerosols.  That would lead to permanently lost
GNP.

Brock Nicholson:   I think that  in  that one example one might suggest  that
you'd lost some of that, but (1) that doesn't necessarily  represent  the
prospects the  industry  as a whole  across  the country,  and  (2) to  a certain
extent,  those  employees  and that capacity are certainly viable  there  for
conversion, for new opportunity, and  for  new products  not  strictly  in the
aerosol  can area.

Ed  Heiden:  It is  one thing to  say that these people  could find new  employment
and it  is  quite another to  say  that a part of our country's  gross national
product  is  permanently  lost.  There are enormous friction  and dislocation
costs  in making transitions for capital.   I  am  sure  it can be done,  and that's
why one  of  the costs  I  have not talked  about was the  cost  of lost employment.
The capital specifically designed  for aerosols  in most cases can't  be
converted  in  terms of the  upstream supplier capital,  although the lines can be
converted  from the marketing  and formulation  standpoint to a great  extent.
One of  the participants in  the  California study indicated  that  they could not
convert  their aerosol  line  and  that they  would  have to abandon  it;  but
generally,  the conversion was  at least a  technical possibility.  We're talking
 about the upstream suppliers and that's simply  lost GNP.
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Comment:  [Bob Hangebrauck,  EPA].   It seems that we need to look at this whole
picture as an evolutionary kind of thing that is going to occur anyway.
Within our development of new products,  existing products change with time.
The names are going to change, and at the same time, new products are being
brought into the marketplace.  I think we're talking about environmentally
attractive evolution.  I am used to seeing a label  on products which says
"new".  A lot of times it's the largest lettering on the product.  This gives
us the idea that there is constant change going on in the consumer area with
respect to products.
     Another comment on the aerosols; I think there are obviously alternative
propellants and alternative dispensing mechanisms that people are thinking
about.  Considering that worldwide we are manufacturing something like 8
billion of those units a year and they are causing disposal problems, maybe we
should think about  innovative approaches for dealing not just with the problem
discussed here, but other aspects of  it as well.

Ed Heiden:  Those are good comments.  The goal you stated, to make sure that
commercial development is seen as part of the normal process of  the ongoing
development of  innovative new products, is a worthwhile goal.  The point  is,
however, that most  new product development occurs against a calculus that  it
is going to be worth while in a consumer payoff  sense, that there will be  a
market for  it, and  that the  benefits  will exceed the long run cost of  the
investment.  That is a good  principle to apply to this type of regulation  as
well.  Certainly you don't want to  impose these  costs unless they will have
meaningful benefits.

Question:  The set  of concerns that you talked about  in regulating  in  this
area, the desire to minimize  vulcanization, to minimize costs to industry  and
consumers,  and to assure compliance,  are the traditional  array of regulatory
approaches; prescriptive command  and  control, fees, market permits, whatever.
What  kind of advice would you suggest as a way to regulate in this  area, where
obviously  it is difficult for the Agency to know a  priori all of the possible
impact?  What are the desirable features of different regulatory approaches?
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Ed Heiden:  Considering the basic costs and benefits of permitting, taxes, and
command and control, these approaches should be examined.   They have real
implications for addressing some of the equity considerations that we've
talked about.  But, again, they also have their problems.   I think it is very
admirable to examine all the potential strategies and conduct a systematic
assessment of them.  I can't answer your question, however, because I have not
given a lot of thought to it.

Comment:  [Leonard Drell, Demert and Dougherty].  There seems to be no
experimental verification for many of the allegations that have been made.  It
is very hard to show industry that a real benefit would occur, in terms of
ozone diminishing, from banning aerosols.  Hydrocarbon propellants have been
lumped together, but the whole concept of VOC exaggerates the ozone forming
potential of hydrocarbon propellants.  It would be unfortunate for industry to
make a large sacrifice with no real benefit to public health.  The best course
would be  to experimentally verify some of these assumptions to convince both
the public and  industry that this is  a worthwhile endeavor.  Reducing ozone  is
very important, but the elimination of aerosols will not solve the problem.
The attitude that  hydrocarbon propel!ants should be disposed of  ignores  the
possibility that they can be improved.   But the government  people  who have
spoken here show no desire to  improve  them.   The  problem requires  a  solution;
it doesn't require unproven  theories.

Jim Weigold:   EPA  and a  lot  of other  people have  been  studying the issue  of
hydrocarbons for the  past  18 years.   There  is an  enormous  body of  data  on
these  studies,  and I  would  suggest  that  you contact  some of EPA's  researchers.
The specific  issue of how much  reduction results  from  regulating aerosols is
extremely difficult to  estimate.  There  is  strong feeling  that reducing
hydrocarbons will  reduce ozone,  but continued progress  in  meeting  the  ozone
standard  is  going  to  be enormously  expensive.  Analysis that takes place
should be comparative.   The  Clean Air Act does not  allow  consideration  of
costs  in  establishing ambient  air  quality standards.   It  only allows indirect
consideration  of  costs  in terms  of  the time needed  to  achieve the standard and
for  implementation of the programs  achieve the standards.   It is understood
that  this process  is  going to  be enormously expensive  and  disruptive.   If a

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strict cost benefit analysis were performed and the benefits were accurately
determined, there might be some imbalance.  But, while costs for this industry
are certainly an important consideration, impact analysis has to include more
than that.
2.12 SANDRA CHEN
     Supervisor, Bureau of Engineering and Regulatory Development
     New Jersey Department of Environmental Protection
     New Jersey Regulatory Activities
     The pathway that led to New Jersey's regulation of volatile organic
content of consumer products began in 1982, as New Jersey finalized its
submittal of revisions to the SIP for the attainment of the National Ambient
Air Quality Standard for ozone.  New Jersey found that it could not attain the
necessary reduction for volatile organic emissions through reasonably
available control strategies alone.  To be able to demonstrate attainment of
the ozone standard by 1987, the State had to resort to extraordinary measures.
One of these extraordinary measures was reducing the emissions from consumer
or commercial solvents.  In the revised draft SIP submitted to the Federal
EPA, New Jersey proposed to study the feasibility of implementing certain
extraordinary measures including controlling emissions from the use of
consumer solvents.  However, during New Jersey's negotiations, the EPA
maintained that a commitment only to study the feasibility of these measures
was insufficient.  The final version of the SIP document approved by the EPA
on November 9,  1983 described consumer/commercial solvent use as a source
category which  includes volatile organic emissions from a variety of products,
including toiletries and cleaning agents.  The Department committed to a
strategy of achieving emissions reductions within this source category by
developing appropriate regulations concerning reformulation or product
substitution.   Certain qualifying language preceded this commitment in the
text such that  if air quality improves, or if more reductions than anticipated
are achieved through the reasonably available control strategies, the
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magnitude of the emissions reductions necessary from extraordinary measures
would be reduced.  In such a case, New Jersey would seek a SIP revision.
     The commitment to adopt extraordinary measures including regulation of
consumer products was made "until and unless such revisions are approved by
the U.S. EPA."  Also, regulation of product content was one of a number of
measures the New Jersey regulators felt could best be addressed by the U.S.
EPA at the national level.  Most consumer products are marketed on a regional
or national basis, making regulation by a broader jurisdiction rather than the
State more logical.  All these factors left a sense of ambiguity at least  in
the minds of New Jersey regulators as to whether they were in fact committed
to regulating emissions from consumer product use.  And in any case, it was
not a question that needed to be settled right away since the schedule  in  the
1983 SIP document did not require adoption of regulations implementing
extraordinary measures until January 1, 1987.
     New Jersey did, nonetheless, clearly recognize its obligation to carry
out studies to establish the technical basis for regulating emissions from
consumer products.   It carried out this obligation by contributing monies, as
did New York and California, to  help support a two phase consultant study
conducted by the U.S. EPA Region  II.  The first phase of these studies  was
undertaken  in 1985 and set out to determine  if there  is a potential for
emission reductions  from regulating  the consumer product category.  A Phase  I
report entitled  "Photochemically Reactive Organic Compound Emissions From
Consumer and Commercial Products" was completed  in November of 1986.  This
study reported that  tens of thousands of tons of volatile organic  compounds
were being  emitted  in New Jersey each year through product use.   Further,  it
found that  a preponderance of these  emissions emanated  from the  following  six
consumer and commercial product  categories  in addition  to  architectural
coatings adhesives,  hair  sprays,  all purpose cleaners,  insect sprays, air
fresheners  and disinfectants, and car polishes  and waxes.  The  second phase  of
the  study  focused  on two  of these six categories:  air fresheners and
disinfectants,  and insecticides.  A technical report,   "Control  Techniques for
Reducing  Emissions of Photochemically Reactive  Organic Compounds from Consumer
and  Commercial  Products," was  issued on  September  30,  1987.   This report
recommended banning the use of  ozone precursors in the manufacture of  consumer
products  as probably the  most effective  control  strategy.   It noted that such

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banning might serve as an impetus for industry to pursue other strategies such
as reformulation, changes in application method, and development of substitute
products.
     New Jersey regulatory focus had been on support of these two studies.
Despite the schedule in the SIP ruling that implementation of extraordinary
measures would be proposed by January 1, 1986, no rule had as yet been
drafted.  On November 14, 1986, a coalition of environmental groups, led by
the American Lung Association of New Jersey and the Natural Resources Defense
Council notified the New Jersey Department of Environmental Protection and the
U.S. EPA of its  intent to commence a civil action against the state for  its
failure to carry the SIP commitment.  On January 28, 1987 this coalition
brought suit to compel the state to implement Stage II gasoline vapor recovery
and six extraordinary measures  including control of emissions from consumer
products.  On September 24, 1987 the U.S. District Court Judge ruled in  favor
of the plaintiffs, and on November 19,  1987, ordered the State of New Jersey
to act to adopt the seven measures in accordance to the prescribed stringent
timetable.  New Jersey was ordered to adopt regulations to control emissions
from consumer solvents by December 30,  1988.
     New Jersey  acted expeditiously to  carry out the Federal court order.
Regulatory development work on  the consumer solvent category was combined with
the regulation of the volatile  organic  content  of architectural coating.  A
combined rule NJAC 727-23, otherwise referred as Subchapter 23, was proposed
on August 15, 1989.  The proposal took  the strategy of establishing maximum
content limit and concentrated  on the two product categories focused on  in the
second Phase of  the U.S. EPA Region II  consultant study.   The proposal
prohibited anyone from selling, offering for  sale, using,  or manufacturing for
sale within New  Jersey any air  freshener or consumer  insecticide which did not
conform with stipulated  VOC content limits, and it set forth a  3-step
implementation schedule, with  a more stringent  VOC content limit being  imposed
at each consecutive step, for  both air  fresheners and  insecticides.  The VOC
content of regulated products  was to be limited to 50%  in  1990,  25%  in  1992,
and 5%  in 1994.  The  intent of the phased-in  approach was  to allow
manufacturers to reformulate their products,  or to develop substitute  products
or alternative modes of  application for their product.  The proposal also
required product labeling and  recordkeeping,  and spelled  out the department's

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authority.   The intent of the labeling section was not only to facilitate
enforcement also to allow informed and environmentally conscientious consumers
to choose products with lower emissions potential.  The products registered
under the Federal Insecticide, Fungicide,  and Rodenticide Act (FIFRA) were
exempted from the labeling requirement as  the labels of the products
registered under FIFRA could not be changed without prior EPA approval.  The
intent of the recordkeeping section was to create a paper trail from the
retailers to the distributors and back to  the manufacturers which could be
retraced by enforcement officials.  The inspection rights to the department
were included so that affected retailers,  distributors, and manufacturers,
would be aware of the department's authority and of their obligation to assist
and not hinder or delay the performance of any inspection.
     Voluminous comments were received on this proposal.  As the department
studied the comments, it recognized the validity of the issues raised by a
number of commenters.  The department recognized that there was uncertainty as
to the availability of alternative products, particularly for  all types of
insecticides.  The absence of a detailed  inventory, compounded by the
reluctance of manufacturers claiming confidentiality of information  and trade
secrets, undermines confidence with regulatory assessments of  the proposed
rule's effect.  Nonetheless,  the  underlying premise of the rule, that
emissions from solvent-based  products contribute  to New Jersey's overall
emissions, could  not  be doubted.
     Subchapter  23 was adopted on January 26,  1989, and was  published  in  the
February  1 New Jersey Register.   Because  of the  uncertainties  associated  with
the technical basis of the rule,  the  version  adopted was  less  comprehensive,
less stringent and less burdensome on the regulated community  than  the
original  proposal.  Consumer  insecticides were not made  subject  to  the
volatile  organic  substances  (VOS) content limit  or  labeling  requirements.
Subchapter 23 did, however,  establish required documents  of  VOS  contents  in
consumer  insecticides shipped for use in  New  Jersey.   Only the 50%  VOS content
limit  for air  fresheners  was  adopted.   In addition,  retailers  of air
fresheners were  exempt  from  recordkeeping requirements.   In  order to make
certain  of the  architecture  coatings  standards in this rule  were consistent
with  New York,  the department undertook immediately following the adoption of
Subchapter  23  to propose amendments  to it.  These amendments appeared in the

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New Jersey Register on May 1 of this year and were adopted on October 16,
1989.  These amendments affected primarily the architectural  portions of the
rule; however, the definition of air fresheners was amended in response to
comments to explicitly exclude products for use on the human body, such as
perfumes.
     To ease the burden on manufacturers who had to contend with the use of
differing terminology and different jurisdictions, the changes also allowed
other terms such as VOC or PROC to be used in labeling to refer to a product's
volatile organic contents.  The term normally used in New Jersey  is VOS.  And
the unlimited exemption of private products subject to a fifth rule was
deleted.
     In June, during the public comment period for these proposed revisions,
the department received a petition for rulemaking from over two dozen New
Jersey paint retailers requesting that the rule be further revised to include
a grandfather clause for architectural coatings.  The department  granted this
petition, thus setting into motion the development of a second set of
revisions.  In lieu of the recordkeeping of provisions previously promulgated,
the department is proposing to require manufacturers and distributors to
attest on the invoice, bill of lading, or other shipping document to the
distributors or retailers receiving the shipment  if the product  is in
compliance with Subchapter 23 requirements.  And  also,  in  lieu of only
manufacturers of consumer insecticides being asked to document the VOS  content
of products sold  in New Jersey, all manufacturers of consumer products
containing VOS sold for use  in New Jersey are to  be required to maintain
records indicating the type  and quantity of products sold, their  VOS content,
and the number of units sold.  Manufacturers are  to report this  information
upon request to the Department.
     Also, the intent of  this provision  is to make accessible to  the
department a valid database  as  it proceeds with future  consumer  product
regulation.  This second  set of proposed revisions to Subchapter  23  was
published just last week  on  November  6th,  in the  New Jersey  register.   Public
comment on this proposal  is  invited.   The deadline for  comment  is the  eighth
of December.  I encourage any of you  who wish  to  do  so  to  submit  comments  in
writing, or  in person at  the public hearing  scheduled for  December 5th  in
Trenton, New Jersey.

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     New Jersey and many other states have not yet come into compliance with
the National  Ambient Air Quality Standard for ozone.   Further reduction of the
emission of ozone precursors must inevitably be an objective for air pollution
control programs in states such as New Jersey for at  least the next decade.
This ensures that reducing the emission of volatile organic substances from
products will not be overlooked by regulatory programs in years to come.  The
steps that New Jersey has taken to date toward the regulation of product
emissions are clearly just the beginning.  There is more information to
gather.  There are more emission reductions that may be obtained from the air
freshener product category and there are more product categories to address.
There are products used in commercial activities, as well as those used by
consumers to consider.  Also, there remains a lot of thinking to be done as to
the appropriate control strategy.  Consumer products are one emission category
in which the use of economic  incentives and disincentives may be an
appropriate approach.   It may be more socially beneficial to allow market
forces, rather than the more  inflexible product  VOS content ban, to dictate
which products will be  forced out of the marketplace.  As New Jersey
contemplates future consumer  product rulemaking,  it does not believe  it will
be proceeding  in  isolation.   New Jersey  is committed to working with  other
states to form a  common regulatory strategy.  New Jersey  is mindful of  the
initiatives  being  undertaken  in California.   The EPA,  as the calling  of this
conference attests,  is  now  also taking steps  to  act  in the  consumer product
arena.  The  new  Clean Air Act Amendments,  if  adopted,  would make  regulation  of
product emissions  a  national  initiative.
     As a closing  remark, I  will  comment  on  the  provision  for  federal
preemption of  consumer  product  regulation  and the Administration's  Clean  Air
Act  bill.  While New Jersey believes that  the U.S. EPA should  take  the lead  in
regulating consumer  products nationwide,  we  also believe  that  there should be
no  preemption  of state  rulemaking.   More severe  regional  or local  ozone
problems  may require some states  to  be more  stringent  than the EPA.   Also,
state  rules  can  test innovative strategies,  which could  help the EPA in its
efforts  to  regulate  this  extraordinary VOC category.

Question:   I think that the opposite is  true regarding your last statement
about  preemption and the state of New Jersey's position that they should have

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their own regulations.  The ozone problem in New Jersey is related to the
problem in New York City and Philadelphia.  I don't see how any regulations
which relate to the State of New Jersey are going to affect the overall
inventory of a region which goes beyond the state boundaries.  The New Jersey
situation is a classic illustration of the preemption issue.

Sandra Chen:   The problems of the Northeast corridor are clearly not going to
be solved by the actions of any one State.  The actions of any one State can
contribute to diminishing these problems, but the most effective strategy is
for all the states in the corridor to work together in a common and
cooperative fashion, and this is certainly an objective we would like to see
achieved in New Jersey.

Question:  New Jersey's proposed rules allow manufacturers to ship products
containing VOC out of state, but manufacturers cannot ship these products into
the state.  It seems that you're just pushing the problem back into the
Northeast corridor.

Sandra Chen:  Our jurisdiction is as a State agency and our mandate is to
protect the air quality of New Jersey.   This is what we have the authority to
do.  We would welcome similar actions in neighboring states, but we can only
act to mitigate this problem in New Jersey.

2.13 MICHAEL KOSUSKO
     Air and Energy Engineering Research Laboratory
     U.S. Environmental Protection Agency
     EPA Research Toward Reduction of VOC Emission from Consumer Products
     The EPA's Air and Energy Engineering Research Laboratory (AEERL)  is
responsible for air pollution control research in the Office of Research and
Development.  In particular, the Organics Control Branch has the
responsibility for ozone non-attainment, air toxics from organics, and
woodstove emissions.  There are a number of research programs ongoing  in the
Branch, including some concerning add-on control technologies.  I'm
responsible for stationary area sources of VOC and how they can be reduced.
The funding for the program has been $300,000 over a three-year period for all

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area sources and consumer products.
     The first stage in our current  program is to gather information about
consumer products and evaluate emission reduction strategies.  AEERL will  be
supporting New York State and NESCAUM in gathering more information about
emissions in the Northeast, and will continuously monitor California
activities.  AEERL was also involved in the planning of this symposium and
gathering much of the industry information.
     The other part of our program involves source-specific research.  A
report on aerosols was prepared and is currently being reviewed by CSMA and
other industry representatives.  Once these reviews are complete, we will
decide whether or not to publish the report.  Some concerns expressed have to
do with the reliability of the formulation data  in the report and the
interpretation of market data to yield a true emissions inventory.  Accurate
emissions  inventory data are very important.  Another question concerns the
loss of effectiveness  in changing from aerosols.   If we go to a different
product form,  is that really going to make a  difference in the amount of VOC
emitted?  The  same question arises with changes  in formulation, especially
once you take  into consideration consumer  use patterns  and the effectiveness
of the product.  The  second source-specific research project has  to  do with
charcoal lighter fluid emissions and  the potential for  emissions  reduction.
This  is  a  small  source,  but emissions  can  be  eliminated almost entirely  by  use
of alternatives.   Evaporative  and combustion  emissions  from  charcoal  lighter
fluid account  for  about  one-tenth of  a percent  of the  VOC  inventory.  The
alternatives may involve replacement  of  charcoal altogether  or replacement  of
only  charcoal  lighter fluid  by using  electric starters  or  chimney starters
 (where  you mount the  charcoal  over  a  screen and use  a  natural  draft and  a
piece of newspaper to light  the charcoal). Of  course,  there are other
 alternatives  that  have to do with  using solvents to  get them started.   We
 also  have  a very small  effort (in  the range of  about $25,000)  going on  right
 now to  try to  identify existing methods for testing  the VOC content of
 products.
      The plans for the current year are to finish the ongoing work, and
 prepare for next year's projects.   The EPA administrator took 2% of the R&D
 funds for fiscal year 1991 to work on pollution prevention type projects,
 rather than add-on controls like carbon adsorbers or catalytic incinerators at

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the end of a stack.   Pollution Prevention is concerned with changing
formulations and changing process methods to reduce the amount of emissions.
Our initiative Demonstration of Emerging VOC Area Source Prevention Options is
one of probably 100 proposed projects.  The laboratory was funded for this
effort for the fiscal year 1991 at the level of $1,000,000.  There is
potential for funding in fiscal year 1992.
     One important issue in the pollution prevention initiative was to have a
broad base of support partners in the effort.  AEERL is the lead laboratory or
the lead agency, but others have a part to play in the initiative.  The
initiative is split essentially into two parts, with funding equally divided.
The first part  is demonstrating the viability and benefits of substitutes for
volatile organics.  This is an interesting effort, because it's going to be
jointly funded by our Laboratory, South Coast Air Quality Management District,
and an unidentified  industrial partner, at a level of about $250,000 per year
per group.  The proposed activities will look at alternatives to aerosol
propellant packaging and whether they will have an effect on VOC emissions,
and surface coating-free materials.  The significance of surface coating-free
materials is that, if you can avoid coating a structure on a regular basis,
you can cut down the amount of emissions that come from that process.  If you
have a surface that doesn't need to be coated at all, you can reduce emissions
even further.   For example, a few years ago U.S. Steel came out with girders
that rusted in  such  a way that protected them from the need to be coated.   The
other participants in this part of the work are South Coast Air Quality
Management District, Region 9, California ARB, and OAQPS.
     The second part of the prevention  initiative deals with consumer
institutional product VOC prevention options.  This work  involves development
of information on organic emissions from consumer products..  The background
engineering analysis is to identify the key players in the marketplace.  We
plan to get a better inventory, have more workshops to  identify pollution
prevention options,  and examine technical/institutional barriers to making
changes to products.  An example of a technical/institutional barrier might be
found  in the stratospheric ozone program  in the use of  Freon refrigerant  in
automobile air  conditioners.  Until a few years ago, there was no way to
certify the quality  of recycled Freon,  and  for this reason the automobile
industry would  not honor their warranties when recycled freon was used.  The

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AEERL identified this problem, set up a work group, and developed a test
method for recycled automobile refrigerants.  Now there is a standard for
recycled Freon, and there is recycling equipment in the automotive industry.
We need to have this type of workshop to work on the problems and the barriers
that are being identified today so that we can go forward.
     In conclusion, the purpose of our program is to gather information about
the entire consumer products industry and focus on emission reduction options
for specific products.  Secondly, to date, our research efforts have been
pretty small, but we expect them to grow in 1991.  We have identified several
areas of uncertainty, a lot of them came directly from CSMA's response to the
aerosol report, and a lot of them have been identified here at this Symposium.
The consumer products industry is extremely complex, and we're going to need
to cooperate with industry to make gains and to come up with an attainable and
verifiable VOC reduction strategies and goals.  Cooperation between industry
and government is needed to identify the barriers to making changes and to
identify opportunities for pollution prevention.  Some of these barriers may
be greater than one company alone can handle.  We would like to work with
industry, with CSMA, and other trade associations to define what government
research may be beneficial.  And finally, we need some input on how we are
going to focus our research in consumer products to make  a difference.
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                          3.0  WORK GROUP SUMMARIES

3.1  PERSONAL CARE PRODUCTS

     The Personal Care Products Work Group focused its discussion on four
major points:

1.   Current inventories of VOC emissions from the use of consumer products
     are inaccurate and unreliable.
2.   Future  inventories should be compound-specific and consider the ozone
     formation potential of VOC's used in consumer products.
3.   Discussions of regulatory approaches is premature.  Regulatory approaches
     should be tailored to specific product categories.
4.   Control measures selected for consumer products must be accompanied by a
     demonstration that reductions in ozone will be achieved.
5.   Regulation of VOC's must be equitable both across VOC  source categories
     and within specific consumer product categories.

3.1.1     Development of an Inventory Database

     Industry representatives felt strongly that there is not  currently a
sufficient database upon which the EPA can base a regulatory program.  A
chemical specific consumer products VOC emissions inventory should be  the
first priority for regulatory development.

     There was consensus that the  inventory protocol  should be jointly
developed by the  EPA  and industry, and then quality assured.   Industry would
be happy to  work  with the  EPA and  its consultants in  order  to  insure  that  the
 inventory  is done with  a full understanding of  the affected industry.  The
aerosol  industry  uses only three hydrocarbons as propel 1 ants,  and there are
only five producers of  these propel 1 ants.  The  participants from the  aerosol
 industry felt that their industry would be happy to work with  the EPA by
giving  them  ozone formation data on each  of these three  hydrocarbons.
 Information  on product  formulation  is available from  the Cosmetic Division of
the federal  Food  and  Drug  Administration  for many consumer  products.
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     The work group participants also felt that clarification of the goal  of
regulation is needed:   is the EPA intending to focus on the reduction of VOC
emissions from the use of consumer products,  or on the overall  reduction of
tropospheric ozone?  This issue would have bearing upon how an inventory is
executed, as well as upon regulatory strategy in general.

3.1.2     PHoHtlzatlon of Solvents

     Industry feels the need to demonstrate to regulators that all VOC's are
not the same; different solvents have different potential  to contribute to
ozone formation.  Many participants also had difficulty with the EPA's
definition of a "VOC", feeling that it is too broad and leaves formulators no
solvents with which to work.  According to the EPA's definition, unless a
product is water-based, it contains some solvent and consequently emits some
VOC.  According to industry representatives, many personal care products would
no longer be effective without some solvent content.

     In the case of aerosols, propellants are liquified gases and are
virtually all solvents.  The group also pointed out that many alternative
(i.e., non-VOC) propellants are likely to create new emissions problems or
contribute to other existing air pollution problems.   It was the opinion of
some participants  that hydrocarbons are the most acceptable propellants and do
not contribute  significantly to air or water  pollution.

     The group  suggested that the  inventory of  VOC  emissions be compound
specific and  include  some  consideration of each organic compound's  relative
ozone  formation potential.   Participants  felt that  it  is  important  for the
inventory to  include  ozone formation  values for each  of the  50  most prevalent
organic  compounds  in  consumer  products.   All  industry  participants  agreed  that
photochemical  reactivity must  be  considered.

      One industry participant  suggested  that  the  "80/20"  rule  may apply,  in
that  a relatively small  subset  of products (i.e.,  20%) may produce  80% of the
VOC emissions.   Focusing on the 20% would produce substantial  reductions  with
less  disruption to the industry as a whole.
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3.1.3     Ozone Reduction

     The group felt it important that any proposed control of consumer
products include a prediction of the amount of ozone reduction it would
achieve.  The group considered market approaches to regulation, such as
economic incentives and allotments, viable options; however, industry is not
able to assess the merits of these options without an emissions inventory and
an estimate of the ozone reduction that the EPA intends to accomplish.

     In addition, there is strong concern within  industry about having
sufficient time and opportunity to adapt/change their products to accommodate
regulation.  A ban similar to the California ban on aerosol deodorants could
be very disruptive to the personal care product industry  if insufficient
warning and preparation time were given.

     Therefore,  industry and government should work together to establish a
reasonable attainment goal.  Industry representatives feel  that they  can
familiarize regulators with their production processes and, thus, ensure
development of an attainable regulatory goal.

3.1.4     Control Measures

     Participants agreed that product substitutions are  feasible  with some
personal care  products;  for example, spray  deodorants can be  replaced with
stick  deodorants, which  contain  less VOC's.  However, substitution  is not
possible with  other  products such  as styling mousse or hair spray.   Product
design changes could also  limit  VOC  emissions;  for example,  containers  can be
designed to  release  a pre-measured  amount of  spray with  each  application.  The
cost of this  change  could  be high,  however,  and VOC emission  reductions could
be  negated  if  the consumer repeatedly pressed  the spray  button.   Consumer
preferences  and  willingness  to  accept substitutes are  an important
consideration  in finding product substitutes  with acceptable market impacts.
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3.1.5     Fairness in the Marketplace

     Fairness in the marketplace should be a guiding principle for any
proposed regulation.  The regulatory approach should be tailored to specific
product categories, providing for reasonable exemptions for products in which
solvent content is essential.  The equity (fairness) issue addresses concern
over possible disproportionate effects (impacts) between (1) small and large
companies, and (2) fair-share of ozone reduction burden.

3.2  HOUSEHOLD CARE PRODUCTS

     The participants in the Household Care Products Work Group felt that it
is too early in the regulatory process to provide answers to the nine
questions posed by the EPA for this workshop.  They felt it imperative that
industry, States, and the EPA continued to work together in the future to
answer some of these questions.  Instead, the group chose to concentrate its
current discussion on three areas:

1.   Current research activities on VOC emissions from  their products,
2.   Evaluation of the regulatory approaches discussed  in the morning  sessions
     of the workshop, and
3.   Steps the EPA should take next to gain a better understanding of  VOC
     emissions from consumer products.

3.2.1     Current  Research Activities

     An  industry  consortium  has  been  established  in response to recent
regulations  (NY Rule 235) adopted by  the  New York Department of Environmental
Conservation  (NYDEC).  The consortium has been  charged  with developing a
protocol  for  the  25% reduction  of VOC emissions from the following  products:
air  fresheners, disinfectants,  room deodorants, and  insecticides.   NY  Rule  235
includes  a four-year study period to  develop this protocol. As of  this date,
the  consortium has elected officials  and  a  Steering Committee,  and  has
approved  bylaws.   They have  yet  to establish technical  committees to develop
specific  protocols.
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     The Soap and Detergent Association (SDA)  is currently studying the fate
of the volatile organic constituents in a number of consumer products to
determine whether or not VOC content of consumer products equals VOC
emissions.  In the household care products category, many of the end use
solutions which contain these products are disposed of down household drains,
and end up at wastewater treatment plants or in septic tank systems.
Preliminary study results indicate that a large percentage of household
products that go down the drain are not emitted to the ambient air and thus
will undergo biodegradation.  Preliminary results from Phase 1 of the study,
which evaluated light duty and heavy duty detergent products such as liquid
dish washing and laundry products, should be available to the public by the
end of 1989.  The SDA believes the results from these studies will be broadly
applicable to other categories of household products.

     The Clorox Company is also studying the fate of VOC's in certain consumer
products.  They are currently conducting a study on the formation of volatile
and non-volatile chlorinated organics from household bleaches.  Clorox feels
that VOC's may undergo other processes besides biodegradation and release to
the air.  Their study includes identification of interactions that may be
occurring between the VOC's  in the products and other materials in sewage.

     Members of the work group also  indicated that  some reformulation and
testing of new products is underway  in response to  recent State legislation.
Some companies are either attempting to reformulate or are choosing to abandon
certain products  in the air  freshener category  in order to comply with
recently promulgated NJ regulations.

3.2.2     Evaluation of Regulatory Approaches

3.2.2.1   Fee Structure--
     The household care products group agreed that  a fee  structure  is not a
desirable option for this industry.  There was concern that whatever fees were
established would not achieve the desired goal of reducing VOC  emissions,
because industry and consumers would be willing to  pay more for certain
products containing higher percentages of VOC's.
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3.2.2.2   Marketable Permits--
     Marketable Permits were considered a better option than the fee
structure; however, there are many issues to resolve.  Participants encouraged
the EPA to explore this option and provide the industry with more concrete
ideas.  One issue discussed was the need for an accurate baseline emissions
inventory.  The participants felt that an inventory is essential for gauging
how well a regulation will achieve the desired goal of reduced VOC emissions.

3.2.2.3   Command and Control--
     Participants felt that the consumer products industry has successfully
dealt with a command and control approach in some individual States, and that,
therefore, this would be the best approach for Federal regulations as long as
they are based on an accurate understanding of the industry.  The participants
stressed that EPA emission reduction targets for the various product
categories must be based on sound emission and use-pattern data.  The
participants suggested that  industry and States should be  involved  in
preliminary research to help determine what the appropriate emissions
reduction targets should be.

3.2.3     Definition of VOC Content

     There was an overwhelming  consensus among the work group participants
that the  EPA's current definition of VOC provides little leeway  for
reformulation efforts, and must be narrowed down for  the household  products
industry.  Participants encouraged the  EPA to  include  photochemical  reactivity
in their  definition  of "VOC"  and  to share the  results  of some recent studies
on reactivity of  various  VOC's.   Considerable  discussion addressed  a test
method  for determining volatility or vapor pressure  of specific  VOC's  as  they
occur  as  components  in consumer products.  The following are  three  basic
questions that the  participants feel the  EPA  should  address  in  defining "VOC"
for  regulatory purposes:

          What compounds  should be covered by a  definition for  VOC  for this
           industry?
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          How are the various products containing VOC's used and disposed of,
          and how does this affect the amount of VOC's actually reaching the
          atmosphere?
          Can the VOC's be ranked based on photochemical  reactivity;  and can
          photochemical reactivity be taken into account in order to  assess
          the VOC's impact on ozone formation?
3.2.4     Recommendations for Additional  Study

     The Work Group participants suggested that the EPA, working with
industry, conduct additional research to accurately quantify emissions from
consumer products, particularly in light of results obtained from the SDA
study.  Product usage practices and the ultimate fate of product organics in
the environment should be considered.  The participants felt that a two year
study period would be adequate for quantifying consumer product VOC content,
but not for defining and evaluating the impacts of the different products on
ozone formation.  The participants encouraged the EPA to conduct additional
studies after the two-year period to establish the amount of VOC actually
emitted to the atmosphere before deciding on the most appropriate regulatory
strategy.

     Following preliminary evaluation of the industry, the EPA should work
with  industry and States to establish an approximate reduction target for VOC
emissions from consumer products.

3.2.5     Consistency with Federal Insecticide. Fungicide, and Rodenticide Act
          (FIFRA)

      It was the opinion of the Work Group that products regulated by  FIFRA
should be given special consideration under VOC regulations.  The EPA should
coordinate with other regulatory agencies and other offices within  EPA,  such
as the Office of  Pesticides and the Office of Toxic Substances,  in  determining
appropriate time  frames and regulatory requirements for developing  new
products.  Registration of new products, product safety testing, and
compliance with existing FIFRA requirements must be considered when

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establishing time frames for compliance with a VOC regulation.   This becomes
especially important when regulating products whose active ingredients are
VOC's.

3.2.6     r.nnsi«;tencv with Future Regulations

     Industry also encouraged the EPA to try to anticipate other air quality
issues that will need to be addressed in the future.  There was concern among
the participants that compounds identified now as suitable alternatives may be
cause for concern later with regard to  indoor air quality, air toxics,
carcinogens, or global warming.  Industry needs to avoid spending millions of
dollars to reformulate products only to find that their new products are
contributing to new air quality problems.

3.2.7     Industry and State Roles  in the Reaulatorv Process

     Both the household care products  industry and  States would like to
continue to advise the EPA  through  workshops  like  this one throughout  the
study and regulatory  process.   It may be necessary  to  involve  more  technical
people to address the more  technical  issues.  Participants would  like  to
continue to act  in an advisory role to  the  EPA.

      Participants also  suggested that  the  EPA should work closely with the
trade associations  to gather information  and industry  input.   The trade
associations  can  collect  necessary  data for the  EPA while  protecting
proprietary information;  or they can direct the  EPA to appropriate  sources for
 information gathering.   A close working relationship with  the  trade
 associations  is essential for continued industry-government  coordination.

 3.3  AUTOMOTIVE PRODUCTS

 3.3.1     NPPH fnr a National  Inventory

      The Automotive  Products Work Group asserted that the primary  issue  for
 regulatory development is the need for a complete and reliable VOC emissions
 inventory for the consumer products source category.   The group recommended

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development of a protocol for gathering VOC emissions data.  The protocol
should include use of existing databases such as SARA-313, NIOSH, MSDS, and
State agency data bases, as well as existing industry data such as market
surveys, product formulation, and industry-sponsored studies.  Industry would
be willing to cooperate and contribute to an inventory if they were included
in development of the inventory protocol.

     The inventory should be species specific, or at least specific to solvent
use categories, and would establish a baseline against which to measure future
emission reductions.  Furthermore, it must be determined whether product VOC
content or VOC emissions are to be measured.  It was the group's feeling that
the two years allotted by Congress for an industry study are not enough; four
years, as suggested by Dr. Ralph Engel, would be more appropriate.

3.3.2     Prioritization of Solvents

     All of the industry representatives agreed that ignoring relative
volatility or photochemical reactivity  is not a realistic  or productive
approach to regulation.  Two types of ranking or categorizing of products were
discussed: first, participants  felt that solvents or groups of products  should
be ranked according to their propensity to emit ozone forming VOC's.   Certain
products could then be targeted as primary contributors to ozone formation due
to their high ozone forming potential.  Secondly, products that  cannot be
formulated without substantial  amounts of VOC should be identified, and  the
emissions  involved quantified.  The industry representatives feel  that certain
products, such as antifreeze or carburetor cleaner, cannot be effective
without solvent content, and must be exempt from regulation or at  least
treated individually.

      Elasticity of consumer demand must  also be determined for classes of
products.  There  are certain consumer products whose contents and/or  cost  can
readily be altered  in order to  meet ozone compliance, but  other  products meet
essential consumer needs and cannot be  reformulated.  For  example,  VOC's in
hairspray would be considered more expendable than those  in  carburetor
cleaners or antifreeze.
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     The EPA representatives responded to these points by reiterating that a
market approach to regulation is intended to address just such issues,
allowing industry to respond to regulations in the most effective way.  The
EPA cannot possibly be as familiar with the intricacies of the market as are
those involved in the industry.  Approaches such as fees and allotments set
limits within which the industry can apply their more complete understanding
of the market in complying with regulations.

     In any case, the industry representatives stated that, in order to know
where to focus their current R&D efforts, they need an indication of the
degree of VOC reduction planned by the EPA and the time frame for coming into
compliance.
3.3.3     Industry Response to Regulatory Alternatives

     The potential for regulation to inhibit  innovation and industry growth
was also of concern to the  industry participants.  Allotments can create
barriers to entry if larger companies monopolize available allotments.  If
allotments are distributed  according to current production, the  industry may
become locked into a market share status quo.  Innovation can also be
discouraged if a particular formulator develops an  improved product using less
(or no) VOC's, but is made  to release the formulation to the entire industry.
Additionally, unless there  is a guarantee of  stable regulations,  industry will
be hesitant to commit money to developing low VOC products that  may eventually
come under regulation or be banned.  Innovation  in  a  regulated  industry is
assumed to be a  high-risk endeavor.  According to industry representatives, a
satisfactory regulatory strategy will need  to consider this risk and  provide
incentives for  innovation and  industry growth.

     In response to this concern, the EPA and some  industry representatives
pointed out that there  is already a growing market  for environmentally  sound
products.  Rather than  inhibit growth, regulation could  act as  a stimulator
for  entirely new markets and new product lines.

     Industry representatives  further pointed out that there  is little  room
left for consumer product VOC  content reduction.   It  was  emphasized that  VOC's
are  an expensive ingredient, and that use of  VOC's  in consumer  products has

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already been minimized in order to optimize profits.  Reformulation,
consequently, does not seem to be a promising alternative in many cases.
Additionally, it was pointed out that formulating products with less VOC may
create less effective products.  Consumers may respond by simply using twice
as much of the product, and thereby negating any gains in emission reductions,
or they may stop buying the product altogether, eliminating a market.

3.3.4     Conclusions

     In conclusion, all participants agreed that this exchange was productive
and should be continued.  Several industry representatives would like to
remain in communication with each other and with the EPA representatives.  The
EPA representatives also emphasized the need for this continued exchange and
gave names and phone numbers of appropriate Agency  personnel to be contacted
for information and discussion.  Industry participants showed an interest  in
the regulatory development procedure, and how to be  involved in the  public
comment period.  This  information was also given by  the EPA representatives.

     Once again, the industry  representatives stressed the need for  a reliable
VOC inventory, their need to anticipate regulatory  actions and subsequent
market reactions,  and  their conviction that relative ozone formation potential
of different solvents  must be  considered  in regulating consumer product  VOC
emissions.

3.4  HOUSEHOLD PESTICIDES

3.4.1     Current  Research Activities

      Industry participants described a project  that the Chemical Specialties
Manufacturing Association  (CSMA)  is undertaking in  conjunction with  NYDEC.
The Court ordered  NYDEC  to regulate VOC's  and  approved a  four year  study to
determine how to  regulate  VOC  emissions from consumer air fresheners,
disinfectants and  insecticides.  An  industry consortium,  through CSMA,  is
developing  a protocol  to identify VOC control  strategies  which maintain
product efficacy,  while  reducing non-active  ingredient VOC emissions into  the
ambient air to the maximum extent feasible.  The study  is intended  to:

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1) determine technologically-feasible ways to reduce VOC's (through
reformulation, total  alteration,  changes in pressurants for aerosols, for
example) and 2) evaluate control-mechanism impacts (including economic and
societal impacts).  For the purposes of this study, VOC was defined by a
specific vapor pressure.  This is a court-ordered process, and CSMA will
report the results of their evaluation to the Court through NYDEC.  CSMA
expects to work with several other regions on similar studies.

3.4.2     Recommendations for Additional Research

     The work group felt that a national study similar to the New Y-ork study
should be initiated.  The participants agreed that one study for the entire
country would be more helpful than regional or statewide studies whose results
may or may not be transferable to the national scale.  In addition, compiling
data on a national scale would preclude the need to prepare distribution
estimates.  Though limited by confidentiality, the necessary formulation and
annual production data for household pesticides are already housed with the
EPA's Office of Pesticide Programs (OPP).  The CSMA member companies and other
members of the pesticide industry expressed a desire to work with the EPA  in
designing and  implementing a study of this nature,  in order to develop
credible emissions data.  The work group felt that this type of study will
require at least  four years to complete, considering the fact that the  New
York  study will evaluate only two product  categories in four years and  will
include only  one  percent of the total pesticide products used in  the U.S.

3.4.3     Need for Federal  Preemption over State  Regulations

      The overwhelming feeling of  the work  group was  that  the  Federal
government must take the lead  in  setting  reduction targets for VOC levels  in
consumer products.  This feeling  stems  from the concern that  existing and
anticipated State regulations may not be  consistent  with  one  another.   It  was
felt  that the EPA could best  help industry by  impressing  upon legislators  that
Federal preemption over State regulations  is  necessary  in  the Clean  Air Act
Amendments with special State needs  addressed when proven  necessary.   Industry
representatives stressed that their  ongoing research efforts  are  hampered  by
the  lack of a fixed reduction target  and  inconsistent  State  requirements.

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Expediting the Federal  government's leadership role in this process may also
eliminate the initiation of other independent State efforts.

3.4.4     Consistency with FIFRA Regulations/Internal  EPA Coordination

     The OPP registration process required by FIFRA includes toxicity testing,
labelling restrictions, and formulation and annual production reporting.   Not
only will it be difficult for industry to develop and conduct the appropriate
toxicity testing for major product reformulations, but the approval process
also will be very difficult for OPP to administer in a timely manner without
increased resources.  An example was given to illustrate the conflicting
program requirements: methylene chloride cannot be approved for use under
FIFRA, but it would be exempt from consideration as a VOC.  The work group
felt that the EPA must begin immediate coordination among the affected program
offices.  In addition to FIFRA, the EPA must also coordinate with the
greenhouse gas issue concerning CFC's; the Toxic Substances Control Act (TSCA)
and the Resource Conversation and Recovery Act (RCRA) requirements may also
come  into play.  The work group cautioned that the EPA must be aware that
restrictions imposed by FIFRA are unique to the pesticides product category,
and that the OPP approval process will become significantly more complex when
VOC regulations are promulgated.  It must also be kept in mind that the
setting of strict deadlines will be unrealistic unless the OPP approval
process can be expedited.  In general, industry asks that the EPA act
consistently across all program offices.

3.4.5     Regulation Must Not Discourage Innovation

      The work group's discussion concerning  innovation and  flexibility focused
on ways to avoid discouraging  innovation with regulation.   Towards that end,
the work group reiterated that Federal regulation should  preempt State
activities and provide nationally consistent regulations.   In particular,  the
work  group asked that the EPA define a standard test method for measuring  VOC
emissions and better define "VOC", with reactivity taken  into consideration.

      Industry also  asked that the EPA consider focusing on  a subset of VOC's
whose elimination will have the greatest environmental impact.  The avoidance

                                     3-13

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of outright solvent bans is also important in assisting technological
development.  A "miracle solvent" is not likely to be found, and response to
regulation will vary from product to product. It is important for the EPA to
understand that for some pesticide products,  VOC's cannot be completely
eliminated.

     Additionally, the EPA could avoid discouraging innovation by including an
efficacy protection clause in any forthcoming regulation.  The EPA should not
promote less efficient formulations simply to control VOC; the end result may
be that consumers are forced to use more of the product to achieve the desired
result, thus emitting the same amount of VOC.  Industry is further hesitant to
market a low VOC product before legislation  is enacted, because if an across-
the-board VOC reduction is promulgated, those who have already reduced product
VOCs will be penalized.  A baseline needs to be established now, or there will
continue to be no incentive to market low VOC products.

3.4.6     Effect of Regulations on Markets

     The work group expressed the concern that efficacy and cost be considered
in regulatory development.  Also, the costs  to consumers must remain
reasonable.  As discussed above, consumers will not be satisfied if product
efficacy is decreased and more product  is required.  (An efficacy protection
clause is  included  in the New York regulation.)  This  issue will also affect
OPP considerations  since consumer exposure to a product may be  increased
because of decreased efficacy.

     Industry  representatives also stated that competition  for market share
will drive technology,  and that  the companies to first market an
"environmentally  safe"  product will be  at an advantage.  The fear was
expressed,  however, that larger  corporations will  be at  an  economic  advantage
due to their greater available R&D resources.  Participants  suggested that
forcing technology  may  actually  mean  that some companies will be "regulated
out of business."
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3.4.7     Regulatory Burden on Formulators

     The possibility that the EPA will  initiate a program to force technology
was discussed in the work group,  and it was stated that the segment of
industry most affected by this type of program would have the least control
over the development of new technology.  The pesticide industry is a very
small part of the solvent suppliers' business; thus, the supplier would have
no financial interest in taking on the responsibility or liability of
developing substitutes for pesticides.   Similarly, the pesticide formulators
are  in no position to develop alternative delivery systems for their aerosol
products.  In addition, the active ingredients in household pesticides have
been developed for agricultural uses, and then formulated for consumer use.
Therefore, only 10% by volume of the active ingredient produced are used in
the household pesticide products.  Because of the low volume of consumer
pesticides, the producers of the active ingredients for pesticides will have
little or no incentive to develop new active  ingredients for use  in non-VOC
systems of regulated consumer pesticides.  Thus, the burden will  fall on the
household pesticide formulators to develop both new formulations  and delivery
systems.

3.5  ADHESIVES AND SEALANTS
3.5.1     Recommendations for Additional Research

     The  industry participants  in the Adhesives and Sealants Work Group
generally questioned whether regulation of VOC emissions from  adhesive and
sealant products is warranted on the basis of their contribution to ozone
formation.  Therefore, they agreed that the first  step to be taken  in
considering regulatory strategies for VOC emissions from adhesive and sealant
products  is to conduct a thorough study of these products,  including analyses
of:

          The formulation of adhesive and sealant  products;
          The quantity and types of VOC's emitted  from different products;
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          The effect of different application and product delivery systems on
          VOC emissions; and
          The impact of specific VOC's on ozone formation.

One goal  of this study should be to develop information that can be used to
compare products on the basis of the quantity of VOC's emitted per household
over a year's time.  This study would then be used as the basis for decisions
by the EPA on which products, if any, warrant regulation.  Products that do
not have high VOC contents should be excluded from regulation.  Similarly,
products emitting VOC's that do not contribute significantly to ozone
formation should be excluded from regulation.

3.5.2     Definition of VOC Content

     Participants  in the work group were concerned that "VOC"  is not
adequately defined, or that the definitions developed by  the  EPA, the American
Society for Testing and Materials  (ASTM), and various States  are conflicting,
and that equations for calculating VOC content differ.  They  recommended  that
the EPA define  "VOC" before developing control strategies,  and  that  individual
industries and  trade associations  participate  in  the development of  this
definition.   It was also recommended  that the  EPA and  industry  define the
equations for calculating VOC content.   A related issue  raised  in the
discussions was the need to develop  test methods  for detecting  and measuring
VOC emissions from adhesive  and  sealant  products.  These  test methods should
take  into account  the  methods of  applying the  product, the  volatility and
reactivity of the  VOC's  in  the  product,  and  the  contribution  of those VOCs to
ozone  generation.

3.5.3     Diversity of Adhesives  and Sealant Industry

      The  participants  agreed that any regulatory program for adhesives  and
 sealants  should address specific products,  rather than general categories of
 products.  The  most important distinction cited by  the group is between
 products  that have a high  solvent content and those  that have been formulated
 to contain relatively small  amounts of VOC.   An across-the-board emission
 reduction requirement for  all  products would disadvantage low-solvent

                                      3-16

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products, which already have minimal  VOC emissions, while possibly achieving
inadequate VOC reductions from high solvent content products.  Distinguishing
low-solvent from high-solvent content products would also recognize that
companies are likely to reduce the cost of a product by reducing the solvent
content whenever possible.

     The work group members also urged that the "social value" (i.e., benefit
to human welfare) of a product should be a basis for distinction.  The solvent
content of products that couple a higher social value with a higher VOC
content should not be required to be reduced if the effectiveness of the
product would be reduced.

     A final distinction urged would be based on the opportunity for VOC
emissions reduction presented by certain products.  Those products that can be
readily controlled could be regulated more stringently than those that are
difficult to control.  For instance, the method of application of a product
might be changed in some instances to reduce emissions,  in lieu of or  in
combination with a reformulation of the product.

3.5.4     Need for Federal Preemption over State Regulations

     The work group members said that it is important to their industry that
emission standards for consumer products be consistent nation-wide, and that
the most effective way of achieving this goal  is for Federal standards to
preempt State and local  standards.  Consistent standards will prevent
companies from having to formulate, test, and market their products
differently depending on where they will be marketed.  Nationally consistent
requirements will also benefit the end user by controlling compliance  costs.

3.5.5     Economic Incentives

     The industry participants in the work group felt that economic  incentives
for reducing emissions (e.g., excess emission  fees) should be set at a level
sufficient to cause companies to reformulate or redesign their products.  They
expressed a concern that some companies may be under market  pressure to pay an
emission fee, rather than reduce emissions.  By doing so, they would avoid the

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high costs of researching and developing new product formulations or delivery
systems, and maintain consumer acceptance of the established product.

3.5.6     Effect nf Regulations on Markets

     The work group members pointed out that requiring controls on VOC
emissions from adhesive and sealant products will have a significant effect on
the market for those products.  Reformulation of a product to eliminate
organic solvents may result in reduced consumer satisfaction with the
reformulated product and in lower sales of that product.  Not only  is this
true for the general population of consumers, but it is particularly true for
industries and trades that have product specifications that call for organic
solvent-based formulations.  Reformulation may also result  in  increased rates
of application of a product that consumers perceive to be less effective than
the original, which would adversely affect the emission reductions  sought
through the  regulation.

3.5.7     Regulatory Burden on Formulators

     The  participants  in the work group  agreed  that  the focus  of any
regulation  limiting  VOC  emissions from adhesive  and  sealant products should  be
on  the  product  formulator.   Formulation  is  the  point  at which  the final
product is  manufactured  and  the mixture  of  solvent-containing  materials
decided upon.   The  formulators are  also  relatively  few in number,  compared to
retailers or consumers,  and  consequently are the easiest  point in the market
to  regulate.  In addition  to regulating  formulators,  any  standards for
emissions from adhesive  and  sealant products should also  address imported
products by making  importers responsible for the compliance of the products
they introduce in the  market in  this country.

 3.5.8     Evaluation of  Regulatory Approaches

      3.5.8.1   Command and control--

      The industry participants agreed that a regulation limiting the organic
 solvent content of a product or products would be preferable to a  regulation

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requiring an across-the-board reduction in VOC emissions from all  products.
Limiting the organic solvent content of a product or products would benefit
those products and manufacturers that have already invested in reformulation
to reduce emissions, while requiring manufacturers of high solvent content
products to take action to comply with the regulation.  Requiring uniform VOC
emission reductions would benefit high-solvent products, which have a greater
opportunity for reducing emissions through reformulation.  Low-solvent
products, on the other hand, already have low emissions and it would be
difficult to reduce them further.

     3.5.8.2   Bubble regulations--

     The industry representatives said that regulation that allowed a company
to allocate the solvent content or VOC emission reductions among the company's
various products would result in the most cost effective controls being
applied, and would give the company the option of retaining specific high-
value, high-solvent products by achieving reductions  in emissions from other
products.  On the other hand, regulations controlling VOC emissions from
specific adhesive and sealant products, rather than categories of products,
would have the smallest effect on competition between products, since all
products would be treated similarly.  Further, product specific regulations
would simplify recordkeeping and enforcement of the regulation.  In the
absence of a bubble, compliance could be determined by testing any single
product; with a bubble, compliance could only be determined by testing all of
a company's products.

     3.5.8.3   Emission fee system--

     Inclusion of an excess emission fee system as part of a  VOC regulation
for adhesive and sealant products would benefit the  industry  by providing
companies with a way to continue producing products that do not meet an
emission or solvent content limit.  This could allow  the company to keep
marketing the product while attempting to reformulate or redesign  it to reduce
emissions.  It could also allow companies to continue producing specified
high-solvent products if the benefits of those products outweighed the cost of
the emission fee.   The problems with an emission fee  system are that it may

                                     3-19

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not achieve the emission reductions desired (since companies can pay the fee
in lieu of reducing emissions) and setting the level  of the fee would be
complex and difficult.  The fee would have to be proportional to market size
in order to have an equitable effect, since a high fee would have a more
significant impact on a small company than on a large one.  The fee could be
applied on a per unit of product basis to reflect company size and resources.
For the EPA to set the fee at a level that would be equitable, reduce
emissions, and separate the high-value products from the low-value products
would require industry input to the fee-setting process.

     3.5.8.4   Allotment system--

     The work group reacted negatively to basing regulations on an allotment
system, because this  system would allow a company to approach a monopoly  in  an
industry by controlling allotments and would limit the entry of new companies
into the  industry.  An allotment system would also reward companies with  the
highest historical emissions by providing them more allotments, putting at  a
disadvantage companies that have made efforts to reduce emissions. The only
positive  aspect of an allotment system recognized by the work group was that
it would  alleviate the problem of  setting an emissions fee  by letting the
market for allotments set  the price.

3.6  AEROSOL PAINTS

3.6.1      Diversity  of Aerosol Paint  Industry

     In the Aerosol  Paint  Work Group's  initial  discussion,  industry
representatives agreed  that  the  aerosol  paint  industry is  too big and  diverse
to be  regulated as one  entity.   Each  area has  unique  requirements and
limitations.   The work  group agreed  that the regulatory process would  require
a combination  of  approaches  -  command and control,  averaging,  and economic
 incentives -  tailored for  the specific  product categories within the aerosol
paint  industry.
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3.6.2     Definition of VQC Content

     Industry representatives felt that the California definition of "weight
VOC per gallon of product minus water" was not applicable to the aerosol paint
industry, since their product is packaged in pressurized containers where the
VOC used as the propellant is lighter than that used as the solvent.
Therefore, removing the propellant would increase the weight VOC/volume
coating.  It was suggested that a more relevant definition would include a
ratio of weight VOC to weight solids.  Industry representatives felt that some
reduction in VOC emissions would be possible by substituting water for solvent
without changing the solids content.

3.6.3     VOC Inventory for Aerosol Paint Industry

     Industry representatives felt very strongly that the aerosol paint
industry needs a baseline emission inventory against which to measure progress
in emission reduction and market acceptance of new products.

     It was suggested that industry work on its own to produce an accurate
inventory.  However, there was concern that the confidentiality of information
would make such an approach impossible.  No real solution was found to the
inventory issue, but representatives from the EPA felt that inability to
develop of an inventory would not preclude development of a regulation.

3.6.4     Industry's Role in the Regulatory Process

     The aerosol paint industry has been sensitized to the need for change.
The industry representatives agree that it is in their best interest to
participate actively in the regulatory process.  The work group agreed that
industry should provide information to the regulators on the specific needs of
the aerosol  paint industry.  They felt that one of the first steps should be
the formation of an industry task force to further discuss the issues raised
at the symposium and to develop a model plan for reducing VOC emissions.
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3.6.5     Recommendations for Additional Research

     The aerosol paint industry was initially motivated to reduce their
products' VOC emissions by promulgation of the California regulation.
Research activities are still in their infancy and include a variety of
approaches to VOC emission reduction.   Specific research projects were not
discussed because this information is considered confidential.  The work group
members agreed that any response to regulation should address environmental
responsibility for products "from cradle to grave", since other regulations
(e.g., air toxics, workplace hazards,  waste disposal) would also apply to
these products.

     There was some discussion of promoting the recycling of aerosol paint
cans and recovering the VOC.  There is some feeling that, since these cans are
not completely emptied during use, they are a source of VOC emissions as they
disintegrate in landfills.  However, industry participants felt certain that
aerosol products typically do get used in their entirety and that recycling is
not a valid issue.
                                     3-22

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                          4.0  AGENDA AND ATTENDEES
jkb.007
                                        4-1

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                SYMPOSIUM ON REGULATORY APPROACHES
                     FOR REDUCING VOC EMISSIONS
                 FROM THE USE OF CONSUMER PRODUCTS

                              Tuesday
                         Noverter 14, 1989
                         Regulatory  Emphasis
       Moderator
 8:00  Registration

 8:30  Welcome
 8:35  Introduction/Objectives
       Overview of VOC  Regulatory Programs
       and the Nonattainment Problem

 9:15  Status of the Clean  Air  Act Amendments
 9:45  Break

10:15  Possible EPA Control  Strategies for
       Consumer Products
10:45  Industry's View of Regulating Consumer
       Products
11:15  Use of Market-based Approaches to
       Reduce VOC Emissions from the Use of
       Consumer Products

11:45  Distribution of Questions to Product
       Category Work Groups

12:00  Lunch

 1:00  Concurrent Product Category Work Groups

 2:30  Break

 3:00  Concurrent Product Category Work Groups

 5:00  Adjourn
John Calcagni, Director
Air Quality Management
Division, Office of
Air Quality Planning and
Standards (OAQPS)
John O'Connor
Deputy Director, OAQPS

John Calcagni, Director
Air Quality Management
Division, OAQPS

Bill Harnett
Emission Standards
Division, OAQPS
Brock Nicholson
Air Quality Management
Division, OAQPS

Ralph Engel
Chemical Specialties
Manufacturers Assoc.

John Chamberlin
Office of Pol icy,
Planning, and Evaluation

John Calcagni
                                 4-2

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                             Wednesday
                         November 15, 1989

                         Technical  Emphasis
       Moderator
 8:00  California Regulatory Activities
 8:30  The Functions of VOC's  in Consumer
       Products

 9:00  New York Regulatory Activities
 9:30  Reformulation and Safety Testing
       Their Timing and Costs
10:00  Break

10:30  New Jersey Regulatory Activities



11:00  The Socioeconomics of Regulating
       Consumer Products

11:30  EPA Research Toward Reduction of
       VOC Emissions from Consumer Products

12:00  Lunch

 1:00  Concurrent Product Category Work Groups

 2:30  Break

 3:00  Work Group Summary Presentations

 4:45  Adjourn
Jim Weigold
Deputy Director
Emission Standards
Division, OAQPS

Dean Simeroth
California Air Resources
Board

Ike Emery, Vice Pres.
Helene Curtis

Ted Davis
New York Dept. of
Environmental
Conservation

Theodore Wernick
Gillette Medical
Evaluation Laboratories
Sandra Chen, New Jersey
Dept. of  Environmental
Protection

Edward Heiden
Heiden Associates,  Inc.

Mike  Kosusko,  Office  of
Research  and Development
 Work Group Co-chairs
                                   4-3

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                         PRODUCT CATEGORY WORK GROUPS
Personal Care Products
Oean Simeroth
Kevin Loftus
Harry McCain
C. Kelly Burton
Leonard Drell
Robert Jamieson
Wallace Coscarelli
John Lazar
Ike Emery
Cynthia Greene
Al Vervaert

Household Care Products
Ted Davis
Richard Bednarz
Richard Sedlak
Robert Koenig
Armin Globes
Ramon Llenado
William Wilderson
John Ferguson
Eileen Moyer
Lorraine Lillis
Matthew McCarthy
James Crowder

Automotive Products
John Chamber!in
Alan Rogers
Graham Reed
Jerone Newberry
Jim Namnath
Norwin Wolff
Laurence Midtbo
Robert Hamilton
Clayton Smith
Bill Johnson

Household Pesticides
John Silvasi
Dean O'Hair
James Case
Steven Rogosheske
Bernard Weinstein
Jay Price
John Domanski
Kerry Leifer
John Ungvarsky
CARB
Gillette Corp.
Aeropres Corp
S.C. Johnson
Demert & Dougherty
Procter & Gamble
American Cyanamid - Shulton
Carter-Wallace Corp
Helene Curtis
EPA-Region 1
EPA/OAQPS
Govt Co-chair
Ind  Co-chair
NYDEC
Amway Corp
SDA
Procter & Gamble
S.C. Johnson
Lehn & Fink
Scott's Liquid Gold Inc.
The Drackett Co.
Airwick Industries
CPL
EPA-Region 2
EPA/OAQPS
Govt Co-chair
Ind  Co-chair
EPA/OPPE
First Brands Corp
Blue Coral
Pennzoil
Chevron Chemical
Interpolymer Corp
IKI Mfg Co
Amway Corp
TACB
EPA/OAQPS
Govt Co-chair
Ind  Co-chair
EPA/OAQPS
Chevron Chemical
S.C. Johnson
McLaughlin, Gormley,  King
Boyle-Midway
Dowbrands
Lehn & Fink
EPA/OPP
EPA-Region 9
Govt Co-chair
Ind  Co-chair
                                       4-4

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Adheslves and Sealants
Brock Nicholson
Dale Oosser
Michael Pezzuto, Jr.
Gerry Klosowski
Ray Thimineur
Kathy Hoi en
Tom Tupa
Greg Walsh
Steve Rosenthal
Wade Ponder

Aerosol Sprav Paints
Jim Berry
Robert Graham
Jim O'Connor
Karl Schultz
Steve Chalmers
Gus Leep
Edward Majkrzak
Roy Mallarnee
Gary long
Vickie Boothe
EPA/OAQPS
3M
ICI Resins U.S.
Dow Corning
General Electric
Loctite Corp
Loctite Corp
Darworth Co
EPA-Region 5
EPA/AEERL
Govt Co-chair
Ind  Co-chair
EPA/OAQPS
Sprayon Products
Rustoleum
Dupont
Guardsman Prod., Inc.
Seymour of Sycamore, Inc.
General Paint and Chemical
Plastikote Co.
Borden
EPA-Region 4
Govt Co-chair
Ind Co-chair
                                     4-5

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4.3  LIST OF ATTENDEES

MICHAEL ADAMS
FOOD & DRUG ADMINISTRATION
200 C STREET - HFF-415
WASHINGTON, DC  20204
(202)472-5680

JIM ALBANESE
DIRECTOR, RESEARCH & DEVELOPMENT
SPECTRUM GROUP
8494 CHOPIN INDUSTRIAL DR.
ST.LOUIS, MO 63114
(314)427-4886

ALLEN C. BASALA
CHIEF, ECONOMIC ANALYSIS SECTION
U.S.EPA/OAQPS
MD-12
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5622

REBECCA BATTYE
PROJECT MANAGER
E.H. PECHAN & ASSOCIATES
3514 UNIVERSITY DRIVE
DURHAM, N.C. 27707
(919)493-3144

DR. RICHARD BEDNARZ
DIRECTOR, RESEARCH SERVICES
AMWAY
7575 E. FULTON RD.
ADA, MI 49301
(616)676-5050

JAMES C. BERRY
CHIEF, CHEMICAL APPLICATION  SECTION
U.S. EPA/OAQPS/ESD
MD-13
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5605

RAY BIAS
EASTERN REGION SALES MANAGER
PHILLIPS 66
203 HUNTING RIDGE RD.
ROANOKE RAPIDS, NC 27870
(919)537-3817
                                      4-6

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VICKIE BOOTHE
ENVIRONMENTAL ENGINEER
U.S.EPA/REGION 4
345 COURTLAND ST.
ATLANTA, GA 30365
(404)347-2864

EARL K. BORMAN
LEHN AND FINK/D-CON
225 SUMMIT AVE.
MONTVALE, NO 07645
(201)573-5785

MARSHA BRANSCOME
ENVIR. ANALYST, CENTER FOR ENVIR. SYSTEM
REASEARCH TRIANGLE INSTITUTE
P.O. BOX 12194
RESEARCH TRIANGLE PARK, NC 27709-2194
(919)541-6726

NANCY S. BRYSON
ATTORNEY/COUNSEL
LEHN & FINK PRODUCTS GROUP
1001 PENNSYLVANIA AV, N.W.
WASHINGTON, D.C. 20004-2505
(202)624-2529

FRANK BUNYARD
ENVIRONMENTAL  ENGINEER
U.S.EPA/OAQPS/AMBIENT STANDARDS  BRANCH
MD-12
RESEARCH TRIANGLE PARK, NIC 27711
(919)541-5297

KELLY  BURTON
SENIOR  SECTION MANAGER
S.C.  JOHNSON  & SON,  INC.
1525  HOWE  ST.  (M.S.  #138)
RACINE,  WI  53403
(414)631-2402

JOHN  CALCAGNI
DIRECTOR,  AIR QUALITY MANAGEMENT DIVISION
U.S.EPA/OAQPS
MD-15
RESEARCH TRIANGLE PARK,  NC  27711
 (919)541-5621

RICHARD J.  CARTER
DIRECTOR OF ADVER.,  TOXIC.,  AND REG.  AFF
BOYLE MIDWAY HOUSEHOLD PRODUCTS, INC.
 SOUTH AVENUE & HALE STREET
CRANFORD,  N.J. 07016
                                       4-7

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JAMES CASE
SECTION MANAGER
S.C. JOHNSON WAX
1525 HOWE STREET
MS 167
RACINE, WI 53406
(414)631-2630

STEVE CHALMERS
VICE-PRESIDENT
GUARDSMAN PRODUCTS, INC.
3033 ORCHARD VISTA DR.
GRAND RAPIDS, MI 49501
(616)957-2600

JOHN CHAMBERLIN
U.S.EPA/OFFICE OF POLICY ANALYSIS
(PM-221)
401 M ST, S.W.
WASHINGTON, D.C. 20460
(202)382-2762

SANDRA CHEN
SUPERVISOR OF RULE MAKING
NEW JERSEY DEPT. OF ENVIRONMENTAL PROTECTION
CN-027
401 E. STATE STREET, 2ND FLOOR
TRENTON, NJ 08625
(609)633-1122

MARTIN CIFUENTES
AUTOMOTIVE CARE REPRESENTATIVE
DOW CORNING
2200 W. SALZBURG RD.
MIDLAND, MI 48686-0994
(517)496-5725

DR. ARMIN L. GLOBES
SECTION MANAGER
S.C. JOHNSON & SON, INC.
1525 HOWE ST.
RACINE, WI 53403
(414)631-2351

DAVID COLE
ENVIRONMENTAL SCIENTIST
U.S.EPA/OAQPS
MD-15
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5565
                                      4-8

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DR. W. COSCARELLI
DIRECTOR, REGULATORY AND ENVIRONMENTAL A
AMERICAN CYANAMID COMPANY
697 ROUTE 46
CLIFTON, NJ 07015
(201)340-6150

TED CREEKMORE
ENVIRONEMNTAL ENGINEER
U.S. EPA
MD-15
RESEARCH TRIANGLE PARK, N.C. 27711
(919)541-5699

JOHN CRENSHAW
PROGRAM MANAGER
RADIAN CORPORATION
P.O.BOX 13000
RESEARCH TRIANGLE PARK, MC 27709
(919)541-9100

JAMES CROWDER
CHIEF,  INDUSTRIAL STUDIES BRANCH
U.S.EPA/OAQPS/ESD
MD-13
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5596

EDWARD  W. DAVIS
ASSISTANT DIRECTOR,  DIVISION OF AIR RESOURCES
NEW YORK STATE DEPT.  OF ENVIR. CONSERVAT
50 WOLF RD., RM.128
ALBANY, NY  12233-3250
(518)457-7231

JOHN  DOMANSKI
DIRECTOR,  PRODUCT SAFETY
LEHN  &  FINK
225 SUMMIT  AVE.
MONTVALE,  NJ 07645
(201)573-5785

DALE  M.  DOSSER
DIVISION VICE PRESIDENT
3-M COMPANY, ADHESIVES,  COATINGS  & SEALE
BLDG  223-IN-07,  3-M CENTER
ST.PAUL,  MN 55144
 (612)733-6675
                                       4-9

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JAMES E. DOWNES
MANAGER OF PRODUCT SAFETY
MONSANTO CHEMICAL CO.
800 N. LINDBERGH
ST. LOUIS, MO 63167
(314)694-2918

LEONARD B. DRELL
DEMERT & DOUGHERTY
814 COMMERCE DR
STE. 310
OAK BROOK, IL 60521-1964
(312)271-6000

ELLEN DUCEY
ENVIRONMENTAL ENGINEER
U.S.EPA/OAQPS/ESD
MD-13
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5408

IKE EMERY
CORPORATE DIRECTOR OF RESEARCH & DEVELOP
HELENE CURTIS INC.
4401 W. NORTH AVE.
CHICAGO,  IL 60639
(312)661-0222

GERALD  EMISON
U.S.EPA/OAQPS
MD-10
RESEARCH  TRIANGLE PARK, NC 27711
(919)541-5616

DR. RALPH ENGEL
PRESIDENT
CHEMICAL  SPECIALTIES MANUFACTURERS  ASSOCIATION
1913  EYE  STREET,  NW
WASHINGTON, DC  20006
(202)872-8110

JACK  FARMER
DIRECTOR, EMISSION STANDARDS DIVISION
U.S.EPA/OAQPS/ESD
MD-13
RESEARCH  TRIANGLE PARK,  NC  27711
(919)541-5572

DR.  JOHN  A.  FERGUSON
DIRECTOR, PRODUCT DEVELOPMENT
THE DRACKETT COMPANY
5020  SPRING  GROVE AVE.
CINCINNATI,  OH  45232
 (513)632-1439

                                      4-10

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D. DOUGLAS FRATZ
DIRECTOR OF SCIENTIFIC AFFAIRS
CHEMICAL SPECIALTIES MANUFACTURERS ASSOC
1913 EYE STREET, NW
WASHINGTON, DC 20006
(202)872-8110

BETH FRIEDMAN
SENIOR ENVIRONMENTAL SCIENTIST
MIDWEST RESEARCH INSTITUTE
401 HARRISON OAKS BLVD
STE.350
CARY, NC 27513
(919)467-5215

PETER G. GOULD
PRESIDENT
EXXEL CONTAINER, L.P.
33 SCHOOLHOUSE RD.
SOMERSET, NJ 07090
(201)560-3655

DR. JOYCE GRAF
STAFF CHEMIST
THE COSMETIC, TOILETRY & FRAGRANCE ASSN.
SUITE 800
1110 VERMONT AVE., NW
WASHINGTON, DC 20005
(202)331-1770

ROBERT GRAHAM
VICE-PRESIDENT & DIV. TECH DIR
SPRAYON PRODUCTS, DIV. OF SHERWIN-WILLIAMS
26300 FARGO AVENUE
BEDFORD HEIGHTS, OHIO 44146
(216)292-7410

CYNTHIA GREENE
U.S.EPA/REGION  1
JFK FEDERAL BLDG.
APS-2311
BOSTON, MA 02203
(617)565-3244

LARRY A. HACKER
ENVIRONMENTAL SCIENTIST
U.S.EPA/REGION  7
ARTX/ARBR
726 MINNESOTA AVE.
KANSAS CITY, KS 66101
(913)236-2893
                                     4-11

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ROBERT HAMILTON
SENIOR GROUP LEADER
AMWAY CORPORATION
MAIL CODE 50-2E
7575 E. FULTON RD.
ADA, MI 49355
(616)676-7697

ROBERT HANGEBRAUCK
U.S.EPA/AEERL
MD-62
RESEARCH TRIANGLE PARK, NC 27711
(919)541-4134

WILLIAM HARNETT
U.S.EPA/OAQPS/ESD
MD-13
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5253

ALTA HEFLEY
MGR., QUALITY ASSUR. & REG. AFFAIRS
MILES, INC.
7123 W. 65TH ST.
CHICAGO, IL 60638
(708)458-6100

DR. EDWARD J HEIDEN
PRESIDENT
HEIDEN ASSOC., INC.
1815 H STREET, NW, STE. 501
WASHINGTON, DC 20006
(202)463-8171

BRUCE HENNING
ENVIRONMENTAL ENGINEER
ALLIANCE TECHNOLOGIES CORPORATION
100 EUROPA DRIVE, SUITE 150
CHAPEL HILL, NC 27514
(919)968-9900

DR. JIM HILL
CHEMICAL SPECIALTIES MANUFACTURES ASSOC
1913 EYE STREET, NW
STE.1120
WASHINGTON, DC 20006
(202)872-8110

THOMAS B. HILTON
DIRECTOR, ENVIR. & TECHNICAL REGULATORY
THE DRACKETT COMPANY
5020 SPRING GROVE AVENUE
CINCINNATI, OH 45232
(513)632-1139

                                      4-12

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KATHY HOLEN
ENVIRONMENTAL HEALTH & SAFETY SPECIALIST
LOCTITE CORPORATION
187-31 CRANWOOD PARKWAY
CLEVELAND, OH 44128
(216)439-5341

ROBERT IRVINE
ENVIRONMENTAL ENGINEER
STATE OF MICHIGAN, DEPT OF NATURAL RESOU
BOX 30028
LANSING, MI 48909
(517)373-7042

M.J. IRWIN
GROUP LEADER, REGULATORY SERVICES
PROCTER & GAMBLE
5299 SPRING GROVE AVENUE
CINCINNATI, OHIO 45217
(513)627-5357

MIKE ISHIMOTO
PENNZOIL COMPANY
700 MILAM STREET
HOUSTON, TX 77252-2967

DR. NORMAN JACOBSON
SIMPSON, THATCHER, & BARTLETT
425 LEXINGTON AVE.
NEW YORK, NY 10017
(212)455-2645

R.A. JAMIESON
SECTION HEAD
PROCTOR & GAMBLE  COMPANY
11511 REED HARTMAN HIGHWAY
CINCINNATI, OH  45241
(513)626-2410

WILLIAM L. JOHNSON
ENVIRONMENTAL  ENGINEER
U.S.  EPA/OAQPS/AQMD
MD-15
RESEARCH  TRIANGLE PARK,  NC  27711
(919)541-5245

BRENDA JOHNSON
ENVIRONMENTAL  SCIENTIST
U.S.EPA/REGION 4
345 COURTLAND  ST.,  N.E.
ATLANTA,  GA  30365
(404)347-2864
                                      4-13

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PAULINE JOHNSTON
CHEMIST-INDOOR AIR DIVISION
U.S.EPA
401 M ST., SW
(MD-ANR-445)
WASHINGTON, DC 20460
(202)382-2871

JOHN R. KEENAN
SCIENTIST
ECOLAB INC.
ECOLAB CENTER
ST. PAUL, MN 55102
(612)451-5693

SUE KIMBROUGH
ENVIRONMENTAL ENGINEER
U.S.EPA/OAQPS/TSD
MD-14
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5457

JEROME KLOSOWSKI
SCIENTIST
DOW CORNING CORP.
DOW CORNING CENTER
MIDLAND, MI 48686-0994
(517)496-4244

ROBERT G.  KOENIG
MANAGER, REGULATORY AFFAIRS
PROCTER &  GAMBLE COMPANY
IVORYDALE  TECHNICAL CENTER
5299 SPRING GROVE AVENUE
CINCINNATI, OHIO 45217
(513)627-5040

STEVE  KOMAZEC
PROCESS  ENGINEER
FABERGE/CHESEBROUGH-POND'S  INC.
HWY.211  E
P.O. BOX  740
RAEFORD,  NC 28376
(919)875-4121

MICHAEL  KOSUSKO
ENVIRONMENTAL  ENGINEER
U.S. EPA/AEERL
MD 61
RESEARCH  TRIANGLE  PARK,  N.C.  27711
(919)541-2734
                                      4-14

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TOM LAHRE
ENVIRONMENTAL ENGINEER
U.S.EPA/OAQPS
MD-15
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5668

BYRON LAPIN
CLAYTON CORPORATION

JAMES A. LATTY
VICE PRESIDENT TECHNOLOGY
ARMOR ALL PRODUCTS CORPORATION
22 CORPORATE PARK
IRVINE, CA 92714
(714)553-1003

JOHN LAZAR
SENIOR RESEARCH MANAGER
CARTER-WALLACE CORP.
P.O. BOX 1001
CRANBURY, NJ 08512
(609)655-6399

GUS W. LEEP
VICE PRESIDENT, RESEARCH & DEVELOPMENT
SEYMOUR OF SYCAMORE, INC.
917 CROSBY AVE.
SYCAMORE, IL 60178
(815)895-9101

KERRY LEI PER
U.S.EPA/OFFICE OF PESTICIDES PROGRAMS
401 M STREET, SW
(H-7505C)
WASHINGTON, DC 20460
(202)557-4354

RICK LEONE
SANITARY ENGINEER
NEW YORK STATE DEC
50 WOLF RD. ALBANY, NY  12233
(518)457-7611

IRWIN LIEBMAN
TECHNICAL DIRECTOR
RADIATOR SPECIALTY  COMPANY
P.O. BOX 34689
CHARLOTTE, NC 28234-6080
(704)377-6555
                                      4-15

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LORRAINE LILLIS
MANAGER, REGUALTORY AFFAIRS
CPL INDUSTRIES, DIVISION OF COLGATE PALM
909 RIVER ROAD
PISCATAWAY, NJ 08855-1343
(201)878-7468

ROMON LLENDO
LEHN & FINK PRODUCTS GROUP
225 SUMMIT AVE.
MONTVALE, NJ 07645
(201)573-5500

DOORIS LO
U.S.EPA-REGION 9
215 FREMONT STREET
A-2-3
SANA FRANCISCO, CA 94105
(415)974-7054

KEVIN LOFTUS
GILLETTE COMPANY
PRUDENTIAL TOWER
38TH FLOOR
BOSTON, MA 02199
(617)421-7880

ARCH A. MACQUEEN
ENVIRONMENTAL ENGINEER
U.S.EPA/CRITERIA EMISSIONS SECTION
MD-14
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5576

EDWARD P. MAJKRZAK
TECHNICAL DIRECTOR
GENERAL PAINT & CHEMICAL
201 JANDUS RD.
GARY, IL 60013
(312)639-5383

W. ROY MALLARNEE
TECHNICAL DIRECTOR
PLASTI-KOTE CO., INC.
1000 LAKE ROAD
MEDINA, OHIO 44256
(216)725-4511

KELVIN MARTIN
ENVIRONMENTAL ENGINEER
U.S.EPA/OAQPS/CHEMICALS & PETROLEUM BRAN
MD-13
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5416

                                     4-16

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BRENDA MASSENGILL
U.S.EPA/AEERL
MD-49
RESEARCH TRIANGLE PARK, NC 27711
(919)541-2990

JAMES W. MCCABE
PRODUCT SAFETY SPECIALIST
THE CLOROX COMPANY
P.O. BOX 493
PLEASANTON, CA 94566
(415)847-6674

DR. HARRY B. MCCAIN
TECHNICAL DIRECTOR
AEROPRES CORPORATION
P.O. BOX 78588
SHREVEPORT,, LA 71137-8588
(318)221-6282

MATTHEW W. MCCARTHY
ENVIRONMENTAL ENGINEER
U.S.EPA-REGION 11
26 FEDERAL PLAZA
NEW YORK, NY 10278
(212)264-2517

RANDY MCDONALD
ENVIRONMENTAL ENGINEER
U.S.EPA/OAQPS/ESD
MD-13
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5402

DR. DEBRA MESCHKE
RESEARCH SCIENTIST
UNION CARBIDE
P.O. BOX 8361
S. CHARLESTON, WV 25303
(304)747-3934

LARRY MIDTBO
VICE PRESIDENT
1-K-l MANUFACTURING
116 SWIFT ST.
EDGERTON, WI 53534
(608)884-3411

MARK MILLKEY
ATTORNEY
SIMPSON, THATCHER, & BARTLETT
425 LEXINGTON AVE.
NEW YORK, NY 10017
(212)455-2645
                                     4-17

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BRUCE MOORE
U.S.EPA/OAQPS/ESD
MD-13
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5460

EILEEN MOVER
DIRECTOR, REGULATORY AFFAIRS
AIRWICK INDUSTRY
1655 VALLEY ROAD
P.O. BOX 941
WAYNE, N.J. 07474-0914
(201)633-2778

KENNETH J. MURRAY
ENVIRONMETNAL AFFAIRS MANAGER
EXXON CHEMICAL COMPANY
P.O. BOX 536
LINDEN, N.J. 07036
(201)474-2861

J.S. NAMNATH
SUPV., FORMULATION & ANALYTICAL CHEMISTR
CHEVRON CHEMICAL CO., CONSUMER PRODUCTS
P.O. BOX 4010
RICHMOND, CA 94804-0010
(415)231-6212

RICHARD NEILL
REGULATORY DIRECTOR
AMREP, INC.
63  INDUSTRIAL DR.
CARTERSVILLE,, GA 30120
(800)221-6772

ROBERT J.  NELSON
DIRECTOR  ENVIRONMENTAL AFFAIRS
NATIONAL  PAINT & COATING  ASSOCIATION
1500 RHODE  ISLAND AVE. NW
WASHINGTON,  DC 20005
(202)462-6272

JERONE NEWBERRY
PRODUCT  MANAGER
PENNZOIL  COMPANY
700 MILAM STREET
HOUSTON,  TX  77252-2967

BROCK NICHOLSON
CHIEF, POLICY  DEVELOPMENT SECTION
U.S.EPA/OAQPS/AQMD
MD-15
RESEARCH TRIANGLE  PARK,  NC 27711
 (919)541-5517

                                      4-18

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JAMES C. O'CONNOR
CORPORATE MANAGER, REGULATORY AFFAIRS
RUST-OLEUM CORPORATION
11 HAWTHORN PARKWAY
VERNON HILLS, IL 60061
(312)816-2251

JOHN P. O'CONNOR
DEPUTY DIRECTOR
OFFICE OF AIR QUALITY PLANNING & STANDARDS
U.S.EPA
MD-10
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5506

DEAN O'HAIR
CHEVRON CHEMICAL CO., CONSUMER PRODUCTS
P.O. BOX 4010
15049  SAN PABLO AVE.,  94806
RICHMOND, CA 94804-0010
(415)231-6351

RICHARD OLIN
SENIOR ENVIRONMENTAL  ENGINEER
VIRGINIA DEPT. OF AIR POLLUTION CONTROL
P.O. BOX 10089
RICMOND, VA  23240
(804)786-7564

DAVID  B. OLSEN
SR.  PRODUCT  RESPONSIBILITY  SPECIALIST
3M  COMPANY
251-2E-12, 3M CENTER
AUTOMOTIVE TRADES DIV.
ST.  PAUL, MN 55144
 (612)733-4604

ANTHONY PATTI
SR.  RESEARCH CHEMIST
CHESBOROUGH  PONDS
40  MERRITT  BLVD
TRUMBULL,  CT 06611
 (203)381-4344

 TIM PETERSEN
 ASSOCIATE
 INDUSTRIAL ECONOMICS, IMC.
 2067 MASSACHUSETTS AVE.
 CAMBRIDGE,  MA 02140
 (617)354-0074
                                      4-19

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MICHAEL PEZZULO, JR.
Id RESINS
730 MAIN STREET
WILMINGTON, MA 01887

JAMES POLLACK
DOW CORNING CORP.
DOW CORNING CENTER
MIDLAND, MI 48686-0994
(517)496-4244

WADE PONDER
CHIEF, ORGANICS CONTROL BRANCH
U.S.EPA/AEERL
MD-61
RESEARCH TRIANGLE PARK, NC 27711
(919)541-2818

BARBARA POPEK
GOVERNMENTAL AFFAIRS ADMINISTRATOR
LEHN & FINK PRODUCTS GROUP
225 SUMMIT AVENUE
MONTVALE, NJ 07645
(201)573-5502

DANNY POTEET
BEECHAM LABORATORIES
501 5TH ST.
BRISTOL, TN 37620
(615)652-3681

J. PRICE
DOW BRANDS
P.O. BOX 368
GREENVILLE, SC 29602

DOUGLAS RAYMOND
REGULATORY AFFAIRS SPECIALIST
SPRAYON PRODUCTS, DIV. OF SHERWIN-WILLIAMS
26300 FARGO AVENUE
BEDFORD HEIGHTS, OHIO 44146
(216)292-7410

ALLEN REED
VICE PRESIDENT, RESEARCH & TECHNICAL SER
CRC INDUSTRIES 885 LOUIS DR.
WARMINSTER, PA 18974
(215)674-4300
                                     4-20

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GLENN REED
SENIOR ENGINEER
PACIFIC ENVIRONMENTAL SERVICES
11440 ISAAC NEWTON ST.
STE.209
RESTON, VA 22090
(703)471-8383

GRAHAM REED
VICE PRESIDENT MANUFACTURING
BLUE CORAL, INC.
5300 HARVARD AVENUE
CLEVELAND, OHIO 44105
(216)641-5490

JOHN ROBSON
U.S.EPA/STANDARDS DEVELOPMENT BRANCH
MD-13
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5305

A.F. ROGERS
TECHNICAL MANAGER
FIRST BRANDS CORPORATION
88 LONG HILL STREET
EAST HARTFORD, CT 06108
(203)728-6086

STEVEN ROGOSHESKE
MCLAUGHLIN, GORMLEY & KING
8810 TENTH AVE. NORTH
MINNEAPOLISN, MN55 55427

DAVID ROMENESKO
SENIOR SPECIALIST-FLUIDS TECHNOLOGY
DOW CORNING
2200 W. SALZBURG RD.
MIDLAND, MI 48686
(517)496-5428

STEVE ROSENTHAL
U.S.EPA/REGION  5
230 S. DEARBORN AVE.
MD-5AR-26
CHICAGO,  IL 60604
(312)886-6052

RONALD RYAN
MANAGER,  PROCESS ENGINEERING  SECTION
ALLIANCE  TECHNOLOGIES CORPORATION
100 EUROPA DRIVE,  STE.150
CHAPEL HILL,  NC 27514
(919)929-8370
                                      4-21

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SUNNY RYERSON
DIRECTOR OF RESEARCH & DEVELOPMENT
WATERBURY COMPANIES, INC.
P.O. BOX 640
100 CALHOUN STREET
INDEPENDENCE, LA 70443
(504)878-6751

DALLAS W. SAFRIET
ENVIRONMENTAL ENGINEER
U.S.EPA
MO-15
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5371

PATRICIA SAMUEL
MANAGER, REGULATORY AFFAIRS
ROUSSEL BIO CORP
170 BEAVER BROOK RD.
LINCOLN PARK, NJ 07035
(201)628-7200

MIKE SANGI0VANNI
EDITOR
AEROSOL AGE MAGAZINE
389 PASSAIC AVE.
FAIRFIELD, NJ 07006
(201)227-5151

RONALD SANTELLI
SR. RESEARCH SCIENTIST
FISONS PHARMACEUTICALS
755 JEFFERSON RD.
ROCHESTER, NY 14623
(716)475-9000 X2533

ELLEN M. SCHEIDE
REGULATORY AFFAIRS MANAGER
3M COMPANY/ADHESIVES, COATINGS & SEALERS
3M CENTER
209-1C-13
ST. PAUL, MN 55124
(612)733-4116

LAUREL SCHULTZ
ENVIRONMENTAL ENGINEER
U.S. EPA, OAQPS
MD-15
RESEARCH TRIANGLE PARK, N.C. 27711
(919)541-5511
                                     4-22

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KARL R. SCHULTZ
E.I. DUPONT CO.
1007 MARAKET ST., B-5226
WILMINGTON, DE 19898
(302)773-4394

MARILYN SCHWAB
MANAGER OF TECHNICAL SERVICES
ARYLESSENCE, INC.
1091 LAKE DRIVE
MARIETTA, GA 30066
(404)924-3775

RICHARD SEDLAK
RESEARCH DIRECTOR
THE SOAP & DETERGENT ASSOCIATION
475 PARK AVENUE, SOUTH
NEW YORK, N.Y. 10016
(212)725-1262

DAVID SHAW
TECHNICAL DIRECTOR
CLAIRE MANUFACTURING
500 VISTA AVE.
ADDISON, IL 60101
(708)543-7600

JOHN SILVASI
CHIEF, POLICY  IMPLEMENTATION SECTION
U.S.EPA/OAQPS/AQMD
MD-15
RESEARCH TRIANGLE PARK, N.C. 27711
(919)541-5666

DEAN SIMEROTH
CHIEF, CRITERIA  POLLUTANTS BRANCH
CALIFORNIA AIR RESOURCES BOARD
1025 P STREET, ROOM 210
SACRAMENTO, CA 95814
(916)322-8283

CLAYTON  SMITH
ENGINEER
TEXAS  AIR CONTROL BOARD
6330 HIGHWAY  290 EAST
AUSTIN,  TX 78723
(512)451-5711

R.L. SMITH
SUPERVISOR, TECHNICAL  SERVICE & DEV.
EASTMAN  CHEMICAL PRODUCTS,  INC.
P.O. BOX 431
KINGSPORT, TN 37762
(615)229-3665
                                      4-23

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CYNTHIA STAHL
U.S.EPA/REGION 3
841 CHESTNUT BLDG
PHILADELPHIA, PA 19107
(215)597-9337

KEN STAMPER
CHIEF ENVIRONMENTAL ENGINEER
PHILLIPS PETROLEUM
12 B-l PHILLIPS BLDG.
BARTLESVILLE, OK 74004
(918)661-3797

DR. ROBERT R STEWART
MANAGER OF REGULATORY AFFAIRS
S.C. JOHNSON & SON, INC.
1525 HOWE STREET
RACINE, WI 53403
(414)631-2882

RANDY STRAIT
ENVIRONMENTAL SCIENTIST
ALLIANCE TECHNOLOGIES CORPORATION
100 EUROPA DRIVE, SUITE 150
CHAPEL HILL, NC 27514
(919)968-9900

DONALD STROBACH
RESEARCH ASSOCIATE
DU PONT
CHESTNUT RUN PLAZA
P.O. BOX 711
WILMINGTRON, DE 19880-0711
(302)999-3212

NICOLA A. STUFANO
DIRECTOR OF  SPECIAL PROJECTS
STANDARD CHLORINE CHEMICAL
1035 BELLEVILLE TURNPIKE
KEARNY, NJ 07032
(201)997-1700

STANLEY SUTHERLAND
SENIOR COUNSEL
S.C. JOHNSON WAX
1525 HOWE ST.
RACINE, WI 53403
(414)631-2995
                                      4-24

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BETH TEAGUE
ENVIRONMENTAL ENGINEER
U.S.EPA/OAQPS/ESD
MD-13
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5428

RAY THIMINEUR
GENERAL ELECTRIC

BRUCE A. TICHENOR
ENVIRONMENTAL ENGINEER
U.S.EPA/AEERL
MD-54
RESEARCH TRIANGLE PARK, NC 27711
(919)541-2991

GARY TONG
ENVIRONMENTAL AFFAIRS
BORDEN, INC.
1050 KINSMILL PARKWAY
COLUMBUS, OH  43229-1143
(614)431-6660

PAUL TRUCHAN
U.S.EPA/REGION 2
26 FEDERAL PLAZA
NEW YORK, NY 10278
(212)264-2517

W.GENE TUCKER
CHIEF-INDOOR AIR BRANCH
U.S.EPA/AEERL
MD-54
RESEARCH TRIANGLE PARK, NC 27711
(919)541-2746

TOM TUPA
CHEMIST
LOCTITE CORPORATION
18731  CRANWOOD PARKWAY
CLEVELAND, OH 44128
(216)475-3600

JOHN UNGVARSKY
U.S.EPA-REGION 9
215 FREMONT
A-2-3
SAN FRANCISCO, CA 94105
(415)974-7054
                                      4-25

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CAROLE VARANELLI
BUSINESS MANAGER
MICRO VESICULAR SYSTEMS, INC.
22 COTTON RD.
NASHUA, NH 03063
(603)889-5538

VISH VARMA
VICE PRESIDENT
ROY F. WESTON, INC.
1635 PUMPHREY AVE.
AUBURN, AL 36830
(205)826-6100

CHUCK VAUGHT
CHEMICAL ENGINEER
MIDWEST RESEARCH INSTITUTE
401 HARRISON OAKS BLVD.
STE.350
CARY, NC 27513
(919)467-5215

AL VERVAERT
CHIEF, STANDARDS SUPPORT SECTION
U.S.EPA/OAQPS/ESD
MO-13
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5602

SUZANNE VETRANO
SENIOR ENVIRONMENTAL ENGINEER
CLOROX CO.
7200 JOHNSON DR.
PLEASANTON, CA 94566
(415)847-6674

DR. ALLAN WAGNER
DIRECTOR, REGULATORY AFFAIRS
ADAMS VETERNARY RESEARCH LABORATORIES
P.O. BOX 971039
MIAMI, FL 33197
(305)253-6601

GREG WALSH
QUALITY ASSURANCE SUPERVISOR
DARWORTH CO.
50 TOWER LANE
AVON, CT 06001
(203)677-7721
                                     4-26

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AL WEHE
CHIEF, COST AND ECONOMIC IMPACT SECTION
U.S.EPA/OAQPS/ESD
MD-13
RESEARCH TRIANGLE PARK, NC 27711
(919)541-5623

BERNARD WEINSTEIN
BOYLE-MIDWAY
SOUTH AVE. & HALE ST.
CRANFORD, NJ 07016

JAMES D. WELLS
VICE PRESIDENT CHEMICAL OPERATIONS
RADIATOR SPECIALTY COMPANY
P.O. BOX 159
INDIAN TRAIL, NC 28079
(704)821-7642

THEODORE WERNICK
DIRECTOR, SCIENTIFIC REGULATORY AFFAIRS
GILLETTE MEDICAL EVALUATION LABORATORIES
401 PROFESSIONAL DR.
GAITHERSBURG, MD 20879
(301)590-1550

BILL WILDERSON
OPERATIONS MANAGER
SCOTT'S  LIQUID GOLD-INC.
4880 HAVANA  STREET
DENVER,  CO 80239
(303)373-4860

CAROLYN  WILLS
REGULATORY AFFAIRS
MARY  KAY COSMETICS
1330  REGAL ROW
DALLAS,  TX 75247
(214)638-6750

NORWIN W.  WOLFF
PRESIDENT
INTERPOLYMER CORP.
330 PINE STREET
CANTON,  MA 02021
 (617)828-7120

ROBERT WOOTEN
 NORTH CAROLINA AIR QUALITY
 512 N. SALISBURY STREET
 RALEIGH, N.C.  27611
 (919)733-3340 X 326
                                      4-27

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CAREL WRIGHT
SIMPSON, THATCHER & BARTLETT
425 LEXINGTON AVE.
NEW YORK, NY 10017
(212)455-2645

ROGER YOUNG
RESEARCH CHEMIST
DESOTO,  INC.
1700 S.  MT. PROSPECT RD.
DES PLAINES, IL 60017
(708)391-9427

HARVEY  ZIMMERMAN
LIQUID  FORMULATION MANAGER
BEECHAM LABORATORIES
501 5TH STREET
BRISTOL, TN 37620
(615)652-3574
                                                    «"'•  •   '.'?,-•••'•  ;S •;,,. . - ..
                                       4-28                         i          H*

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U.S. Environmental Protection Ag«ncy
Region 5, Library (PL-12J)
77 West Jackson Boulevard,  12th Flo*
Chic^o, 1L  60604-3590

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