Going Beyond the Usual Suspects to Reduce Emissions
While it might not seem like hair spray, carpet cleaner, or air fresheners contribute to Utah’s PM2.5 problem, they do. Many states have already enacted VOC limitations on a wide range of consumer products, mainly to address elevated ground-level ozone concentrations in California, the Northeast, and the Midwest. Since VOCs are also a major factor in the formation of PM2.5, a reduction in the VOC emissions from household products will likewise lead to a decrease in the formation of fine particulate pollution. In an effort to address high episodic levels of PM2.5 in Utah, the Division of Air Quality (DAQ) is proposing rules that would reduce VOCs in consumer products sold in the state.
Unexpected Sources
Solvents contained in common products such as paints, varnishes, preservatives, waxes, dry cleaning products, polishes, degreasers, and automotive products have long been known to emit VOCs. New carpeting, backing, and adhesives, wood products manufactured using certain glues, finishes, and waxes, and vinyl type flooring and wall coverings can all release VOCs into the air.
What most people might not know is that cosmetics, personal care products, disinfectants, laundry detergents, air fresheners, fabric softeners, dryer sheets, dish detergents, all-purpose cleaners, soaps, hand sanitizers, lotions, deodorants, shampoos, and hair spray contain organic chemicals that release VOCs when used. While the quick drying solvents in aerosols generate good quality sprays and keep the pressure in the containers constant, they add to the VOC emissions from these spray products. But prohibiting aerosol sprays doesn’t completely solve the problem, because pump sprays and stick deodorants also contain VOCs.
Rulemaking to Reduce VOC Emissions in Utah
Concern about the air quality impacts of VOCs in consumer products is not new. The Environmental Protection Agency (EPA) promulgated a rule in 1998 to reduce VOCs in consumer products nationwide after the agency determined that VOCs emissions from the use of these products can cause or contribute to high ozone levels. For some ozone nonattainment areas, these rules did not go far enough to improve air quality. Eastern states that are members of the Ozone Transport Commission (OTC) and the California Air Resources Board (CARB) updated their state rules to achieve VOC reductions in consumer products beyond those required by the federal rule. These groups have worked with manufacturers to reconfigure their products to meet these lower VOC requirements. States wishing to reduce VOC emissions from consumer products are now considering updated requirements contained in the OTC 2014 Model Rule for Consumer Products, which is part of a regional effort to reduce ozone levels in the Northeast.
DAQ is following suit, proposing rules to reduce VOCs from manufacturing and sales of consumer products. The rule establishes VOC limits which will require the reformulation of some of these products. These products fall into four categories:
- Personal care products
- Household products
- Auto aftermarket products
- Consumer use coatings
Lower VOCs in these products would provide a reduction of approximately 4,000 tons per year for the counties in nonattainment for PM2.5.
When preparing the rule, DAQ consulted and collaborated with national stakeholders who would be affected. These stakeholders included:
- The Consumer Product Specialty Association (CSPA), the trade association for companies that engage in the manufacture, formulation, distribution, and sale of familiar consumer products. Their membership accounts for 75 percent of the products manufactured that would be regulated by this rule,
- The Personal Care Products Council (PCPC), the leading national trade association for the cosmetic and personal care products industry, and
- The American Coatings Association, Inc. (ACA), representing manufacturers of paints and coatings.
Generally speaking, the CSPA, PCPC, and ACA have told DAQ that they support the OTC model rule because it offers regulatory uniformity that allows manufacturers to produce formulations that can be distributed nationally.
These rules would not ban these products. Products currently on the shelves and in warehouses could still be sold. Products subject to these rules will be required to clearly display the product manufacture date no later than a year before the rules for that particular product go into effect. Once the rules go into effect, manufacturers and suppliers would be required to provide only low-VOC product formulations for sale and distribution in the affected counties.
What Consumers Can Do Today
Some consumer products already offer lower VOC alternatives. Consumer demand for low or zero VOC paints, solvents, and coatings has created a greater market for these lower emitting products, although a growing assortment of green logos can make it hard to determine whether or not the product meets strict standards for VOCs.
For consumers looking for a way to make more informed purchasing choices, EPA’s Design for the Environment (DfE) program screens and identifies products through a stringent scientific review process. Chemical-based products carrying the DfE logo meet strict EPA standards and include all-purpose cleaners, laundry detergents, degreasers, and carpet and floor care products. The DfE Standard for Safer Products incorporates the California Air Resource Board’s VOC regulations, which limit the amount of VOCs that can be used in various cleaning product categories. EPA has a list of DfE labeled products located on its Website.