“The California Air Resources Board (CARB) needs to develop accurate and relevant data recording to properly assess emissions from down-the-drain cleaning products, according to comments submitted by the American Cleaning Institute. CARB has proposed the use of emission factors that greatly overestimates the emissions from these products.”
ACI is urging CARB to:
Revise the emissions discount adjustment factors to more accurately account for volatile organic compound (VOC) and low vapor pressure (lvp) VOC emissions from down-the-drain products.
- Review its consumer products survey to ensure that all down-the-drain products are accurately represented and correctly categorized into Fate Categories as outlined in the spreadsheet
“While ACI agrees with ARB’s approach of considering actual emissions from products to inform any State Implementation Plans (SIP), the adjustments described in the report, Environmental Fate of Low Vapor Pressure – Volatile Organic Compounds from Consumer Products: A Modeling Approach (Report), and used as the emissions discount adjustment factor in the spreadsheet, are insufficiently supported by other measured and modeled data. In fact, the numbers are contrary to the scientific studies that have been conducted, and ignoring those studies is inconsistent with ARB’s stated approach,” noted Kathleen Stanton, ACI Director, Technical & Regulatory Affairs.
“The report inappropriately assumes only two emission modes – direct outdoor air emission and indoor down-the-drain wastewater emission. However, the down-the-drain product categories would have much less air emission than currently apportioned (90%). Assigning the same adjustment factors for combustion products whose VOC and lvp are directly released into outdoor air through outdoor use or expelled through vents or chimneys and products whose uses are largely indoors, contained in aqueous solution, and whose fate is down-the-drain is inexplicable.”
ACI also notified CARB that “categories of down-the-drain products are missing from the spreadsheet. Rinse-off personal care products such as hand, body and facial cleaners and soaps are represented, but rinse-off cleaning products such as hard surface and all-purpose cleaning products are not listed. ACI recommends the spreadsheet be amended to include these product categories as down-the-drain products.”