CONSUMER SPECIALTY PRODUCTS ASSOCIATION

Improving Air Quality

CSPA member companies take seriously the environmental health and safety benefits of our products, and continuously seek to improve them. Therefore, CSPA member companies commit to expend the time and money to develop the new technologies necessary to reformulate their products to meet the regulatory requirements that limit the emission of volatile organic compounds (VOCs) while still maintaining the efficacy of their products.

For more than 20 years, CSPA's member companies have worked with the California Air Resources Board, environmental groups and other stakeholders to lower VOC content in consumer products. These efforts have helped to improve air quality in California, which has the world's most stringent VOC regulations.

In 1998, the U.S. Environmental Protection Agency (EPA) promulgated national VOC emission standards for certain categories of consumer products pursuant to §183(e) of the Clean Air Act.  See 40 C.F.R. Part 59 Subpart C (2008).  Since many consumer products are manufactured for a nationwide market, CSPA supports uniform regulations that improve air quality without imposing unnecessary impediments to interstate commerce.  CSPA worked cooperatively with the EPA to assist development of the current regulation.

During the past several years, 15 states and the District of Columbia promulgated final regulations based on the Ozone Transport Commission's (OTC) Model Consumer Products Rule.  These state regulations cover more categories of consumer products and generally impose more stringent limits than the current EPA rule.  These regulations are an integral part of the states' comprehensive strategy to reduce ground-level ozone to demonstrate attainment of the federal eight-hour ozone air quality standard.  CSPA worked cooperatively with states to encourage the development of consistent regional regulations because even slight differences between state regulations can make it very difficult for medium- and small-size companies to comply with the stringent VOC limits.

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