Odor RemoverEliminator

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Odor Remover/Eliminator

• Bryan Ruble
• Dial Corporation
• CSPA Household Products Technical Seminar
• For California Air Resources BoardJuly 27, 2006

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Odor Remover/EliminationCategory or Claim??

• CARB has traditionally identified product
  categories by product purpose
• Air freshener sprays, wicks, powders, and
  crystals, designed for the purpose of masking
  odors, or freshening, cleaning, scenting, or
  deodorizing the air.
• General Purpose Cleaner product designed for
  general all-purpose cleaning, in contrast to
  cleaning products designed to clean specific
  substrates in certain situations.

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Odor Remover/EliminationCategory or Claim??
(cont.)

• Fabric Refresher product labeled to neutralize
  or eliminate odors on non-laundered fabric
  including, but not limited to, soft household
  surfaces, rugs, carpeting, draperiesdoes not
  include soft household surface
  sanitizersdisinfectant

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PRODUCT STATEMENT OF IDENTITY

• Federal Trade Commission
• Consumer Product Safety Commission
• Environmental Protection Agency

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Consumer Products with Odor Removal/Elimination
Claims

• Odor removal/elimination is a specific product
  benefit/feature, regardless of the product
  category or form
• 7/19/06 Proposed Category Definition for odor
  removal/elimination does not acknowledge the
  distinction between the category and the specific
  claim

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Consumer Products with Odor Removal/Elimination
Claims

• Categories of products currently making odor
  removal/elimination/neutralization claims
• Air freshenerall forms Fabric Refresher
• Bathroom and Tile Cleaner General Purpose
  Cleaner
• Disinfectant Sanitizers
• Dual purpose Air Freshener/ Toilet/Urinal Care
• Disinfectant
• Carpet and Upholstery Cleaners

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Consumer Products with Odor Removal/Elimination
Claims

• These categories are currently regulated by CARB,
  with the exception of disinfectants and
  sanitizers (which are included in the CONS-2
  proposal)
• Most restrictive limit, Section 94512 (a),
  requires that if a product has more than one
  purpose, the most restrictive VOC limit will
  apply (does not apply to general purpose cleaners)

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Current VOC Limits

• Air freshener
• Double phase 25
• Single phase 30
• Liquids/pump spray 18 (0.5 proposed)
• Solids/semisolid 3
• Bathroom and Tile Cleaner
• Aerosol 7 (5 proposed)
• All other forms 5 (1 proposed)
• Carpet and Upholstery Cleaners
• Aerosols 7
• Non-aerosols (dilutables) 0.1
• Non-aerosols (RTU) 3

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Current VOC Limits

• Disinfectant
• Aerosol 70 proposed
• Liquid 5 proposed
• Dual purpose Air Freshener/Disinfectant60
• Fabric Refresher
• Aerosol 15
• Non-aerosol 6
• Sanitizer
• Aerosol 70 proposed
• Liquid 5 proposed

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Current VOC Limits

• Toilet/Urinal Care
• Aerosols 10
• Non-aerosols 3
• With the application of the most restrictive
  limit, all of these products would be required to
  reduce to 0.5, which is technically infeasible
  for all of these products

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2003 Survey Data

• 2003 survey data does not include a significant
  percentage of products currently on the market
  using an odor remover or odor eliminator
  claim (most likely because there was no
  definition, and most products are already
  regulated)
• Most of the products in the 2003 survey would be
  in the air freshener category and would be exempt
  based on the proposed definition
• End result A significant number of products on
  the most recent list should be moved to other
  categories

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Recommendations

• Therefore, CSPA proposes eliminating the proposed
  category of odor remover/ eliminator
• Justification
• virtually all the products making such claims are
  already regulated by CARB
• have already achieved significant reductions
• Odor remover/eliminator is a claim NOT a category