VOC reactivity program for antiperspirants/deodorants under consideration by California.

CALIFORNIA "CLEAR" REACTIVITY VOC STANDARDS FOR ANTIPERSPIRANTS/DEODORANTS under consideration by the state's Air Resource Board (CARB) as an alternative volatile organic compound reduction program. Currently, personal care companies are required to limit VOC emissions by weight and not by measurement of chemical reactivity.

California's antiperspirant/deodorant VOC reg, slated to take effect Jan. 1, 1999, establishes a high volatile organic compound (HVOC) limit of 0% for aerosol products and a medium volatile organic compound limit (MVOC) not to exceed 10% by weight. Under the rule, antiperspirants and deodorants containing ethanol or fragrances or having a low vapor pressure of 2 mmHg or less at 20C are exempt from the MVOC standard.

The "California Low Emissions and Reactivity Program for Antiperspirants and Deodorants" (CLEAR) provides a "reactivity-based approach" for manufacturers and marketers as a "means to provide flexibility" in complying with CARB's HVOC and MVOC standards, the air resource board said. The program was first suggested in mid-October, and a formal proposal is expected to be introduced in early 1998.

Once the CLEAR program is accepted by the state, personal care companies will have the option to choose which VOC reduction program best suits their products. All of a company's products will be subject to the single program chosen.

Under the CLEAR program, manufacturers would measure the extent to which VOC chemicals react with the environment to create ground level ozone, or smog. A product's calculated potential to form ozone, or Maximum Incremental Reactivity value, must be zero for all non-carbon ingredients and non-volatiles. Specific MIR values would be assigned to selected compounds, including ethanol (1.34 g), acetone (.56 g) and isopropanol (.54 g). Other carbon-containing ingredients would be assigned a default value of 6 g.

The Cosmetic, Toiletry & Fragrance Association has voiced concerns with CARB's proposed CLEAR reactivity program. The Nonprescription Drug Manufacturers Association is following CTFA's lead on the CARB reactivity issue.

During the trade group's 1997 scientific conference in Atlantic City Oct. 26-29, CTFA VP-Legal & Regulatory Affairs Tom Donegan called the reactivity approach "unbelievably complex and intrusive." CARB's elimination of the ethanol, fragrance and LVP exemptions found in the mass-based approach is "totally unacceptable," Donegan declared. The program also would allow manufacturers "only 14 months to reformulate...entire product lines," he continued.

CTFA is working with CARB to "forge some middle ground" on the proposed antiperspirant/deodorant reg, Donegan noted. Since, according to Donegan, reactivity is a relatively new discipline that does not have the full endorsement of the scientific community, the trade group is concerned the reg is not based on "solid science." Donegan said he has "some reason to believe" an agreement can be reached. The board will discuss the antiperspirant/deodorant reactivity proposal at a Nov. 18-19 meeting in Sacramento, Calif.

During the CTFA conference, Donegan updated the audience on other CARB VOC regulatory initiatives. "Virtually all" of the product categories that were being considered for regulation in 1997, such as astringents and antimicrobial soaps, have been tabled. Some of the categories have been deferred "pending other considerations," Donegan explained. For example, astringents were referred to the California Department of Health Services for a study of their medical or health benefits to consumers.