December 1, 2006

Subject: 2007 CARB (California Air Resources Board) Chemical Product Regulations

Dear Valued Customer:

We want to make sure you are current on the upcoming CARB restrictions on cleaners and Techspray’s plan moving into 2007.

CARB is one of the strictest regulatory bodies in the US. New restrictions become effective Jan. 1 '07 that hit the West Coast region the most, but will touch everyone with customers in California. Any chemical product (that is not exempt) built on or after Jan. 1 ’07 has to meet the new CARB requirements.

We want this to be as transparent to distributors (and their customers) as possible. 100% of Techspray branded products will be able to ship into California as of Jan. 1 '07. We have done this by double-checking every product, reformulating and/or relabeling as necessary, and stocking up when more development time is needed.

If we are unsuccessful at meeting CARB requirements with a specific product, you will be given approximately 30-days notice of a stock-out, and we will then have to mark the product "NOT FOR SALE IN CALIFORNIA". At this point, you will have to tag this product in some way to avoid selling and shipping into California. This is expected to be a very rare occurrence and not on major sellers.

Please see attached document for answers to frequently asked questions. Feel free to contact me if you have questions on any specific products.

Sincerely,

Kevin Pawlowski
Senior Product Manager
Techspray
800-858-4043 x531
kpawlowski@techspray.com

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CARB Frequently Asked Questions

More information is available at http://www.arb.ca.gov/consprod/regs/cp.pdf

Q: What is CARB?

A:   CARB (California Air Resources Board) is one of the strictest regulatory bodies in the US. New restrictions become effective Jan. 1 '07 that regulate chemicals being sold within California. Only products build on or after Jan. 1 ’07 are required to meet the 2007 requirements. The goal of the CARB regulations is to limit VOC emitting chemicals used within the state. It generally regulates consumer products, but definitions are often broad enough to also cover industrial-type products as well.

Q:  What is the problem with VOC’s?

A:   The definition of VOC is as follows (source: TABLE 1, Definition of VOC, 40 CFR Part 51.100(s), Updated in 2000):

      “Volatile organic compounds (VOC) means any compound of carbon, excluding carbon monoxide, carbon dioxide, carbonic acid, metallic carbides or carbonates, and ammonium carbonate, which participates in atmospheric photochemical reactions.”

In short, VOC’s are considered a major contributor to smog. Although the majority of man-made VOC’s are generated by vehicles (Source: EPA, National Air Pollutant Emission Trends, 1999), solvents are often regulated to reduce VOC emissions.

A very good explanation of VOC is available at http://www.americansolventscouncil.org/resources/pdfs/VOC_2002.pdf

Q:  My facility is not in California, so does this affect my company?

A:   If you are an end-user with no facilities in California, these regulations do not affect you. If you have facilities in California, or you are a distributor/reseller with customers in California, you need to make sure only CARB compliant products are used/sold in California. We recommend that inventory is segregated physically or electronically, e.g. tagging a product “not for sale in California” similar to “ground shipment only”.

Q: How do I know if the products I buy are CARB compliant?

A:   All Techspray branded product can be sold into California in 2007. They either meet CARB requirements or were built before Jan. 1 ‘07. All Techspray branded products will be marked appropriately for CARB requirements. If it is apparent a product will not be CARB compliant, Techspray customers will be notified with 30-days notice. Anything not compliant will be marked “NOT FOR SALE IN CALIFORNIA”.

Q:  How is CARB compliance calculated?

A:   CARB defines VOC limits by product categories. The correct product category must first be ascertained to get the applicable VOC requirement. Product categories are generally derived from the product name or other verbiage on the labeling. In some cases, entire product categories are exempted, so are not regulated. If the product category is regulated, the percentage of the VOC chemical composition must be calculated. Chemicals that are exempted are subtracted from the VOC percentage.

For example:
5% of the formula is Isopropyl Alcohol (VOC)
95% water (exempted)
2% of the formula is CO₂ (exempted)
If this is a “glass cleaner”, it has to be at or below 7%, which it is. So it is CARB compliant. It has to be marked with a code representing the category and VOC requirement, so in this case Techspray would mark it GC-7.

A:   Who do I contact for more information on CARB compliance of specific products produced by Techspray?