Submitted Comment Name Sherrie Pace Affiliation N/A Subject Public Comment on the Draft Roadmap to Reduce Air Toxics – Prioritizing Indoor Air Quality, Consumer Products, and Fragrance-Free Environments Message Dear Chair Sanchez and Members of the Board, Thank you for the opportunity to provide public input on CARB’s Draft 2026 Roadmap to Reduce Air Toxics. As noted during the August 25 public workshop, CARB’s strategic intent to expand focus beyond traditional diesel emissions toward non-diesel sources and emerging air toxicants is both timely and essential. To build a truly protective, forward-looking toxics program for the next 20 years and beyond, CARB must explicitly integrate Indoor Air Quality (IAQ) and the primary chemical drivers of indoor toxic exposure—specifically, fragranced consumer and commercial products brought into the built environment—into the final Roadmap. I urge CARB to incorporate the following priorities into the revised Roadmap prior to its presentation to the Board in November 2026: 1. Bridge the Regulatory Gap Between Outdoor and Indoor Air Toxics Californians spend roughly 90% of their lives indoors, where concentration levels of volatile organic compounds (VOCs) and toxic air contaminants (TACs) are frequently several times higher than outdoors. While CARB has historically focused on ambient outdoor air, indoor air is where human exposure is highest. Because consumer and commercial products used inside the built environment off-gas directly into breathing zones, indoor air toxics represent a critical public health and environmental justice vulnerability that CARB is uniquely positioned to address under its authority. 2. Target Fragranced Consumer and Commercial Products as Major Sources of Emerging Toxicants Fragranced consumer and commercial products (e.g., ambient scenting, air fresheners, cleaning supplies, personal care items, and scented facility maintenance products) release complex mixtures of toxic air contaminants, including terpenes, phthalates, synthetic musks, and aldehydes. Secondary Organic Aerosols (SOAs): Scented products high in terpenes (such as limonene and pinene) react with indoor ozone to generate secondary pollutants, including formaldehyde and ultrafine particles. Building Comparisons Demonstrate Clear Benefit: Comparative building research—such an unpublished study by researcher Dino Zuppa evaluating air profiles across different facilities—demonstrates that transitioning to fragrance-free building policies and products significantly reduces indoor toxicant concentrations, specifically benzene, resulting in measurably healthier, lower-risk indoor air quality. 3. Address "Fragrance" Transparency and Toxic Chemical Mixtures The proprietary nature of "fragrance" formulations masks hundreds of undisclosed chemicals, many of which are known or suspected air toxics, sensitizers, and endocrine disruptors. A 20-year toxics roadmap must tackle the regulatory blind spots created by trade-secret fragrance mixtures in commercial, educational, and public built environments. Recommended Action Items for the Final Roadmap: Expand Research Gaps & Source Categories: Explicitly add Indoor Air Toxic Exposures from Fragranced Consumer and Commercial Products and Volatile Fragrance Compounds as dedicated categories in CARB’s research and risk management agenda. Promote Fragrance-Free Best Practices for State & Public Facilities: Partner with state agencies, school districts, and commercial facility managers to incentivize or mandate fragrance-free procurement policies and product selections. Strengthen Consumer and Commercial Fragranced Product Standards: Utilize CARB’s existing Consumer Products Program to establish stricter limits on volatile toxic ingredients in fragranced product categories and drive a market shift toward safer, fragrance-free formulations. Public Education & Building Guidance: Issue clear guidance for building owners, employers, and the public on the indoor health advantages of substituting fragranced maintenance and personal products with fragrance-free alternatives. Conclusion Addressing non-diesel and emerging toxicants requires looking at where human exposure actually occurs. By incorporating indoor air quality, fragrance chemical reductions, and fragrance-free building practices into the final 2026 Roadmap to Reduce Air Toxics, CARB can set a nationwide precedent for holistic, science-based public health protection. Thank you for your leadership and dedication to protecting the health of all Californians. Sincerely, Sher File Upload (i.e., Attachments): N/A N/A
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