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Why are VOCs in Automotive Windshield Washer Fluid Regulated in California?
Before it was regulated in 1993, automotive windshield washer fluid (AWWF) was a very large source of pollution in California's cities. AWWF contained high levels of volatile organic compounds (VOCs) which are a component of ground-level ozone formation, and one of the main pollutants that compose smog. VOCs are used in AWWF as an anti-freeze which reduces the temperature the fluid will freeze in cold weather. In most areas of California, milder temperatures do not necessitate the use of VOCs for AWWF to wet and clean vehicle windshields. Reducing the amount of VOCs emitted into the atmosphere from consumer products is imperative to California's commitment to cleaner air, to protect public health and the environment. The California Consumer Products Regulation establishes limits on the VOC content of AWWF.
What kinds of AWWF are affected by the Regulation?
Pre-mixed AWWF that is typically sold in gallon-size containers, labeled "summer formula" or "protects to +32 degrees." The regulation for this type is 1% VOC content, and it can be sold anywhere in California.
Pre-mixed AWWF that is typically sold in gallon-size containers labeled "winter formula", "protects to zero degrees," or something similar. The regulation for this type is 25% VOC content, and it is only allowed to be sold in Type "A" areas of California.
Dilutable, or Concentrated AWWF, typically sold in 1-quart size containers. The regulation for this type is that it must clearly state on the front label that it is a concentrate, or dilutable, and on the back it must have clear instructions of how to dilute it to Type "A" area specifications and to non-Type "A" area specifications. It is available anywhere in California, and is most often found at automotive supply stores and service stations.
Service stations filling customers’ windshield washer fluid reservoirs must abide by the VOC limits for their location.In a Type "A" area, a service station may not fill an AWWF reservoir with AWWF above the 25% VOC limit, and service stations located in other areas of the state are required to fill AWWF reservoirs with up to only 1% VOC AWWF.
For further clarification, pre-mixed AWWF may be sold in containers greater than one quart, but less than 10 gallons. Dilutable AWWF is sold in containers that are one quart or less, or 10 gallons or more. Currently, AWWF sold in Type "A" areas is limited to 25% VOC, meaning pre-mixed AWWF will have no more than 25% VOC, and dilutable AWWF, when properly diluted, will contain no more than 25% VOC.All other areas of California (non-Type "A" areas) are limited to selling 1% VOC in pre-mixed AWWF.
Where are the Type "A" areas of California?
Type "A" areas in California include the following counties: Alpine, Amador, Calaveras, Del Norte, El Dorado, Inyo, Lassen, Mariposa, Modoc, Mono, Nevada, Plumas, Shasta, Sierra, Siskiyou, Trinity, and Tuolumne.
Additionally, the following areas described by the ZIP codes listed in the Table below are Type "A" areas.
Note: The county name is provided for reference only.
Type "A" Areas Identified by ZIP Code
Kern/Ventura/Santa Barbara/San Luis Obispo
* County name is provided as a point of reference only. Except as specified for ZIP codes 95602, 95603, and 95631, all portions of the identified ZIP codes are Type “A” areas.
** Only the portion of ZIP codes 95602, 95603, and 95631 that lie to the east of Range 9 east, Mount Diablo Baseline and Meridian.
Most Type "A" areas are defined by the county lines. However, in Placer County, the boundary between the Sacramento Valley Air Basin and the Mountain Counties Air Basin is not clearly defined by conventional maps. The boundary is called "Range 9 east, Mount Diablo Baseline & Meridian (M.D.B. & M)*." ZIP codes, in Placer County, east of this boundary is considered a Type “A’ area. For ZIP codes 95602, 95603, and 95631 only the portions that lie east of this boundary are considered Type “A” areas. For the Meadow Vista ZIP code (95722) the part west of this line is also considered a Type “A” area.`
Figure 1 illustrates the line dividing Type "A" area and non-Type "A" area, in Placer County, using a heavy bold line. A lighter bold line is used to delineate Placer County from the Nevada and El Dorado counties. The Range 9 east, M.D.B. & M. line is depicted using a hyphenated line through the Meadow Vista ZIP code and continuing on as the border between Type “A” and Non-Type “A” areas in Placer County.
*Range 9 east, M.D.B. & M. can be described as bordered by the Nevada County line to the north, and the El Dorado county line to the south. It is in a rural area between the towns of Auburn to the west, and Applegate to the east. On Interstate 80, it is between Neils Road (Exit 124) and Placer Hills Road (Exit 125).
Figures 2 and 3 are detailed street maps of the Range 9 east M.D.B. & M. boundary line areas within Placer County.
What constitutes compliant labeling of dilutable AWWF?
A compliant label on dilutable AWWF must have the following in order to be sold in California:
- The front label must clearly state that the product is a concentrate and must be diluted.
- The label must have clear instructions of how to properly dilute the product in Type "A" and in non-Type "A" areas. A sticker with this information affixed to the back of the container is permissible.
- The Type "A" Area dilution instructions must indicate a concentration of VOC no more than 25%. (See Section 94509(b) of the Consumer Products Regulation.)
- The container must be date-coded for the Julian day and year upon which it was manufactured, or meet other date-coding requirements detailed in the Consumer Products Regulation, Sections 94512(b) and c).
The label may also include language advising consumers to dilute to Type "A" specifications if traveling to areas where freezing temperatures are expected.
Is there a sell-through period for the labeling requirements?
Yes, there is a three-year sell-through period for properly date-coded AWWF manufactured on or before the finalized date of the Regulation: August 6, 2010.See the Consumer Products Regulation, Section 94512(c) for specific requirements.