The Household & Commercial Products Association (HCPA) supports the amendment to add trans-1,1,1,4,4,4-hexafluorobut-2-ene (HFO-1336mzz(E)) to the list of substances not considered to be a VOC in Virginia.  However, during HCPA’s review of the proposed definition of a VOC for Virginia as compared to the federal definition, HCPA realized that another compound, cis-1,1,1,4,4,4-hexafluorobut-2-ene (HFO-1336mzz-Z), exempted by the U.S. Environmental Protection Agency (EPA) is still recognized as a VOC in the state of Virginia.

By developing consistent VOC regulations with the same definitions, states can achieve improvements in air quality without imposing impediments to interstate commerce.  Therefore, HCPA would like to respectfully request that DEQ also include HFO-1336mzz-Z in the list of substances not considered to be VOCs in the state so that the definition of a VOC in Virginia aligns with EPA.

HCPA appreciates the opportunity to provide these comments and is submitting our full letter on the proposed amendments via email to karen.sabasteanski@deq.virginia.gov.