HIGH PERFORMANCE CREATIVE CHEMISTRY

Blaster Corporation

8500 Sweet Valley Drive

Valley View, OH 44125

(216) 901-5800

1-800-858-6605

FAX: (216) 901-5801

June 23, 2008

Board Members

Air Resources Board

1001 I Street, 23rd Floor

Sacramento, California 95814

Attn: Ms. Lori Andreoni, Board Secretary

http://www.arb.ca.gov/lispub/comm/bclist.php

Subject: Proposed Amendments to the California Consumer Products Regulations 6/25/08; Board Agenda Item # 08-6-5

Dear Board Members:

For over 50 years, Blaster Corporation has manufactured penetrants, lubricants, rust inhibitors and a full line of specialty, highly concentrated formulas for the automotive, industrial and hardware industries. Blaster has a full-line of specialty lubricant, performance enhancement and cleaning products to serve professionals and DIYers.

Blaster appreciates the opportunity to comment on the proposed regulation. Blaster supports the staff proposal on Penetrants of 25% VOC limit effective 12/31/2013. Blaster Corporation is the market leader in this category. Our product will need to undergo a significant reformulation to meet this technology forcing limit. We plan to work closely with the staff through the R & D reports to ensure that the 25% limit is technically feasible and that we can achieve the given time table. The staff proposed timeline is needed to ensure that all attributes of the product are maintained. Our customers expect a product that provides penetration as well as water displacement and corrosion resistance. The majority of company sales are from this one important product, thus Blaster must maintain its high quality and consumer acceptance.

Thank you for your attention to this issue. Any questions or comments feel free to contact me at 216-901-5800 or e-mail to .

Respectfully submitted,

Paul Gardner

General Manager/Plant Operations

cc: Robert Fletcher, P.E., Division Chief, Stationary Source Division

Robert Barham, Ph.D., Assistant Division Chief, Stationary Source Division

Janette Brooks, Chief, Air Quality Measures Branch, Stationary Source Division

Carla Takemoto, Manager, Technical Evaluation Section, Stationary Source Division

David Mallory, P.E., Manager, Measures Development Section, Stationary Source Division

Judy Yee, Manager, Implementation Section, Stationary Source Division

Doug Raymond, Raymond Regulatory Resources (3R)