Submission Number: 00002
Received: 10/25/2012 8:32:32 PM
Commenter: Ron Ruosch
Agency: Federal Trade Commission
Initiative: Proposed Consent Agreement In the Matter of The Sherwin-Williams Company, a corporation; FTC File No. 112 3198
Attachments: No Attachments
RE: Settlement with Sherwin-Williams and PPG Paints with respect to "VOC Free" claims on consumer paint products.
My objection to the settlement is in allowing the paint manufacturer to continue the VOC-free claim for the "base" paint so long as the label shows that VOC levels "may rise significantly" after tinting to the finished product. This is unacceptable because it simply obfuscates the issue for the consumer. The concerned consumer expects that "VOC-Free" means that the product "used as intended" will be free of VOCs. If the alternative labeling is allowed, it should be accompanied with information as to what levels the VOCs would "rise significantly." Do the VOCs vary by color? Are pastels lower in VOCs than deep tints? Reds worse than Greens? Without this information, consumers are left wondering. A better alternative would be to restrict the tinting to only those colors and color depths that would NOT cause the VOCs to rise above a certain level. Even then, the paints should be labeled "LOW VOCs," not VOC Free.
These paints, in their finished and ready-to-apply formulations, could be attractive honest alternatives to regular paroducts.
In summary, if the ready-to-use product cannot be made VOC-Free, then no such claim should be allowed. The LOW VOC claim should be allowed so long as any manufacturer-authorized tinting or alteration of the product at the point of sale maintains its Low VOC quality.
Thank you for the opportunity to voice this concern. ~RER