www.aeropres.com www.inhalant.org www.coster.com www.dscontainers.com www.diversifiedcpc.com www.ikimfg.com www.mbc-aerosol.com www.montebellopkg.com www.precisepackaging.com www.terco.com April 2014 Spray 9 Regulatory Issues Doug Raymond Raymond Regulatory Resources The EPA's aerosol coating regulation requires triennial reporting, and reports needed to be filed by March 31, 2014. CARB News from the California Air Resources Board (CARB) is that its 15-day comment notice will have expired by the end of March. By the time you’re reading this, you will have hopefully seen the comments. Remember, CARB needs to complete work on the 15-day comment notice to finalize the September 2013 Board Meeting amendments. It appears that some changes will be made to the definitions adopted at the September 2013 Board Meeting. If changes are deemed “significant,” CARB staff needs to take the changes back to its Executive Board to be voted on. Hopefully, we will see the changes soon. In the past, CARB Enforcement has honored any changes made at the Board Meeting that are pending final approval by the Office of Administrative Law (OAL). Be prepared to review and remark quickly on the CARB comments when they become available, as we will only have 15 days to comment. Next on CARB’s agenda are surveys. This year, CARB plans to survey Architectural Coatings, Personal Care Products and Consumer Products. CARB is in the process of updating its volatile organic compound (VOC) inventory. These surveys will be comprehensive and we need to work closely with CARB on what information is needed and the timing of these surveys. Industry is already involved with several issues that will make completing the surveys in a timely manner difficult. SCAQMD The staff of South Coast Air Quality Management District (SCAQMD) is working on amending two rules. First, as reported last month, is Rule 1168. SCAQMD is proposing to reduce the VOC limit in numerous categories, but more importantly it is proposing to regulate all consumer uses of Adhesives and Sealants that do not have a CARB VOC limit. CARB has reviewed several Adhesive and Sealant categories and have not set VOC limits due to technological and commercial feasibility issues. This does not mean that CARB has not regulated these product categories. More discussion with SCAQMD and CARB is needed on this issue. Second, SCAQMD staff is proposing a change to Rule 102 that will add HFO 1233zd to the list of exempt solvents. In February, SCAQMD held a workshop on this issue. This HFO will likely be used in the degreasing products arena. OTC The Ozone Transport Commission (OTC) will hold its next meeting on April 10 in Washington, DC. Industry needs to monitor the OTC for upcoming adoptions of the states with the new OTC model Consumer Products regulation. Timing and consistency maintenance are needed when additional states begin to adopt the model rule. EPA The U.S. Environmental Protection Agency’s (EPA) aerosol coating regulation requires triennial reporting, and we needed to report by March 31, 2014. If you missed that deadline, then file as soon as possible. The link to the rule can be found at: http://tinyurl.com/lsec5pj Green Chemistry The product categories and compounds to be regulated by California’s Safer Consumer Products Regulation (Green Chemistry) are due to be released in April 2014 and will be reported on in the May issue of Spray, as well as on www.spraytm.com. Spray
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