28 Spray August 2014 compliance difficult, they raise the spector of state-specific regulation of aerosol coatings in the Ozone Transport Commission (OTC) states and other regional state organizations. To date, OTC and other state environmental agencies have declined to adopt an air quality regulation for aerosol coatings because the EPA adopted the California standards and each state is able to include important emission reduction credits in each of their State Implementation Plans (SIP) which emanate from compliance with the national standards. Once the revised standards are enforceable in California, the remaining 49 states may determine that the EPA standards for aerosol coatings are obsolete and consider adopting the revised California standards. Monitoring and tracking regulations on a state-by-state basis is not a very efficient system and will prove to be extremely problematic. The threat of regulation from Environment Canada is also present. Several years ago, Environment Canada considered adopting air quality standards for aerosol coatings. However, since CARB was committed to a comprehensive rulemaking, ACA’s Spray Paint Manufacturers Committee convinced Environment Canada to wait until this rulemaking was completed. ACA also argued that a large number of aerosol coating products in Canada were already compliant with the California standards. Once the California amendments are final, Environment Canada will likely review their position on aerosol coatings. The SPMC continues to focus on those issues that threaten the marketplace for aerosol coatings. As you can see, efforts will continue in California to address the 2013 Consumer and Commercial Product Survey initiative and, outside of California, the status of the EPA national rule remains a concern. The Graffiti Resource Council, with the support of the ACA, will continue to work proactively with those localities that appear willing to adopt restrictions on the display or sale of aerosol coatings. Spray aerosol coatings formulas. In the late 1990s, significant amendments transformed this rule from a mass-based regulation to a reactivitybased regulation. These reactivity standards became enforceable in 2002 and 2003. The ACA convinced the U.S. Environmental Protection Agency (EPA) to adopt a very similar regulation with the same reactivity standards in 2008. Consequently, aerosol coatings manufacturers have enjoyed an efficient regulatory environment for many years, where the categories, definitions and standards in California and in the EPA national rule were exactly the same. Last year, California completed a comprehensive rulemaking which significantly amended the aerosol coatings regulation by refining many of the product categories, adding several new categories, reducing the reactivity limit for most categories and including updated Maximum Incremental Reactivity (MIR) values to be used in calculating the formula’s limit (productweighted MIR) with significant input from the SPMC. As we go to press, the amendments to the regulation have not yet been reviewed and approved by the Office of Administrative Law in California and are not yet “final” regulations. However, there is no doubt that the rule and the revised standards will become final and aerosol coatings will need to be compliant with these new standards in 2015 and 2017, depending on the category. This presents several issues for aerosol coatings manufacturers. There will be significant differences between the regulations of both CARB and the EPA, and compliance with both of these regulations will be very difficult to monitor. Not only do the varying standards and MIR values make
SprayAug14
To see the actual publication please follow the link above