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 8 Spray August 2014 Regulatory Issues Doug Raymond Raymond Regulatory Resources Updates on the CARB Survey, DTSC Priority Products and SCAQMD Rule 1168 Amendments CARB In speaking with the California Air Resources Board (CARB), I learned that the amendment package from the 2013 Board Hearing is moving through CARB management and should be on its way to the Office of Administrative Law (OAL) soon. This is the last step to make the amendments final and needs to be done soon to meet its deadline. Remember, for some specialty coatings, the Maximum Incremental Reactivity (MIR) limits were revised and become effective Jan. 1, 2015. Anyone making specialty coatings should review these limits and ensure their products are compliant. Also, remember that the new MIR values are also now in place. Thus, to make sure your products are compliant, you need to use the new MIR values with your formula and check it against the new limits for specialty categories. Other coating category limits will become effective in 2017. Survey Industry and CARB have been having numerous discussions to try and complete the new survey, which is due out in late August or September 2014. This survey will be the most comprehensive survey the Consumer Products industry has seen. CARB wants to try and get an accurate inventory of all Consumer Products before proceeding with future rulemakings. The amount of detail that CARB is asking for is more than in past surveys and the number of categories has also increased. Industry has voiced its concerns over the amount of detail CARB is requesting. Currently, there is a dialog with some give-and-take over the survey. One of the largest concerns of the industry is the issue of security. This is one area that cannot be compromised. Confidential formulas are the lifeblood of a company. CARB is taking this issue seriously and making every effort to secure the data. The final details will likely be worked out soon and then CARB will send out the survey. Currently, CARB is granting six months for completion. We will need to wait and see how the final details work out. Green Chemistry The Dept. of Toxic Substance Control (DTSC) is now reviewing comments received on the Safer Consumer Products Regulation. Comments were requested by June 30, but will be accepted after that date. There is significant concern in the industry on how and why DTSC picked the current Priority Products and Candidate Chemicals. The two Priority Products affecting the Consumer Products industry are Spray Polyurethane Foam and Paint Strippers. Neither of these products is widely used by the majority of the population. Industry will need to wait for DTSC to review the comments and respond before we get any answers. DTSC has been willing to meet with the industry on these products. This appears as though it will be a very long process. SCAQMD The South Coast Air Quality Management District (SCAQMD) is still moving ahead with amendments to Rule 1168, which regulates adhesives and sealants. One of the amendments is to regulate consumer products used in the district. This is a very dangerous precedent. As an industry, we need to oppose any district-by-district regulation of Consumer Products. Even if you do not have adhesives and sealants, your product category could be next. When SCAQMD attacked Multi-Purpose Solvents and Paint Thinners a couple of years ago, most of the industry ignored the issue. Now, SCAQMD is after another category. This only leads us to ask which category is next should these amendments pass. SPRAY
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