Regulatory Issues continued from page 10 CARB may be displayed on the bottom of a container as long as it is The CARB staff is in the process of developing amendments clearly legible without removing any product packaging. to the Consumer Products regulation. Aerosol Coating and CARB’s standard code has to be represented separately Aerosol Adhesive VOC limits are on the top of the list. Other from other codes on the product container so that it is easily amendments include CARB looking at the LVP-VOC exemption recognizable is the following: YY DDD = Year-Year-Day-Day-Day. for Multi-purpose Solvent and Paint Thinner. Remember, if one A manufacturer who uses this standard CARB code to indicate the category loses this exemption others will be next. In addition, date of manufacture does not have to report this code. maybe some definitions will be modified. Also, CARB is Failure to register a date code is subject to a fine. Every year considering one compound for a VOC exemption: HFO-1234ze. the fines seem to go up. Your date code explanation needs to be The next workshop will likely be in February. submitted to Enforcement on an annual basis, on or before January 31st of each year. Product Dating/Date coding Remember, date code information needs to be reported to Green Chemistry CARB every year by your company if you do not use CARB’s The Dept. of Toxic Substance Control (DTSC) is still reviewing standard date coding. For California, Section 94512 (b) product the significant amount of comments submitted to them on the dating, specifically requires all consumer products to be sold into proposed Safer Consumer Products rule. After DTSC finishes the state to display the day, month and year the products was reviewing the comments, it is anticipated that the agency will manufactured or a code indicating the date. CARB has been revise the proposed safer consumer products rule, and then send increasing their activity on investigating and levying fines for the revised draft out for further comments. As we go to press, non-compliance of this section. it looks like the revised draft may be out as soon as before the The date or date-code information shall be located on the holidays. Comment period will likely only be thirty days. container or inside the cover/cap so that it is readily observable or obtainable (by simply removing the cap/cover) without irreversibly Wishing everyone a Happy & Prosperous New Year! disassembling any part of the container or packaging. Information 22 Spray January 2013
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