“Regulatory compliance will also present continuing challenges,” said Fratz “Two of our primary goals will be to enhance recycling instructions on labels under the new Federal Trade Commission (FTC) Green Guides criteria, and assist in complying with the new U.S. Occupational Safety & Health Administration (OSHA) Hazard Communication Standard requirements for new Globally Harmonized System of Classification & Labeling of Chemicals (GHS) tests and criteria for aerosol flammability classification.” Laurie Nelson & Nicole Quinonez, Randlett/ Nelson/Madden, consultants to the National Aerosol Association (NAA) “As California goes, so goes the Nation.” At least that’s what California lawmakers want to believe. The state strives to set an example for the rest of North America, and based on sheer quantity, California has long been the regulatory leader in North America. As we look ahead to 2014, it’s no surprise that more regulatory programs are on the horizon. California’s landmark Safer Consumer Products program, known as Green Chemistry, is officially underway. The Dept. of Toxic Substances Control (DTSC) will select up to five priority product/ chemical combinations by April, requiring product manufacturers to conduct an alternatives analysis which could lead to product January 2014 Spray 13 ballpark… comprehensive consumer products survey to obtain complete VOC and LVP data. Joe Yost, CSPA Senior Director of Strategic Issue Advocacy, said at least five states on the East Coast plan to initiate rulemaking processes during 2014 to update existing VOC regulations by incorporating provisions of the current Ozone Transport Commission (OTC) Model Rule for Consumer Products. In addition, the OTC recently adopted a resolution calling upon the U.S. Environmental Protection Agency (EPA) to update the 1998 federal consumer products regulation by incorporating provisions of that rule. In addition, Environment Canada plans to issue a proposed regulation next summer and to promulgate a final regulation in mid-2015; the new VOC limits and related enforcement provisions are scheduled tentatively to take effect in January 2017. Yost explained that CSPA will work closely with the Canadian Consumer Specialty Products Association (CCSPA) in advocating that the new Canadian regulation is consistent with the current OTC Model Rule and not the current CARB regulation. Challenges for Aerosol Products The CSPA Aerosol Products Division also will be pursuing several specific regulatory goals in 2014, including adjustments to the National Fire Protection Association (NFPA) Code 30B fire code, U.S. Dept. of Transportation (DOT) transport regulations, and EPA guidance under the Resource Conservation & Recovery Act (RCRA) to facilitate recycling for rejected filled aerosol products. Nelson Continued on next page
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