The U.S.’s GHS-based Hazcom 2012 regulation is based on the now-outdated 3rd edition of the Purple Book. It is not outside the realm of possibility that OSHA will update Hazcom 2012 to be aligned with Revision Four or Five of the Purple Book; this would mean a great deal of revision work for industry, as Revision Four changes labeling rules for non-flammable aerosols. With new versions of the Purple Book being released every two years, the only constant for GHS-based regulations is change. Douglas Troutman, American Cleaning Institute (ACI) VP & Counsel, Government Affairs ACI will be thoroughly engaged in efforts to try and strengthen TSCA in 2014. We believe the best opportunity to accomplish this is to move forward with the bipartisan legislation introduced in the Senate by the late Senator Frank Lautenberg (DNJ) and Sen. David Vitter (R-LA): the Chemical Safety Improvement Act. The Lautenberg- Vitter bill is the best opportunity we’ve had in a generation to get a solid, science-based, common sense update to TSCA. A strengthened TSCA has the potential to promote consumer and environmental protection while enabling innovation for new and improved products. ACI will also be engaged, on behalf of the cleaning product supply chain, on state level efforts to regulate chemicals in commerce. California’s implementation of their Safer Consumer Product regulations could have far-reaching implications for cleaning product manufacturers and chemical producers alike, especially in the selection process for so-called “Priority Products.” Taking TSCA before the House In November, ACI urged Congress to strengthen TSCA, in testimony before a House subcommittee. ACI President & CEO Ernie Rosenberg told reformulations, product use restrictions or product bans. This program has been a significant foil in TSCA reform efforts at the federal level over concerns of preemption, as it is a much more aggressive program than what is being contemplated on the national level. Meanwhile, CalRecycle is busy planning ways to reach an ambitious goal of 75% recycling, composting or source reduction of solid waste by 2020, which was set by California Legislature in 2011. CalRecycle’s recommendations will be presented in a report to the Legislature in January. Draft versions have included promoting extended producer responsibility programs, expanding the beverage container recycling program, and source reduction, to name a few. At CARB, a research project examining the reactivity of LVP-VOCs in consumer products, kicked off in December. The research will take approximately two years, and could lead to revised regulations. In the summer of 2012, South Coast Air Quality Management District (SCAQMD) proposed eliminating the LVP exemption currently in place, but industry advocated intensely for more research before giving SCAQMD carte blanche, so heading into 2014 the industry is in a much more stable position than it was a year ago. Predicting the future is never easy, but it’s probably safe to say regulations will continue to increase…and, if the adage is true, the rest of the country can expect the same. Mike Moffatt, Ph.D., Nexreg Compliance, Inc., London, ON, Canada The year 2014 is shaping up to be a big one for the implementation of GHS-based regulations around the world. GHS will finally come to Canada with the release of a new Hazardous Products Regulations. In 2013, we saw the EU release a fourth Adaptation to Technical Progress (ATP) to the Classification, Labeling & Packaging (CLP), which harmonizes the EU’s CLP regulation with Revision 4 of the United Nation’s Purple Book. Seeing as Revision Five was recently released, expect another update from the Europeans. Troutman Moffatt The regulatory ballpark… 14 Spray January 2014
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