January 2014 Spray 17 and Specialty Coatings A are Jan. 1, 2017, while the standards for Specialty Coatings B are Jan. 1, 2015. The schedule of effective dates is of absolute importance to the aerosol coatings industry. As indicated above, the bulk of aerosol coatings products in the marketplace are the General Categories of Flat, Non-Flat, Primer and Clear coatings. In addition, these are the products that will have to undergo significant reformulations in order to achieve these reduced standards. This schedule of effective dates provides formulators and manufacturers more than three years to reformulate these categories. This extended time is absolutely necessary to accomplish wide-scale reformulations for over 1,700 different SKUs and was one of industry’s themes throughout this rulemaking. Conversely, the Specialty Coatings B categories, which theoretically do not have to be reformulated since they are being capped at the highest reportable reactivity value, must be compliant with the newly adopted standards by Jan. 1, 2015. The Table of MIR Values In this rulemaking, CARB also adopted the revised Table of MIR Values for use with the newly proposed reactivity standards for aerosol coatings. The most recent MIR Values, added to the Table on Oct. 2, 2010 represent the most scientifically accurate measurement of reactivity. It is appropriate that these values become the norm for compliance with the new standards and that manufacturers be granted the ability to use these values as soon as is possible. Use of these MIR Values has become a pivotal issue for the aerosol coatings industry and American Coatings Association has asked CARB to authorize use of the revised MIR values as quickly as possible in order to facilitate reformulation of the more than 1,700 products on the market in California. Other significant changes to the rule are the addition of several new categories including mold releases, electrical/ electronic/conformal coatings, rust converters, uniform finish blenders, two-component coatings and flexible coatings. The definitions of these new categories have been carefully crafted with assistance from the industry. The definition section also includes many refined definitions and newly added ones, such as resin, pigment, plasticizer, and extender, now included in the regulatory text. There were some changes made to the Aerosol Coatings Regulation to harmonize provisions with the Consumer Products Regulation, such as the sell-through, the sell-through notification provisions and the labeling requirements. Calculating the PWMIR for aerosol coatings formulas was addressed in these amendments as well. Due to problems confirming the PWMIR of formulas in the laboratory setting, CARB has provided some clarification of how to assign MIR Values to different categories of compounds (such as antimicrobials, fragrances and other compounds) and has included a “default value” for use of a compound that does not appear Table of Reactivity Limits Product-Weighted MIR in Grams Ozone per Gram Product (g O3 / g product) Aerosol Coating Category General Coatings 06/01/2002 01/01/2017 Clear Coatings 1.50 0.85 Flat Paint Products Coating 1.20 0.80 Fluorescent Coatings 1.75 1.30 Metallic Coatings 1.90 1.25 Nonflat Paint Products Coating 1.40 0.95 Primers 1.20 0.70 Specialty Coatings (A) 01/01/2003 01/01/2017 Auto Body Primer 1.55 0.95 Electrical/Electronic/Conformal Coating 2.00 Exact Match Finish: Automotive 1.50 0.95 Engine 1.70 0.95 Industrial 2.05 1.20 Flexible Coating 1.60 Ground Traffic/Marking Coating 1.20 0.85 Mold Release Coating 1.10 Two Component Coating 1.20 Uniform Finish Coating 1.30
SprayJan14
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