California Aerosol Coatings Standards Continued on the Table of MIR Values. These provisions will assist the formulator in developing compliant products by eliminating some of the historical uncertainties. The Rulemaking Process These amendments to the Aerosol Coatings Regulation and the Table of MIR Values are the culmination of a rulemaking process that engaged all stakeholders, including formulators, applicators and environmental organizations. CARB was careful to begin this effort with a comprehensive survey effort in order to understand current aerosol coatings technology. 2 Throughout this rulemaking process, there was a continuing dialogue between the agency and all stakeholders. CARB invited comments, questions and discussion on all of these amendments. One of the initial events in this rulemaking process was a seminar that the industry developed for CARB staff—our goal was to educate those CARB staff members who would be evaluating the survey data and our presentation provided information about the aerosol dispensing container and technology, propellants and resin systems, and formulation processes that included all the testing that is required to bring an aerosol coatings product to market. Once the survey data was provided, our discussions moved to specific categories and specific provisions in the rule. While CARB was intent on gaining the maximum achievable emission reductions, the industry was focused on providing aerosol coatings products that continued to provide excellent performance characteristics. In the “push and pull” of these discussions, the final rule appears to be sound and, hopefully, will fulfill both of these goals. In 1998, when CARB adopted the initial reactivity standards for aerosol coatings, there were several witnesses that testified in opposition at the final Board hearing. This included the U.S. Environmental protection Agency (EPA), several aerosol coatings manufacturers and some in the consumer products and personal care industries. In stark contrast, at the Sept. 26, 2013 hearing, there were no witnesses in opposition. All those who testified were in support of the final rulemaking package, including a Southern California air district official. SPRAY 2 It is worth noting that the Air Resources Board initially conducted a survey of aerosol coatings in 2006. However, when it became clear that the response to the 2006 survey was inadequate, CARB was reluctant to develop a rule based upon insufficient data and an additional survey effort was conducted in 2010. 18 Spray January 2014
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