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www.aeropres.com www.inhalant.org www.coster.com www.dscontainers.com www.diversifiedcpc.com www.mbc-aerosol.com www.montebellopkg.com www.precisepackaging.com 8 Spray January 2014 Regulatory Issues Doug Raymond Raymond Regulatory Resources www.ikimfg.com www.terco.com Wishing everyone a Happy & Prosperous New Year! CARB The California Air Resources Board (CARB) continues to work on finalizing the amendments to the Consumer Products and Aerosol Coating regulation. The fifteen-day notice should be released around the first of the year. After comments are made and CARB staff finalizes the rule, the next step is to send the rule to the Office of Administrative Law (OAL) for review. OAL has thirty days to comment then submit the rule for finalization. If everything goes well, this will all be done by the end of the first quarter. LVP Research In addition to this work, the research division is working on the low vapor pressure-volatile organic compound (LVP-VOC) study. The final list for testing has been set. Below are the compounds that will be in the LVP-VOC study. LVP-VOCs for Chamber Study Chemical Class LVP-VOC Compounds Comments Glycol Diethylene Glycol Propylene Glycol Glycol Esther Diethylene Glycol Ethyl Ether (DEGEE) Diethylene Glycol Monobutyl Ether butoxyethoxyethanol) Hydrocarbon Solvent Iso-paraffinic Hydrocarbons Example: Isopar M Aromatic HC Mixture Example: Aromatic 200 Predominantly Cyclo-paraffinic HC Example: Conosol C-200 n-Tridecane (C13) n-Heptadecane (C17) Esters Dimethyl Glutarate Methyl Palmitate Other Triethanolamine Glycerol Next, CARB research will review formulations of products with each of these compounds in them. CARB will also review different categories of products for different use patterns. For example, some products are used where a majority of the product is not emitted into the atmosphere. One example is products that are routinely washed down the drain, such as cleaners. The VOCs from these products are likely not emitted as a result of being in contact with water and processed through a sanitation plant. The next call with the CARB research division will be in early January. If your company relies on LVP-VOC for your formulations, you need to pay specific attention to CARB’s LVP-VOC study; the outcome could have a significant effect on your product. Product Dating/Date coding Date code information needs to be reported to CARB every year by your company if you do not use CARB’s standard date coding. California Section 94512 (b) product dating specifically requires all consumer products to be sold into the state to display the day, month and year the products was manufactured or a code indicating the date. CARB has been increasing their activity on investigating and levying fines for non-compliance of this section. The date or date-code information shall be located on the container or inside the cover/cap so that it is readily observable or obtainable (by simply removing the cap/cover) without irreversibly


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