www.aeropres.com www.inhalant.org www.coster.com www.dscontainers.com www.diversifiedcpc.com www.ikimfg.com www.mbc-aerosol.com www.montebellopkg.com www.precisepackaging.com www.terco.com 8 SPRAY July 2014 Regulatory Issues DOUG RAYMOND Raymond Regulatory Resources CARB, SCAQMD and Environmental Regulations CARB The California Air Resources Board (CARB) September 2013 Amendments are still not finalized by CARB staff. The 15-day comment period has come and gone. CARB staff has indicated that the amendments will be finalized soon. Therefore, we will just need to wait for the staff to finalize these amendments, which include limit changes and definition changes. Some of the volatile organic compound (VOC) limits are effective on 1/1/2015 for Aerosol Coatings. Survey CARB staff is proposing to release a very comprehensive survey on all categories of Consumer Products. CARB held a workshop in May concerning survey details. There were numerous Industry comments on the survey design and information requested. One of the largest issues was the security of this confidential information located in one spot. In addition, the staff is asking for information on all products. Very little grouping is allowed. Thus, all color and fragrance variations of our products will need to be reported. Also, all compounds need to be reported down to 0.1%. These are just some of the changes. Lastly, staff is requesting that all information be reported electronically using a program that some industry members are finding hard to access. CARB has proposed that the next workshop will be in early July, but no notice of the workshop has been released as we go to print. CARB wants to release this survey in August. Industry is requesting a delay until later in the year or possibly next year. Green Chemistry The Dept. of Toxic Substance Control (DTSC) finished its three workshops on its Priority Product list on June 4. DTSC has proposed the following Priority Products and Candidate Chemicals: • Spray Polyurethane Foam (SPF) Systems containing unreacted diisocyanates • Children’s Foam Padded Sleeping Products containing Tris (1,3-dichloro-2-propyl) phosphate or TDCPP • Paint and Varnish Strippers and Surface Cleaners with methylene chloride DTSC had high attendance at the two workshops I attended. The Spray Foam Industry was out in force on this issue. The DTSC asked interesting questions concerning the use and magnitude of products sold. One would think that DTSC would know this information already before picking these products as Priority Products. DTSC had requested all information be sent to them before June 30, 2014. This will be a long process, as DTSC is to finalize these priority products by October of this year. The process will likely take a year to finalize after that. Following, companies affected will need to begin to produce Alternative Assessments (AA) on their products. These AA could be very expensive to produce. The next step is to submit comments. SCAQMD South Coast Air Quality Management District (SCAQMD) is still working on Rule 1168–Adhesives and Sealants. Rule amendments currently proposed would adversely affect any consumer use of Adhesives and Sealants that do not have a CARB VOC limit. In addition, this will set a very bad precedent for the future. The Western Aerosol Information Bureau (WAIB) and National Aerosol Association (NAA) are actively working in the state of California with SCAQMD, CARB and the California Legislature to maintain the regulation of Consumer Products with CARB as statewide rules. This is a very important issue. Statewide Consumer Product rules are essential for the Industry. In addition, SCAQMD is proposing amendments to two new regulations: Rule 1151 on Automotive Refinish Coatings and Rule 1113 on Architectural Coatings. The good news here is that Aerosol Coatings can only be regulated by CARB. That is California state law! EPA The U.S. Environmental Protection Agency (EPA) continues to move forward on amendments to its Significant New Alternatives Policy (SNAP) program. Amendments will include delisting HFC-134a from aerosol use. Industry is working with EPA to develop a definition for Technical Aerosols, which will need to maintain the use of HFC-134a for the foreseeable future. EPA has sent its proposed rule to the Office of Management & Budget (OMB); after a review, the EPA can propose the rule to the public. Therefore, time is short to get comments in before the rule is released; it could be proposed this month. SPRAY
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