Up to the Challenge The EAA examines regulatory issues at its Spring Meeting The Eastern Aerosol Association (EAA) convened in Mahwah, NJ for its Spring Meeting. The topics were divided into two specialized areas of specialty: Regulatory and Raw Materials Feed Stocks (for Raw Materials Feed Stocks, see p. 18). ARR Coordinating Industry Efforts on LVP Issues was presented by Adam Selisker of CRC Industries and ARR Treasurer. The Alliance for Responsible Regulation (ARR) was formed to articulate the legal, technical and scientific reasons why the proposals are flawed and could have devastating impacts on the consumer products industry. It promotes facilitating the sharing of information, developing coordinated strategic advocacy efforts, coordinating legal and scientific review and analysis of the proposals and supporting documents by participating organizations as well as fundraising to support outside legal and scientific review. The ARR is governed by a volunteer Selisker Dolegiewitz 26 Spray June 2013 Executive Board and facilitated by CSPA staff. It is not a lobbying entity. Participating trade associations and member companies are responsible for execution of the strategies as well as their own advocacy efforts. In 2012, activities included a coordinated plan for strategic industry advocacy efforts, the development of an ARR Science Team to support advocacy efforts and a fundraising effort to support ARR activities. In 2013, activities will include continuing advocacy on the revised 2013 Draft Amendments to the CARB Consumer Products Regulation; participation at CARB workshops; coordinated advocacy meetings with CARB staff; facilitated comments on CARB proposed research; the initiation of an ARR Science Team and industry research plan; briefing SCAQMD and CARB staff on industry research; collaborating with CARB staff on research plans and participating in Research Steering Committee discussions. This is not just an aerosol issue and not just a California issue, stressed Selisker. Proposals developed in California often gain traction in other states and the CARB proposals could result in a new national definition of LVPs and VOCs. The ARR needs to fund critical research and possible legal challenges. Participating ARR trade associations include Adhesives & Sealants Council; American Coatings Assoc.; American Chemistry Council; American Cleaning Institute; Automotive Specialty Products Alliance; Consumer Specialty Products Assoc.; Eastern Aerosol Assoc.; International Fragrance Assoc. North America; International Sanitary Supply Assoc.; Midwest Aerosol Assoc.; National Aerosol Assoc.; Personal Care Products Council; and Western Aerosol Information Bureau. GHS Timothy Brown, Regulatory Counsel, Consumer Specialty Products Assoc. (CSPA) presented Global Harmonization. The Globally Harmonized System for Hazard Communication (GHS) is a system that defines and classifies the hazards of chemical products and communicates health and safety information on labels and safety data sheets (SDS). Hazard groupings include Physical Hazards, Health Hazards and Environmental Hazards. GHS’ goals are to promote regulatory efficiency; facilitate trade; provide consistent information across borders; and encourage safe transport, handling and use of chemicals. Classes within Physical Hazard include flammable aerosols; flammable gases; gases under pressure; explosives and oxidizing gases, liquids and solids. In 2012, OSHA modified only the necessary provisions of the Hazard Communication Standard to align with GHS; the basic framework remains the same. Major changes include Information and Training; Hazard Classification vs. Evaluation; Labeling; and SDS. The CSPA has developed a GHS Compliance workshop with various agency representatives (OSHA, EPA, CPSC) to answer member questions. The second workshop on the training component is currently being planned. OSHA Ed Dolegiewitz, Director of Safety Engineering at L’Oreal, presented OSHA Inspections. Occupational Safety & Health Administration (OSHA) inspections can be conducted without advance notice, either on-site or by phone/fax. OSHA cannot inspect all seven million workplaces it covers each year; therefore it conducts its inspections on the most hazardous workplaces by priority: imminent danger; catastrophes; worker complaints/referrals; targeted inspections high injury/illness rates, severe violators; and follow-up inspections. Planned investigations (inspections aimed at specific high-hazard industries or workplaces that have experienced high rates of injury/illness) also receive priority. Prior to an onsite inspection, OSHA compliance officers research the operations and inspection history of a worksite using various data sources. They wear appropriate personal protective equipment and use testing instruments to measure potential hazards. They present credentials, explain why OSHA selected the workplace for inspection and describe the scope, procedures and employee interviews. The employer selects a representative to accompany the compliance officer during the inspection. The compliance officer and company representatives then walk through areas of the workplace covered by the inspection, looking for hazards that could lead to employee injury or illness. Compliance officers may point out some apparent violations that can be corrected immediately. While the law requires that these hazards must still be cited, prompt correction is a sign of good faith on the part of the employer. Records reviewed may include internal and external safety and health inspections; maintenance records for all on-site equipment; forklift records; exhaust system tests; medical monitoring; hearing tests; and health monitoring for employees who use a respirator. Other regulations under review may include process safety; storage of hazardous materials; evacuation drills; means of egress; emergency teams training and drills (fire, spill, first aid, evacuation, continued on p. 45 Spray Publisher Cindy Hundley (left) receives the EAA Recognition Award from EAA President Chris Nyarady of Montebello Packaging. Hundley is the only remaining original EAA Board member.
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