Regulatory Doug Raymond Issues Raymond Regulatory Resources www.aeropres.com www.inhalant.org www.coster.com www.dscontainers.com www.diversifiedcpc.com www.ikimfg.com www.itwsexton.com www.mbc-aerosol.com www.precisepackaging.com www.terco.com 8 Spray June 2013 California Air Resources Board (CARB) issues remain the topic of the industry. On April 24, CARB staff held a workshop to discuss amendments to the Consumer Products VOC regulation. CARB amendments to volatile organic compounds (VOC) standards are focused on two product categories: Aerosol Coatings and Aerosol Adhesives. Remember, most of the Specialty Coating limits were capped at the highest levels that were reported. They are proposed to be effective on 1/1/2015. Other Specialty Coatings Categories were added at relatively high levels as well; the proposed effective date is 1/1/2017. One major change is that every aerosol coating will be included in this regulation unless specifically exempted. This means that if your product meets the definition of an aerosol coating, then the product needs to be placed in one of the categories. Make sure if the product is a specialty coating that the product displays claims only for that category or the product will be subject to the Most Restrictive limit provision. In addition, numerous definitions were added into the The following are the MIR Limits for the General Aerosol Coatings Categories. These limits are proposed to be effective on Jan. 1, 2017 Current CARB Original CARB Current PWMIR Proposal Proposal Clear 1.50 0.80 0.85 Flat 1.20 0.80 0.80 Ground Traffic/Marking 1.20 0.80 0.85 Fluorescent 1.75 0.80 1.30 Metallic 1.90 1.25 Non-Flat 1.40 0.80 0.95 Primers 1.20 0.60 0.70 Auto Body Primers 1.55 0.95 0.95 Exact Match Finish Engine/Automotive Industrial 1.70/1.50 0.90 0.95 2.05 0.90 0.95 Aerosol Coating regulations such as Resin, Coating Solid etc. Again, please review this regulation. Remember, all other Specialty Adhesives are unchanged. These limits are very low; however, CARB states that these limits are technologically feasible. The big news is that CARB staff has significantly modified their proposal to remove the changes to the LVP-VOC definition. This is a welcome change. Industry was concerned with any changes to the LVP-VOC definition until the scientific studies have been completed. In March 2013, CARB Executive Board voted to consider studies on the The following are the proposed limits for Aerosol Adhesives LVP-VOC topic. Later in May 2013, CARB Scientific Committee reviewed the proposal on the LVP-VOC research. The Executive Board will likely vote in June to approve work on these studies. Again, this was a significant and positive change to the proposal. Scientific research on the LVP-VOC issue is needed before any changes should be made. In addition, changes to the Multi-purpose Solvent and Paint Thinner categories were made. The changes affects how these two product categories can be sold in the South Coast Air Quality Management District only. This is consistent with the District Rule 1143. In addition, a 10% limit has been proposed for Aerosol Multi-purpose Solvents and Paint Thinners. Category Current CARB CARB VOC Limit 1st Proposal Current Proposal Mist Spray 65 30 30 Web Spray 55 30 40 Screen Printing Adhesive 55 www.montebellopkg.com continued on p.38 CARB
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