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 June 2014 Regulatory Issues DOUG RAYMOND Raymond Regulatory Resources CARB, SCAQMD and Environmental Regulations CARB The 15-day changes notice was released on April 3 and ended on April 18. Remember, this was the next step in the California Air Resources Board’s (CARB) effort to finalize the September 2013 amendments. Now that the notice period is over, the CARB staff will begin finalizing the amendments. They hope to have their review done by the end of May. Next, the amendments will be sent to the Office of Administrative Law (OAL) for completion. No definite time has been set for the amendments to be finalized. Hopefully that will come this summer. Survey CARB staff is working on releasing a new comprehensive survey for multiple categories. It is attempting to get an updated product inventory to use in future rulemakings. On May 21, CARB held a workshop on the details of this survey with stakeholders. CARB staff plans to review, in detail, the format and requirements for this survey and will be asking for more specific information on products in this survey then ever before. In addition, staff is requesting that all information be supplied electronically. There is no exact timing yet on when this survey will be released. CARB is pushing for earlier rather than later, but Industry is hoping for a delay due to significant other activities such as changes in the Globally Harmonized System (GHS). More on the May 21 meeting in the next issue. SCAQMD On April 17, the South Coast Air Quality Management District (SCAQMD) had another workshop on proposed amendments to Rule 1168 Adhesives & Sealants. This is the rule in which SCAQMD is proposing to regulate Consumer Product Adhesives & Sealants. One of the new categories to be regulated is Aerosol Foam Sealants. Finally, in this workshop, SCAQMD changed their proposed emission reductions from 3.7 tons per day to 0.5-0.9 tons per day. Their estimate is still far too high. CARB’s data shows an estimate of 0.4 tons per day for the whole state. Adoption has been delayed until September. SCAQMD amended Rule 102 definitions on May 2. The only change was to add HFO-1233zd to the list of exempt compounds in the VOC definition. On the day before the hearing, one person opposed the full exemption of the compound, requesting that it be restricted for use in foam blowing and aerosols. The National Aerosol Association (NAA) and Honeywell opposed these restrictions and SCAQMD adopted the definition without restrictions. However, the board instructed staff to review the compound for the additional uses and return back with any restrictions that are needed. Thus, more work will need to be done. Nothing is ever easy with SCAQMD. OTC On April 10, 2014, the Ozone Transport Commission (OTC) held a meeting in Washington, DC, wherein the U.S. Environmental Protection Agency (EPA) reported on Consumer Products. The OTC stated that a request has been sent to the EPA to update the National EPA Consumer Products regulation with the OTC model Regulation. EPA The EPA is proposing to amend its Significant New Alternatives Policy (SNAP) program for several categories this summer, including aerosols. Industry has met with the EPA twice this year to discuss this rule. The EPA, among other issues, is proposing to delist HFC 134 in Consumer Aerosols. Industry needs to inform the EPA of all issues with this change. The NAA and Consumer Specialty Products Association (CSPA) are working cooperatively on this rule to provide a technically feasible outcome on this regulation. Feel free to contact us with any issues. Green Chemistry On May 7, the Department of Toxic Substance Control (DTSC) held its first workshop on its Initial Priority Products list in Sacramento, CA. In attendance were about one hundred people. The Priority Products and Candidate Chemicals are: • 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 After the DTSC, staff presented its initial information on the program, stating that no decisions have been predetermined. The workshop was then broken up into groups for each of the priority products. The foam group was the most vocal group, stating that because of the way DTSC has presented the Priority Products list, its businesses have been negatively impacted. Numerous participants made these statements. In addition, DTSC is asking for data on sales of products, where products are sold, how products are used and product chemistry. I was amazed at how much information DTSC is requesting on foams and paint strippers, given that these products are targeted. This provides the Industry with an opportunity to work with DTSC on this rule. SPRAY
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