Promoting & protecting the aerosol industry in state capitals across the nation… The Consumer Specialty Products Association (CSPA) and its member companies and allies have worked on some current priority policy issues for many months and, in some cases, many years. Issues often evolve over time as various stakeholders engage with legislators and regulators. Consumer Specialty Products Association (CSPA) Sustaining advocacy efforts is critical in addressing these issues. 2013 brings continued efforts on a number of ongoing issues and emerging issues of interest to the aerosol industry. From the initial development of the California volatile organic compounds (VOCs) regulation of consumer products and continuing over the past 20+ years, CSPA and allies have collaboratively worked with the California Air Resources Board (CARB) to develop appropriate standards protective of health and the environment that are commercially and technically feasible. While manufacturers have always risen to the challenge, it has become increasingly difficult as the standards have been ratcheted down. A new wrinkle in this issue arose in 2012 when CARB and the South Coast Air Quality Management District (SCAQMD) announced plans to regulate low vapor pressure (LVP) compounds. Collective industry advocacy efforts were successful in getting a proposed LVP control measure removed from the 2012 SCAQMD Air Quality Management Plan and seeking additional research on the potential contributions of LVPs to ozone formation. CSPA will continue to negotiate new VOC regulations for consumer products in various states, including California’s 2013 Amendments and a new Utah regulation, and will also be engaged this year in scientific research on LVP compounds with CARB and the update to the California State Implementation Plan. Other key initiatives will include working with retailers on VOC compliance assurance, and joining with Ozone Transport Commission states to recommend updates to the EPA’s National Consumer Products Regulation. CSPA has also taken a front seat in the multi-year development of the California Safer Consumer Products regulation, which is part of the state’s Green Chemistry Initiative. 18 Spray March 2013 By CHRIS CATHCART, President & CEO, The regulation, which, when implemented, will require manufacturers to prepare and submit an assessment of alternatives to certain priority chemicals of concern in selected products, has been in development for over four years. CSPA has actively engaged in the rule making process, participating in coalition activities in policy development, advocacy and legal review. The ninth iteration of the regulation was released in late January, and while some industry concerns were addressed, concerns remain with the new public comment provisions on the alternatives assessments. The state of Washington and seven other states (CA, CT, MA, MI, MN, NY, OR) are developing guidance to “help transition to safer chemicals.” The technical assistance is taking the shape of twelve individual modules on topics ranging from hazard evaluation to exposure considerations. CSPA is working with other interested parties to review and respond to the guidance documents as they will certainly be the template used by the initiating states and others for alternatives assessments. CSPA also has been active in recent years seeking to assure that the growing pressure for ingredient communication does not result in state or federal mandates that cause a loss of confidential business information. Many CSPA members are engaging in voluntary ingredient communication, and CSPA has developed the CSPA Consumer Product Ingredients Dictionary to facilitate their efforts. CSPA members are active on these and other issues through participation in numerous CSPA committees and task forces. The considerable time and effort spent in reviewing and analyzing issues of critical importance helps develop and inform the scientific and legal review and advocacy efforts. Oftentimes, the issues progress over the course of years from an initial concept introduced by a legislator to the ongoing implementation of the law by a regulatory agency. Sustained involvement by all interested parties is critical to promoting and protecting the industry. With 25 new member companies aboard to support CSPA’s mission, 2013 will bring new and continuing issues to engage and advance the aerosol industry. SPRAY
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