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Regulatory Doug Raymond Issues Raymond Regulatory Resources www.aeropres.com www.inhalant.org www.coster.com www.dscontainers.com www.diversifiedcpc.com www.gerstungaerosol.com www.ikimfg.com www.itwsexton.com www.mbc-aerosol.com www.precisepackaging.com www.rajones.com www.terco.com 8 Spray March 2013 This year is starting off very busily. We have the South Coast Air Quality Management District (SCAQMD) and California Air Resources Board (CARB) issue with low vapor pressue (LVPs). Now, SCAQMD will begin work on CTS-01, CTS-02 and CTS- 03. CARB has resumed work on its rule development currently scheduled for a July board hearing. Utah has started a VOC rule development on Consumer Products. Additionally, Canada has finally resumed its work from years ago on a rule development, and last but not least, the revised Green Chemistry Regulation has been released by DTSC. Busy, busy, busy! LVP issue The Low Vapor Pressure (LVP) volatile organic compound (VOC) issue is near and dear to most Consumer Products manufacturers. LVP VOCs will now be studied by CARB to determine if any change is necessary. This was the decision that came from the SCAQMD Air Quality Management Plan (AQMP). However, CARB, in its current rulemaking, is considering modifying the LVP-VOC definition for Multi-purpose Solvents and Paint Thinners in this year’s rule development. This change would be made before any studies could be started. This makes no sense. Industry should be appalled that the CARB staff would consider any wholesale changes to any category until the study that CARB management has agreed to do is done. I should not need to remind everyone, but if any category has the LVP-VOC provision removed, then consider what category will be next. Perhaps your product’s category will be the next category targeted. This is a very slippery slope. CARB Rule Development CARB had its most recent workshop on the rule development for Aerosol Coatings and Aerosol Adhesives on Feb. 26, in Sacramento, CA. Additionally, CARB will release its work on LVP-VOC for certain categories as discussed above. During this rulemaking, I encourage you to address any outstanding issues that you feel need modification while the rule is “open.” For example, the General Purpose Cleaner definition is vague as to all the products that the category encompassed. If you read this definition, it appears to encompass “kitchen cleaners.” However, this category encompasses all hard surface cleaners for home, office, schools, garages, institutions, etc. This is just one example. There are at least a half dozen more definitions that could use modification to make the definitions clearer to the regulated community and avoid undue enforcement actions. continued on p.31


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