www.aeropres.com www.inhalant.org www.coster.com www.dscontainers.com www.diversifiedcpc.com www.mbc-aerosol.com www.montebellopkg.com www.precisepackaging.com 8 Spray March 2014 Regulatory Issues Doug Raymond Raymond Regulatory Resources www.ikimfg.com www.terco.com BOV labeling, EPA proposals, and a slippery slope in Southern California comprise the regulatory outlook for 2014 and beyond.... Weights & Measures Update On Jan. 20-21, the National Conference of Weights & Measures (NCWM) held a meeting in Albuquerque, NM. During this meeting, the Laws & Regulations (L&R) committee held its Open Hearings, when any interested stakeholder could comment on current amendments. Comments were made on the Bag-on-Valve (BOV) labeling issue and whether BOV containers should label products using volume or weight to declare contents. During an earlier January meeting held by the National Institute of Standards & Technology (NIST), industry believed there was a consensus to label BOV by weight, the same as traditional aerosols. However, two days before the meeting, two letters opposing the weight declaration were received. During the Open Hearings, however, all comments were in favor of declaring the contents of a BOV container by weight. Later in the meeting, the L&R committee met in a closed meeting and voted to move the BOV debate to a voting issue at its June meeting. Thus, Weights & Measures will vote on this issue in June and the standard will be effective January 2015. At present, it appears that the L&R committee will vote to have the contents of BOV containers declared by weight. Still to be determined is the sellthrough period. More to come after the June meeting. SNAP Meeting On Feb. 4, the U.S. Environmental Protection Agency (EPA) held a meeting to discuss changes to its Significant New Alternatives Policy (SNAP) Program. There are several changes proposed for refrigerants that will likely be put in place in 2014 with various effective dates. The EPA is proposing to make changes to Consumer Aerosols as well, possibly including the delisting of HFC-134a, HFC- 227ea and HFC-125 for use in non-medical and non-technical aerosols. If the EPA delists these compounds, they can no longer be used in aerosols. The EPA believes the timing for this change will be proposed in the summer of 2014. No effective date was given. In addition, there currently is no official definition of non-technical aerosols. The EPA is asking for comments on this issue sooner rather than later. Industry needs to review its uses of these chemicals and comment to the EPA. CARB The California Air Resources Board (CARB) still has not released its 15-day comment notice, which is needed to finalize its Board action of September 2013 on the Consumer Products and Aerosol Coating regulation. The amendments need to be finalized now that it is 2014. Industry needs the clarification that these amendments will provide. Currently, Industry is apprehensive about working under the amendments before they become law. In past rulemakings, CARB Enforcement has not enforced against any changes made by the executive board at the hearing. Once the 15-day comment period is over, the Office of Administrative Law can finalize the amendments for use by the Industry. SCAQMD 1168 South Coast Air Quality Management District (SCAQMD) is amending rule 1168 on Adhesives & Sealant products and is again trying to regulate consumer products. In its latest draft, SCAQMD has stated that its rule 1168 is applicable to all adhesives and sealants, which are consumer uses that are not currently regulated with a VOC limit in the CARB regulation. This is a horrible precedent. If readers recall, when SCAQMD went after Multi-purpose Solvent & Paint Thinners, I stated that this could spread to other categories. Well, here we go! SPRAY
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