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Regulatory www.aeropres.com Doug RaymonD Issues Raymond Regulatory Resources www.inhalant.org CARB On Sept. 12, California Air Resources Board (CARB) staff held their first workshop on proposed amend- ments to the Aerosol Coating regulation and the Consumer Products Regulation. CARB is targeting lower Maximum Incremental Reactivity (MIR) limits for Aerosol Coatings and lower Volatile Organic www.coster.com Compounds (VOC) limits for Aerosol Adhesives. Both sets of limits were detailed in last month’s article and are currently on the CARB website at http://www.arb.ca.gov/consprod/regact/2013/2013ra.htm. Comments were due by Oct. 10. However, this rulemaking will be in progress until next June. Therefore, I suggest you continue to review your products and provide comments if you did not already do so. www.dscontainers.com Highlights of the workshop are the following: • The largest turnout to a CARB workshop in over a decade. • As predicted, the LVP-VOC issue received the most attention, with a significant amount of discussion. Non Government Organizations (NGOs) and the South Coast Air Quality Management District (SCAQMD) voiced their opinion that the LVP-VOC provision should be eliminated or modified. Industry provided compelling reasons for the LVP-VOC provision www.diversifiedcpc.com to stay in place and untouched. If any modification is done to the LVP-VOC provision, even in one category, a bad precedent will have been set. It was clear at the meeting that NGOs and SCAQMD will push hard on CARB to change the LVP-VOC provision. Remember, this provision is the basis for the majority of the VOC limits currently in place for the product categories. Modification to the LVP-VOC provision will cause issues with technical feasibility www.gerstungaerosol.com of the VOC limits. If you are not involved with this issue, you need to be! Contact your as- sociation or give me a call. This is a very important issue. • CARB wants to change or modify Most Restrictive limit for Multi-purpose Solvent & Paint Thinners. There is no basis for this change, other than pressure from SCAQMD. The products in question are complying with the regulation. • CARB is proposing to regulate Aerosol Paint Thinner. To date, no VOC limit proposed other www.ikimfg.com than the current limits for that category. • CARB proposes to include the word “Plastic” back into Rubber/Vinyl Protectant. If you make these products, this is a significant change. • CARB is proposing changes to Hair Spray and Hair Styling products. Closely monitor this if you make these products. • Lastly, CARB is considering VOC exemption for HFO-1234ze. Finally, something we can www.itwsexton.com support. CARB did share the information for the workshop approximately one week before it took place; this gave industry some time to review. By providing this information ahead of time the meeting was more successful. Again, this is a process, get involved! Make sure your products are compliant. Aerosol www.mbc-aerosol.com SCAQMD SCAQMD is preparing their Air Quality Management Plan (AQMP). Remember, there are four provi- sions that affect Consumer Products: CTS 01–CTS 04 (CTS 04 being the provision that proposes to eliminate or modify the LVP-VOC provision). www.oystar-group.com The good news is that SCAQMD has once again delayed the hearing on this, with the proposed adoption date now set at Dec. 7. If you have not commented on this plan, now is the time. SCAQMD wanted comments by Oct 5. You need to make time and get these comments in. SCAQMD should not have this provision in their AQMP, as it has no authority over Consumer Products and should defer to CARB on this issue. Get your comments in and prepare to go to the Dec. 7 meeting. We need everyone’s support on this! www.precisepackaging.com Green Chemistry The Dept. of Toxic Substance Control (DTSC) wanted comments on their Safer Consumer Prod- ucts Regulation by Oct. 11, 2012. Finally, there appears to be some opposition to this regulation from legislators in California; this opposition is based on the potential cost to everyone if this regulation is not significantly modified. Hopefully, this regulation will be changed and made to be constructive and www.terco.com workable. Stay tuned. 8 Spray November 2012


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