Regulatory Issues Doug Raymond Raymond Regulatory Resources www.aeropres.com www.inhalant.org www.coster.com www.dscontainers.com www.diversifiedcpc.com www.ikimfg.com www.itwsexton.com www.mbc-aerosol.com www.montebellopkg.com www.precisepackaging.com www.terco.com CARB On Sept 26, 2013 The California Air Resources Board (CARB) held an Executive Board hearing to adopt amendments to the Consumer Products regulation and to the Aerosol Coating Products regulation. The formation of these amendments has been in development for over two years. Some of the highlights for the Consumer Products regulation are the following: 8 Spray November 2013 • HFO-1234ze was added to the list of exempt volatile organic compounds (VOC) compounds in the state of California for Consumer Products. • There were changes to several lubricant definitions that clarify the categorization of several products. Most importantly, Dry Lubricants; Gear, Chain and Wire Lubricant; and Multi- purpose Lubricant definitions were modified. • There was an addition of Single Purpose Cleaner and Degreaser definitions. The addition of these two definitions clarifies the use of products that are used for a single purpose and are not general-purpose products. • The delay of the 10% VOC limit for Multi-purpose Lubricant from 12/31/2015 to 12/31/2018 will provide industry time to meet this stringent future effective limit. • Changes to the Hair Spray definition should clarify the issues for this category. • New Spray Adhesive limits will be very difficult to meet. Industry will have a challenge to meet these limits. • Likewise, the new Multi-purpose Solvent and Paint Thinner limits in the South Coast Air Quality Management District (SCAQMD) will be very challenging. Product efficiency will likely be degreased. • Remember, there are new VOC limits for Aerosol Multi-purpose Solvents and Aerosol Paint Thinners. For the Aerosol Coating Product Regulations there are too many changes to highlight. If you make Aerosol Coatings, I highly recommend that you review this regulation closely: • The biggest change is that all products meeting the definition of aerosol coatings are regulated by this regulation unless specifically exempted. This means review product labels closely and make sure claims represent the appropriate category for your product. • There are numerous changes and additions to definitions; please review to make sure you understand the changes. • There are numerous changes to VOC limits; start reformulation of products now. Industry is still working with CARB on the effective date of 2010 MIR values that will be used for the future effective limits. Remember, some limits are effective 1/1/2015 and others are effective 1/1/2017. Now that the board has approved these amendments, CARB can begin to prepare for finalization of these amendments. The amendments need to be submitted to the Office of Administration Law (OAL) before the amendments become final. In the meantime, CARB will continue working on new issues. Industry will need to closely monitor the low vapor pressure (LVP) research work. In addition,CARB will be starting work on a new and comprehensive product survey, so stay tuned. Review these at http://www.arb.ca.gov/regact/2013/cp2013/cp2013.htm, Appendix B & C. OTC updates New Hamsphire began work in October to update their state rule with the new Ozone Transport Commission (OTC) model rule. As this rule progresses, we will keep you informed. OTC continues to push the U.S. Environmental Protection Agency (EPA) into making this new OTC model rule a national rule. Continued on page 53
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