www.aeropres.com www.inhalant.org coster.com dscontainers.com diversifiedcpc.com ikimfg.com mbc-aerosol.com terco.com Regulatory Issues Doug Raymond Raymond Regulatory Resources summitpackagingsystems.com 8 Spray April 2016 SCAQMD Big news! The California South Coast Air Quality Management District (SCAQMD) has announced more organizational changes. Barry Wallerstein, SCAQMD Executive Officer since 1997, was removed from office. Wallerstein had been the major push within the district to regulate Consumer Products at the district level. This change comes after the SCAQMD board voted in its seventh Republican board member in February. This is the first time since I started working with the SCAQMD Board in 1988 that there has been a conservative majority on the board. We will need to wait to see how this change affects SCAQMD. Last year, the Western Aerosol Information Bureau (WAIB) and the National Aerosol Association (NAA), with the assistance of the Consumer Specialty Products Association (CSPA), met with all SCAQMD Board members to explain our position on Consumer Product regulations being regulated solely by the California Air Resources Board (CARB) and not individual districts. To our surprise, many Board members mentioned a need for “balance” within SCAQMD. In other meetings last year with Wallerstein, there was an agreement that SCAQMD would let CARB know if there were any Consumer Product categories that SCAQMD was anticipating regulating. Hopefully, this arrangement will be maintained by the new Executive Officer. CARB A new addition to the CARB Executive Board is Dean Florez, who follows an earlier appointee, Diane Takvorian. This year, the aerosol industry is planning to meet with all the CARB Executive Board members much like we did with the SCAQMD Board members last year. These meetings get the industry’s message out and let us put a face to a name. This is a great time for such meetings, as there are no pressing activities at CARB, such as upcoming adoptions of volatile organic compound (VOC) reductions. These meetings also educate the new Board members at CARB on the past aerosol industry activities, not forgetting pending low vapor pressure (LVP) studies. The more the Board knows about our work, the better. CARB Survey As mentioned last month, CARB has released some information from the last two years of survey data. First, CARB has released a list of compounds used in Consumer Products. Please review this list and comment. CARB Staff has designated all the compounds as VOC, LVP or Exempt. If you make Consumer Products, then review this list carefully to make sure that the status you are using for your compound matches CARB’s status. For example, you may have information that shows a compound is an LVP but CARB may consider the same compound to be a VOC. This would not be good. Therefore, review the entire list. This is the aerosol industry’s opportunity to get the status of each compound correct. Second, CARB listed down-the-drain and alternative fates for numerous categories of products. Obviously, many products are disposed of down the drain, such as toilet bowl cleaners, etc. However, we need to also think about alternative fates. For example, brake cleaners used in a shop are collected and disposed of. Therefore, a certain portion of brake cleaner emissions should be removed from overall inventory because these emissions are not released to the air. Again, please review this document and provide comment. If you are uncomfortable commenting to CARB, send your comments to me; I will be happy to submit the comments for you. Remember this is our opportunity to comment and get the record right. Let’s not waste it! OTC Delaware has finalized its Ozone Transport Commission (OTC) rule and the effective date is 1/1/2017. It is the latest OTC Model Rule. Maryland plans to move ahead with its Consumer Products rule (OTC Model Rule), with its first meeting sometime in late March or early April. Maryland is planning a 1/1/2017 effective date and the rule has not even started. We need to ask for the effective date to be delayed. Spray formulatedsolutions.com
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