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 August 2016 CARB The California Air Resources Board (CARB) held a webinar on June 30 to review the July 1 start of the last phase of its consumer products survey, which is in its third and final year. The webinar was very well attended. This third phase of the survey began on July 1 and ends Nov. 1. It is extremely important that everyone complete this survey. The data is used to build a consumer product volatile organic compounds (VOC) inventory, which is used in the future to calculate emission reduction from any further VOC regulations that may be developed. As reported last month, CARB staff is developing its 2016 State Implementation Plan (SIP). This plan will guide staff in the next few years on future regulations for consumer products and other sources of VOC emissions. The survey data is used in several ways. First, the data is used to determine the amount of VOCs in each product category. Normally, these categories are then listed in order of quantity with the categories containing the largest amount of VOC at the top of the list. The second use of data is for accurate measurment of the amount of each VOC reduction from the category as regulations are developed. This is important to illustrate the consumer product contribution to overall VOC reductions. Currently, VOCs have been reduced by about 50% since VOC regulations started in the early 1990s. The last use of the data is to show the overall photochemical reactivity (the ability to create ozone) of consumer product. Consumer products have very low reactivity compared to other sources, such as cars and trucks. CARB staff acknowledged that consumer products have a lower reactivity than other sources. Hopefully, staff will begin to show consumer products emission not only in mass VOC quantities, but convert this to reactivity to show that the contribution to VOC formations is lower than other sources. The SIP will go to the CARB Executive Board for a vote on Sept. 22. The bottom line is that it is crucial to fill out the survey. Also, remember that CARB removed a significant number of product categories that do not need to be surveyed in this year’s survey. Review the list at: http://www.arb.ca.gov/consprod/regact/2013surv/2013main.htm VOC Limits Future effective limits become effective for Mist Spray Adhesives, Web Spray Adhesives and Screen Printing Adhesive on Jan. 1, 2017 in California. Also, the Aerosol Coatings General and Specialty Coatings (A) categories become effective on Jan. 1, 2017 in California. All of these limits will be difficult to meet. Remember that all products produced after Jan. 1, 2017 for sale in California need to be VOC compliant. Products made before Jan. 1, 2017 have a three-year sell-through period. SNAP On July 20, the new amendments to the U.S. Environmental Protection Agency (EPA) Significant New Alternatives Policy (SNAP) rule became effective. These new amendments drastically limit the use of HFC-134a in aerosol products in the U.S. Most consumer use of HFC-134a in aerosols has been prohibited; however, there are exceptions for certain aerosol products. In addition, all products manufactured before July 20 have a sell-through period. Canada Canada approved VOC exempt compounds in its Canadian Environmental Protection Act, 1999. Of the compounds approved, HFO-1234ze, HFO-1233zd and AMP were a few exempted. Review the list at: http://www.gazette.gc.ca/rp-pr/p2/2016/2016-06-15/html/sor-dors120-eng.php. Spray formulatedsolutions.com
Spray August 2016
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