www.aeropres.com
www.inhalant.org
dscontainers.com
diversifiedcpc.com
formulatedsolutions.com
ikimfg.com
mbc-aerosol.com
terco.com
Regulatory Issues
Doug Raymond
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray December 2017
California
On Oct. 15, 2017, California Governor Jerry Brown signed Legislative
Senate Bill (SB) 258, authored by State Senator Ricardo
Lara, Democrat for Bell Gardens. SB258 is the Cleaning Product
Right to Know Act and will require manufacturers of cleaning
products used in homes and commercial establishments to disclose
the ingredients in the product.
The intent of the bill is to provide consumers and workers with
ingredient information that encourages informed purchases and
reduces exposure to potentially harmful chemicals.
Products subject to this bill are air care products, automotive
products used for maintaining the appearance of motor vehicles,
general cleaning products or polish or floor maintenance product
used primarily for janitorial, domestic or institutional cleaning
purposes. Products not subject to the bill are food, drugs, cosmetics
or personal care products such as hand soap, shampoo, etc.
Also not subject to the bill are industrial products used specifically
in manufacturing.
Product subject to the bill must list specific ingredient information
on the label and more extensive ingredient information online. The bill does include confidential
business information protections. The ingredients that need to be disclosed are subject to a
long list of requirements and exceptions. I encourage you to review this bill in great detail at https://
leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB258
The disclosure of the ingredients needs to be on the label as well as available on the company’s
website. The online disclosure requirements will apply to products sold into the state on or after Jan.
1, 2020. The product label disclosure requirements will apply to products sold into the state on or
after Jan. 1, 2021. There is an unlimited sell-through for product labels produced prior to Jan.1, 2021,
provided the product is labeled with the day, month and year of manufacture of the product or a code
indicating the date of manufacture.
CARB
As explained last month, the California Air Resources Board (CARB) held a workshop on multi-purpose
lubricants. CARB staff asked for comments on its proposal to use a Reactivity Alternative Option.
If you are a manufacturer or Marketer of Multi-purpose lubricants, this affects your product. Your
company should comment on this proposal. Reactivity is a solid scientific way to regulate volatile
organic compounds (VOC) emissions and should be used more often for VOC limits in Consumer
Products. The next workshop will be in early 2018. Remember, the CARB hearing on this proposal is
scheduled for May 2018.
OTC Meeting
The next Ozone Transport Commission (OTC) meeting was scheduled for Nov. 15, 2017 in Washington
D.C. More on discussions concerning updating the Model Rule for OTC in the next issue.
Maryland
The Maryland Consumer Product Rule becomes effective on Jan. 1, 2018. The amendments to this rule
appear to be consistent with the OTC Model Rule. Review at http://mgaleg.maryland.gov/pubs/committee/
aelr/17-044P-Regulation.pdf
Connecticut
The Connecticut Consumer Product Rule becomes effective on May 1, 2018. The amendments to this
rule appear to be consistent with the OTC Model Rule. The rule can be reviewed at
https://eregulations.ct.gov/eRegsPortal/Search/getDocument?guid={6328F22C-C6FF-4371-8B34-
5CD7D821969D} Spray