www.aeropres.com www.inhalant.org coster.com dscontainers.com diversifiedcpc.com ikimfg.com mbc-aerosol.com precisepackaging.com terco.com 8 Spray February 2015 Regulatory Issues Doug Raymond Raymond Regulatory Resources CARB Consumer Product Survey: Time to get moving... summitpackagingsystems.com CARB Survey By now you should be working on your California Air Resources Board (CARB) Consumer Product Survey. This very comprehensive survey needs to be completed by March 1, 2015. Some of the items that need to be included in this survey are products sold into California for sale in California in 2013, as well as all formula data, which means that 100% of the formula needs to be included in the survey. In addition, the ability to group products into a single entry has been greatly reduced. This means more entries to the survey. If you have not started on the survey you need to begin soon! Remember, the better the data that is submitted, the better rules we can develop. On Feb. 4, CARB staff plans to have a webinar from 10am–1pm PST to respond to any questions to the 2013 Consumer & Commercial Products Survey. Questions on data upload, upload portal and reporting tools are welcome. Registration for the webinar is available at: https://attendee.gotowebinar.com/register/119958100 LVP Research studies on Low Vapor Pressure (LVP) compounds are currently being funded by CARB to determine if they contribute significantly to ground level ozone. Remember, LVP compounds have been the avenues for compliance with the strict volatile organic compound (VOC) limits that CARB has developed since the mid to late 1990s. LVP compounds are not counted toward the total VOC content for compliance with VOC limits. Any change to the LVP compound definition that would change or restrict the use of LVP compounds could mean that the current VOC limits are not technologically feasible as required by California law. Currently, there are ongoing studies at the University of California, Riverside and the University of California, Davis. These studies will likely be finished in 2016. Industry needs to monitor these studies and provide feedback to CARB on this issue. Stay tuned for updates. As stated above, any change to the LVP definition will have a substantial impact on current formulas. VOC limits New Aerosol Coating product limits became effective for the Specialty Coating Categories (B) on 1/1/2015. A VOC limit for Multi-Purpose Solvent and Paint Thinner Aerosol will become effective 1/1/2016; this new VOC limit is 10% by weight. On 1/1/2017, Mist Spray Adhesive will have the VOC limit reduced from 65% to 30%—this is a significant drop. The Web Spray Adhesives VOC limit is reduced from 55% to 40%—another big drop. Companies with these products need to begin reformulating now to determine if these VOC limits are technologically feasible; if the reformulations are not possible, then CARB needs to be notified. Also, on 1/1/2017, all the new Aerosol General Coating limits and Specialty Coatings (A) VOC limits become effective. Some of the VOC limit changes are significant. Companies making these products should review these limits and begin work on reformulation. Green Chemistry The Dept. of Toxic Substance Control (DTSC) will likely begin rulemaking on its initial list of Priority Products and Chemicals of Concern. It was in March 2014 when DTSC first announced the following products and chemicals of concern: • Spray Polyurethane foam (SPF) with unreacted diisocyanates • Children’s foam padded sleeping products containing tris (1,3-dichloro-2propyl) phosphate • Paint and Varnish Strippers with Methylene Chloride. DTSC will likely start on the formal rule development in the first or second quarter of 2015 on these priority products. SPRAY
Spray Feb 2015
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