www.aeropres.com www.inhalant.org coster.com dscontainers.com diversifiedcpc.com ikimfg.com mbc-aerosol.com precisepackaging.com terco.com Regulatory Issues Doug RaymonD Raymond Regulatory Resources CARB Enforcement Manager retires; leaves gap summitpackagingsystems.com 8 Spray February 2016 While agencies have not moved their activities into full swing yet, there is one new development of interest I would like to share. CARB The California Air Resources Board (CARB) had a retirement as of Dec. 31, 2015. Steve Giorgi, Manager of Consumer Product Enforcement, retired at the end of last year. Giorgi was well respected by his fellow personnel at CARB as well as by the consumer products industry. He had a reputation for being fair and distributing fines evenly and equally. During my first experience with Giorgi in his enforcement role, he stated that he wanted to treat all companies fairly and maintain an equal “playing field” for the industry. Unfortunately, I have had more than my fair share of opportunities to interact with Giorgi on my clients’ behalf. To my knowledge, he treated everyone equally (although no one likes to pay a fine and I am sure there are some companies out there that may not feel the same way). I firmly believe that Giorgi will be missed. Starting in the Rule Writing Division, he possessed significant knowledge of the Consumer Products regulation, as well as the history of the formation of the regulation. Giorgi also did a very good job of training his staff in, not only the regulation, but in the history of the formation of the regulation and to understand the “intent” of the regulation. As we all know, in some circumstances, the Consumer Products regulation is not crystal clear on several topics; therefore the “intent” of the regulation is crucial. Giorgi’s replacement is not currently known and we might not know who will take his place for several months. CARB Survey Hopefully, by the time you read this article, CARB staff will have released data on the first phase of the survey. It is crucial that industry closely reviews this data from CARB, because this is the data that will likely be used to determine the next round of emission reductions and which product categories are targeted. Thus, if there are significant errors in the data, these errors need to be pointed out to CARB to be corrected. In this way, we can develop future rules on Consumer Products in the best ways possible. CARB staff will be supplying summaries on the ingredients that were reported in the survey, which will include volatile organic compounds (VOCs), low vapor pressure compounds (LVP) and exempt and non-VOC compounds. Along with the list of ingredients will be the tonnage in each category. This will be a significant amount of data that needs to be sifted through, which is not easy to do but extremely necessary. Look for these summaries at the end of January or early February. California Legislation Of particular importance to our industry is Assembly Bill 708 (AB 708), a Legislative Bill concerning ingredient disclosure and communication. Readers may hopefully remember from last year that AB 708 was made into a two-year bill that called for the labeling of ingredients on Consumer Products in California. The bill, as written, was extremely burdensome on the industry and very few provisions were made for confidential business information protection. The bill had an initial deadline of Jan. 31, 2016 to be heard on the assembly floor. By this month, we will have a better idea of this bill’s status and may need your assistance. More information to follow. Spray
Spray February 2016
To see the actual publication please follow the link above