research projects conducted by CARB and the industry on the impacts of Low Vapor Pressure (LVP) and VOCs on ozone and particulate matter. For example, the survey covers over 500 categories of consumer products, some of which have never been surveyed before. Federal At the federal level, the EPA will finalize its rule under the Significant New Alternatives Policy (SNAP) Program to eliminate many current uses of the aerosol propellant HFC- 134a. The CSPA filed extensive comments on the August 2014 proposal, seeking a few more allowed uses and additional time beyond the January 2016 proposed phase-out deadline. The EPA will continue implementing its Work Plan Chemical Program to evaluate the safety of specific chemical uses under the existing Toxic Substances Control Act (TSCA), as efforts continue to modernize it. The U.S. Occupational Safety & Health Administration (OSHA) will continue implementing its 2012 Hazard Communications Rule, with critical 2015 deadlines for revised labeling and Safety Data Sheets. The rule implements the Globally Harmonized System of Classification & Labeling (GHS) in the U.S. workplace. The U.S. Dept. of Transportation (DOT) is planning to issue a major proposed transport rule that would be the most extensive update in many years. Retailers as regulators Non-traditional regulators will continue to emerge in 2015; retailers are establishing new requirements for consumer products. One common theme so far is the desire for ingredient communication. Wal-Mart will require certain consumable products it sells to have ingredients communicated on a website starting January 2015, and Target will base 20% of its product sustainability score on ingredient disclosure. The CSPA As we usher in 2015, many questions arise as to what the regulatory arena will look like. In an effort to bring readers a variety of perspectives, SPRAY surveyed regulatory experts and researched various sources to bring together a comprehensive look at what lies ahead in the aerosol and related industries. D. Douglas Fratz, Senior Science Fellow & Aerosol Products Division Executive, The Consumer Specialty Products Association (CSPA) Aerosol and other consumer products will face a number of challenges at the state, federal and international levels in 2015, many carried over from 2014. At the state level, the California Dept. of Toxic Substances Control (DTSC) will continue implementing the Safer Consumer Products Regulation. The department has released a work plan identifying product categories of interest and intends to name five to ten products each year, in addition to the three priority products that were announced in 2014. Another carry-over from 2014 action in California is the Consumer & Commercial Products Survey, because companies will continue to dedicate significant time and resources in responding to this activity. The scope of the survey is unprecedented both in terms of the expanded number of products and the scope of data being required. Many companies will be challenged to meet the March 2, 2015 deadline for completing the initial year’s reporting of 2013 products because they will also need to begin the second-year reporting of 2014 products by the end of this year. A new action in 2015 will be the updated ozone State Implementation Plan. The South Coast Air Quality Management District (SCAQMD) and the California Air Resources Board (CARB) will begin developing the plan for submission to the U.S. Environmental Protection Agency (EPA) in 2016. The plan will contain new commitments for volatile organic compounds (VOC) reductions from consumer products. Data gleaned from the CARB survey will help form the extent of the commitments, as will the results of ongoing 12 Spray January 2015 The regulatory arena… safer products, cleaner Fratz BY AVA CARIDAD, EDITORIAL DIRECTOR
Spray Jan 15
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