created an initiative to reduce “Short-Lived Climate Pollutants,” which include hydrofluorocarbons (HFCs). EPA is also working hard in that area, in a follow-up to President Obama’s 2013 Climate Action Plan, and is seeking to reduce HFCs internationally through amendment of the Montreal Protocol. We also anticipate additional actions will be taken by the California Dept. of Toxic Substances Control (DTSC) to regulate through the Safer Consumer Products (SCP) Regulation. This requires product manufacturers to find “safer” alternative ingredients for their products through an alternatives analysis, report the results to DTSC and then implement the mandated regulatory response. While CSPA-represented products are not currently the subject of the first three “Priority Products,” future Priority Products will be designated. Alternatives Analysis Guidance recently released by DTSC will set the standard for alternative analyses mandated by the SCP regulation. Kristin Power, VP, State Affairs,The Consumer Specialty Products Association (CSPA) Fast Forward on Right-to- Know Policy Issues Policy concepts often take many years to develop as legislators, industry and other interested parties discuss proposals and amendments with all stakeholders—who often evolve their positions as the debate progresses. Much iteration of right-to-know proposals has surfaced over the years from broad in scope to narrow in focus. California has led on these issues and is again taking the lead in 2016. In 2012, the consumer products industry proactively responded to a challenge from legislators and consumers that led to the development of an industry-led ingredient communication initiative that helps consumers make more informed choices about the products they use their homes. The initiative was launched in part by discussions about a proposed California bill. Fast forward to 2015 and California is again attempting to take a leadership role in ingredient communication with Assembly Bill 708 (AB 708, Jones-Sawyer), which would require disclosure of the 20 most prevalent ingredients on the product label—and on the manufacturer’s website—for air care, automotive, cleaning and polish and floor maintenance products. Following an aggressive industry advocacy campaign, AB 708 was stopped on the California State Assembly Floor in Summer 2015; the bill will again be considered, however, As 2016 dawns, 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) 2016: Regulatory Challenges Ahead The year 2016 will most certainly be very challenging for the aerosol products industry in terms of air quality. California will be adopting a new State Implementation Plan Fratz (SIP) aimed at attaining the 75 ppb ozone standard that the U.S. Environmental Protection Agency (EPA) adopted in 2008, and the 2016 SIP will incorporate the South Coast Air Quality Management Plan (AQMP) on which work will be continued into next year. The California ozone SIP strategy will rely primarily on reductions of nitrogen oxides (NOx) but will also include new commitments for volatile organic compound (VOC) reductions that will continue to present risks for further regulations of aerosol and other consumer products, starting in 2016 or 2017. Complicating this SIP revision is the lower 2015 70 ppb ozone standard. Meanwhile, the California Air Resources Board (CARB) is continuing its burdensome Consumer & Commercial Products Survey, covering 2013-2015 products and with the third year of reporting due next year. We will also be engaged in the immense task of correcting the data from the first year (2013) so that can be used as an accurate basis for updating the consumer products VOC emissions inventory. It is important that the uncorrected survey data not adversely impact the SIP revision. Complicating things further is the low vapor pressure (LVP) issue, with ongoing scientific research funded by CARB and by industry. Another area where California is seeking to lead the nation and the world is global warming. The greenhouse gas reductions mandated by AB 32 (California’s Global Warming Solutions Act of 2006) continue, augmented by new legislation that has 14 Spray January 2016 Experts remark upon regulatory concerns Regulatory outlook… Powers
Spray January 2016
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