been unable to alleviate the state’s concerns and its consumer products regulation is fairly obsolete. For aerosol coatings, the regulatory outlook is a bit confusing. Since California amended its regulation in 2013— lowering the standards significantly for the general categories and other select categories, and adopting a new table of maximum incremental reactivity (MIR) values—manufacturers, formulators and marketers are in a position of complying with both the CARB regulation and the EPA national regulation in the rest of the country. This is proving somewhat difficult as there were new categories created in the 2013 amendments in California and the calculation of the product’s reactivity must be completed with two separate lists of values for the product ingredients. The first compliance date was in January 2015, but the most challenging compliance deadline is still ahead: Jan. 1, 2017. Numerous requests were made to the EPA to initiate some changes to the national rule to address these new discrepancies, but the agency has indicated that it does not have the resources or the political will to do so at this time. ACA is committed to continuing this effort. Aerosol coatings have not been targeted as a source category in state rulemaking efforts to date. This is due to the fact that the EPA adopted a national regulation in 2008 that included CARB standards. Now that the national rule is not consistent with CARB standards, there could very well be states that might be willing to do so. In addition, Environment Canada had previously indicated a desire to implement some controls on aerosol coatings once CARB completed its rulemaking. To date, Environment Canada has not divulged any rulemaking plans. Aerosol coatings manufacturers should also be wary of enhanced enforcement efforts. Now that the 2013 amendments to the CARB regulation have been completed and the test methods for determining compliance have been refined, there will be focused scrutiny on these products in California. Other regulatory challenges that lie ahead include compliance with the Globally Harmonized System of Classification & Labeling of Chemicals (GHS) requirements around the globe, potential activity from EPA if the Toxic Substances Control Act (TSCA) reform efforts on Capitol Hill are successful and the chemical management programs that are quickly developing in several states around the country. Moffatt Mike Moffatt, PhD, Director of Communications, Nexreg Compliance Inc. The year 2016 should be relatively quiet for Globally Harmonized System of Classification & Labeling of Chemicals (GHS) compliance in the U.S. The deadline to have Hazcom 2012 compliant Safety Data Sheets and workplace labels has passed, although some companies are still working to become compliant. There may be some scrambling in early 2016 among distributors that missed the Dec. 1, 2015 deadline to stop distributing stock with old labels or outdated Material Safety Data Sheets. With the release of the 6th revision of the UN’s Purple Book, Hazcom 2012 has already become dated, so expect to see the regulation updated at some point. I would be surprised if this update occurs in 2016, but stranger things have happened. The situation in Canada is substantially different, with the country in a transition period between the old Workplace Hazardous Materials Information System (WHMIS) system January 2016 Spray 17
Spray January 2016
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