www.aeropres.com www.inhalant.org coster.com dscontainers.com diversifiedcpc.com ikimfg.com mbc-aerosol.com precisepackaging.com terco.com 8 Spray March 2015 Regulatory Issues Doug Raymond Raymond Regulatory Resources Industry must address ozone misconceptions, CARB survey deadline arrives summitpackagingsystems.com EPA The U.S. Environmental Protection Agency (EPA) held three hearings to discuss the changing of the new ozone standard. Currently the ozone standard is 75 parts per billion (ppb). This means that if the ozone (O3) level in the air is higher than 75ppb, then the area in question is out of compliance with the Federal Clean Air Act. This requires the area, whether it is an air district as seen in California, or a county, state or other designated area, to develop and implement plans called State Implementation Plans (SIPs) to control emissions of volatile organic compounds (VOCs) or oxides of nitrogen. These two compounds, in the presence of sunlight, create ozone. Three meetings were held in Washington DC, Texas and California. I monitored the California meeting, which started at 9:00 am and was rumored to have gone until 9:00 pm; I left at 5:30 pm. The majority of speakers were from the public or from environmental groups such as the Sierra Club, Coalition for Clean Air and Mom’s for Clean Air. Also, a number of agencies testified, such as the Office of Environmental Health Hazed Assessment (OEHHA), California Air Resources Board (CARB) and Bay Area Air Quality Management District (BAAQMD). Very few industry people spoke. The EPA is proposing to lower the ozone standard from 75ppb to between 65–70ppb. To reach a standard of 70ppb by 2025, the EPA is estimating a cost of $3.9 billion and $15 billion to meet the standard at 65ppb. This does not include California because of the severity of the area; California has until 2037 to meet the limits, which will cost an additional $800 million for the 70ppb standard and $1.6 billion for the 65ppb standard. Almost all of the public and environmental comments were similar: • Petroleum and chemical plants are to blame. • We can go to electric cars tomorrow. • Solar energy and wind power are the answer. • Industry can adjust. In addition, most speakers were asking for 60ppb to be the standard. This is a state that cannot even meet 75ppb. Also, numerous speakers were from high schools; these children testified that industry is holding everything back and that they are entitled to clean air! I kept wondering, do these children have parents who work? Do these children ever want to drive a car? Do they really believe that if industry could move to newer technology that we would not? It is sad that so many children have this perception of the industry. Industry needs to respond to the EPA in force on this issue, as well as start educating our children on reality. Written comments are due by March 17, 2015. When the ozone standard is lowered, this will mean more jurisdictions across the country will need more emission reductions. View the EPA’s ozone map at www.spraytm.com by clicking on the “Regulatory Issues” link. In addition, review the list of speakers at http://1.usa.gov/1vhjltY. Take a look; it may surprise you who spoke. CARB On Feb. 4, California Air Resources Board (CARB) staff held a webinar on its current Consumer Product Survey. Remember, the survey is due on March 2, 2015. The Survey was released in September 2014 and is very comprehensive. Almost all categories need to be reported. You need to include sales, labels and formulas to 100%. If you have not started, you need to get moving on this survey. The better the information that is submitted, the better rulemaking we can have later on. During the webinar, CARB staff answered the industry’s questions. CARB stated that they were willing to grant some extensions, which is big news because, up until now, CARB had said no extensions! You will need to apply for an extension and will need a good reason for it. For example, there are many formulators waiting for the responsible party to fill out the survey and forward the survey data on the formulas to them. If the responsible party does not act in a timely manner, the formulators will not have time to reply, thus the need for an extension. CARB’s website has the latest slides from the last webinar, as well as extension information: http://bit.ly/1FvhLur. SPRAY
Spray March 2015
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