www.aeropres.com www.inhalant.org coster.com dscontainers.com diversifiedcpc.com ikimfg.com mbc-aerosol.com terco.com Regulatory Issues Doug RaymonD Raymond Regulatory Resources summitpackagingsystems.com 8 Spray March 2016 California Legislation This year is starting out well. Last year, as well as this year, Assembly Bill 708 (AB708)— concerning Ingredient Disclosure—was a hot topic for our industry. Yes, I stated was! The bill needed to pass the Assembly floor by Jan. 31, 2016. However, it didn’t have enough votes to pass. Therefore, the bill is dead for now. AB708 required a product’s top 20 ingredients to be listed on the label. This would be extremely burdensome for the aerosol industry. In addition, and even more troubling, was the lack of any provisions to safeguard Confidential Business Information (CBI). Earlier this year, industry had a grassroots effort to meet with numerous legislators to discuss this bill. The meetings were a success. Thanks to Kristin Power and Nicole Quinonez for organizing the event and to all industry members who participated. For now, the bill is dead. However, the author has stated he will bring it back; we’ll need to wait and see what happens later this year. CARB Enforcement More organizational changes. As reported in the February issue, Steve Giorgi, California Air Resources Board (CARB) Consumer Product Enforcement Manager, retired on Dec. 31. In February, Keith Kennedy, CARB Consumer Product Enforcement Investigator for nine years, changed positions to head up the laboratory sector. With both Giorgi and Kennedy leaving Enforcement, there is a loss of knowledge and understanding of past regulatory actions. Hopefully, the new personnel hired into these vacancies will have knowledge of Consumer Products regulation. Unfortunately, the loss will be of how past issues have been dealt with. Kennedy was a fair and detailed investigator; he will be missed for those reasons. The bright spot here is that maybe, under Kennedy, the laboratory will become timelier in its processes. Some samples sit in the lab for years before being processed. We will need to wait and see. CARB Survey Update On Feb. 9, CARB released the following information on its Consumer Product Survey: • A list of all volatile organic compounds (VOCs), Non-VOCs and low vapor pressure compounds (LVPs) that were reported in the surveys. This list is the interesting part. • A correction for emissions for products that are considered down-the-drain products. • A list of all Responsible Parties that filed a survey and what product categories each reported. All information can be found here: http://www.arb.ca.gov/consprod/ regact/2013surv/2013main.htm CARB staff stated it would release the following data in a couple months: • Emissions per category (this is the important data!) • Ingredient profiles for the categories. And now the real fun begins! All of this data will need to be reviewed very closely and industry comments should have been submitted by Feb. 26. Spray formulatedsolutions.com
Spray March 2016
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