Spray November 2014 8 Spray November 2014 Regulatory Issues Doug Raymond Raymond Regulatory Resources With new regulations on the horizon, is your company in compliance? CARB Finally, the Office of Administrative Law (OAL) approved the California Air Resources Board (CARB) Consumer Product regulation on Sept. 17, 2014. This action finalizes the amendments and the U.S. Secretary of State has endorsed the rule. Thus, all amendments are final. This process has taken almost a year. The new volatile organic compound (VOC) limits for some of the Aerosol Specialty Coating categories become effective on Jan. 1, 2015. If you have products in this category, make sure you check them for compliance. Survey The CARB Consumer Products Survey is out and you need to review this document. Anyone that sold consumer products into the state of California in 2013 that are listed in the survey needs to report their product to the state. The deadline to file is March 1, 2015. CARB had a webinar on its Consumer Products Reporting Tool (CPRT) on Oct. 15 to ask questions on the survey or the CPRT. More on this webinar next month. On Dec. 15, 2014, the staff will have another webinar. Register for that at This survey is extremely important, as all information is used for rule making. Therefore, the more accurate the findings, the better. Enforcement CARB Enforcement has been busy. In 2013, CARB leveled fines of close to $1.6 million on Consumer Product violations. In the first six months of 2014, CARB has settled fines of $409,000 on Consumer Product violations. Make sure your products are in compliance, as CARB staff is out looking for violations. SCAQMD The South Coast Air Quality Management District (SCAQMD) staff hosted a symposium called Assessing & Managing Toxic Risk from Alternative VOC Compounds at SCAQMD Headquarters in Diamond Bar, CA on Oct. 29. Recently, SCAQMD has been faced with a variety of issues regarding the potential toxic risk posed by compounds proposed for exemption. The symposium included presentations from experts from the regulatory, industrial, academic and environmental communities exploring critical issues from different perspectives. The objective was to provide SCAQMD with expert advice and potential future direction regarding the analysis and mitigation of potential toxic risks associated with alternative VOC compounds. More on this symposium next month. SNAP The U.S. Environmental Protection Agency (EPA) released the proposed amendment to the Significant New Alternative Policy (SNAP) Program. The rule is at The SNAP amendments focus on the prohibition of HFC 134a in products, including all Consumer Aerosol products. Thus, if you need to maintain the use of HFC 134a in your product, pay close attention to these amendments. continued on page 37

Spray November 2014
To see the actual publication please follow the link above