Thanks to the management of Spray Technology & Marketing—specifically, Cindy Hundley and Ava Caridad—I will be writing each month to tell you what the Consumer Specialty Products Association (CSPA) and its Aerosol Products Division are doing to address the legislative, regulatory and public relations challenges facing the aerosol products industry. In this first Pressure Points column, the focus is on one of the unsung heroes of our industry: voluntary standards. 10 Spray November 2015 Pressure Points Doug Fratz CSPa aerosol Products Division Staff executive Voluntary Standards: A Firm Foundation 1 The association operated under the name Chemical Specialties Manufacturers Association (CSMA) before changing its name to CSPA n 2000; the Aerosol Division changed its name to Aerosol Products Division in 2002. 2 The full title for the standard is Aerosol Propellants: Considerations for Effective Handling in the Aerosol Plant and Laboratory. Voluntary standards play an essential role for the aerosol products industry, just as they do for most other industry sectors. Obtaining consensus in the development of these standards is seldom easy, but well worth the effort. Voluntary standards, which can include terminology, specifications, test methods, best practices and combinations thereof, play a number of critical roles. They can assist in assuring the compatibility of existing technology and facilitate the development of new technology. They provide the opportunity for industries to self-regulate and to maintain control of their own future. When regulations are developed by government agencies—which we know from protracted experience will happen—they assure that there is a firm foundation upon which to base those regulations and not a blank slate for others to determine the future of our products. In some cases, voluntary industry consensus standards can serve to deter indefinitely the imposition of restrictive and costly government regulations. CSPA, as an organization, has been active in developing voluntary consensus standards since the very beginning of its 100-year history, although formal “Standard-Setting Procedures” were not adopted until the early 1980s. The earliest efforts were pesticide efficacy tests for antimicrobials and insecticides. Those test methodologies have evolved into the tests still used today and are now required by the U.S. Environmental Protection Agency (EPA). Efficacy was the primary concern of government agencies regulating pesticides in those early years; issues relating to human health, safety and the environment were still decades away. When aerosol insecticides were first marketed, we adapted those methods for the new product form, and even provided the Official Test Aerosol (OTA) used as the internal standard (ironically, the first OTA contained dichlorodiphenyltrichloroethane DDT and chlorofluorocarbons CFCs, both of which would be banned by the EPA in the 1970s). After formation of the CSMA (i.e., CSPA) Aerosol Division1 in 1949, the organization continued to develop new standard specifications and test methods for the rapidly evolving new packaging technology and soon decided to collect all of them in the CSMA Aerosol Guide (precursor to the CSPA Aerosol Guide). The CSPA Aerosol Guide, now in its 9th Edition (2009), continues to be the home of most of the current CSPA aerosol standards. Various Aerosol Products Division committees—primarily the Commercial Standards Committee and Tests & Standard Methods Committee—are now working to update its many standards and add new ones for the 10th Edition, which CSPA plans to issue next year. This is a monumental task that requires many top industry experts serving on more than a half dozen committees. The new edition will include new standards covering bag-on-valve (BOV) technology, plastic aerosol containers and other new technologies, as well as updated glossaries defining industry technical terms, new government regulations, information on aerosol fire and building codes, aerosol recycling, flammability testing and other information key to aerosol packaging technology and product marketing. For some years, CSMA coursed most of its standards through the American Society for Testing & Materials (ASTM), but in recent decades has not done so. ASTM informed us recently that its packaging committee intends to retire all of the remaining aerosol standards due to insufficient technical expertise. Therefore, CSPA soon will once again be the only standards-setting group for aerosol packaging technology. CSPA’s other major aerosol voluntary standard is the CSPA Aerosol Propellants Safety Manual2. This is a comprehensive recommended safe-practices standard that was first published in the late 1970s at a time when serious accidents at filling facilities were still occurring. This standard has undoubtedly saved lives and property. In the late 1980s, this manual served as the basis for the manufacturing chapter of the National Fire Protection Association (NFPA) Code 30B, the fire code for aerosol manufacture and storage. CSPA seeks to encourage all aerosol manufacturing facilities to adhere to the practices detailed in this manual, and indeed the U.S. Occupational Safety & Health Administration (OSHA) often enforces compliance with voluntary industry standards under the General Duty clause of the OSHA Act. CSPA committee experts are now working on the Fourth Edition of the CSPA Aerosol Propellants Safety Manual which will be consistent with the revised Code 30B and include safe handling recommendations for HFO-1234ze. CSPA’s latest voluntary standards project also impacts aerosol products: the CSPA Consumer Product Ingredients Dictionary. Although its primary purpose is to define and name product ingredients for ingredient communication—EPA Safer Choice and Walmart are among those recommending the CSPA Dictionary for that purpose—it is also a valuable technical reference for R&D and a regulatory compliance tool. Voluntary industry consensus standards that help us control our own future are indeed a solid foundation for protecting the aerosol industry from ineffective and costly regulation. Spray
Spray November 2015
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