www.aeropres.com www.inhalant.org coster.com dscontainers.com diversifiedcpc.com ikimfg.com mbc-aerosol.com precisepackaging.com terco.com 8 Spray November 2015 Regulatory Issues Doug RaymonD Raymond Regulatory Resources EPA lowers ozone standard, DTSC releases info summitpackagingsystems.com EPA The U.S. Environmental Protection Agency (EPA) finalized the new Ozone Standard limit at 70ppb. The Ozone Standard limit is the level at which all states are regulated. This means if a state or area has ozone (volatile organic compound VOC) levels at higher than 70 ppb, the agency regulating that area needs to develop a plan to get the area into attainment. VOC emissions from all sources will need to be reduced. The Ozone Standard limit was at 75 ppb; at this limit, there were numerous states and areas out of attainment. With EPA lowering the limit, this means even more states will be out of attainment. What does this mean to you? More states will need to develop State Implementation Plans (SIP) that will guide state agencies toward attainment of the Ozone Standard limit. In plain English, it is likely more states will adopt the Consumer Products VOC regulations. Therefore, the California Air Resources Board (CARB) VOC regulations and the Ozone Transport Commission (OTC) VOC model rule will likely be adopted in more states in the coming years. In addition, the lowering of the Ozone Standard will also lead to the development of more VOC regulations on Consumer Products, likely starting in California, eventually moving to the OTC and Lake Michigan Air Directors Consortium (LADCO) states. Industry has been working on this issue for several months and can claim a victory in that the Ozone Standard limit was not reduced even further. The EPA had proposed to move the Ozone Standard to 65ppb and environmentalists were pushing EPA to lower it to 60ppb. The reduction of the Ozone Standard to 70ppb will cause more regulation and, more importantly, the spread of regulation to other areas in the U.S. If EPA would have further lowered the Ozone Standard to 65ppb or 60ppb, it could have been disastrous for the industry. These lower standards would be impossible to meet. In some areas in the U.S., an Ozone Standard of 60ppb could be below the area’s normal local ozone level. For example, some federal parks have natural ozone levels greater than 60ppb. Therefore, the new Ozone Standard of 70ppb is not what Industry pushed for. Our message was that EPA should wait for all current regulations to be implemented, then measure the ozone in the 50 states and determine the ozone standards from those levels. Remember, Industry did have a very good grassroots effort put forth by numerous associations and companies to battle this issue. Cindy Hundley from Spray Technology and others of us traveled to Washington, D.C. to fight this battle. This issue brought the Industry together and we did prevent EPA from lowering this standard even further. Now that the Ozone Standard has been finalized, we will need to wait and see what the states have in store for us. DTSC The Dept. of Toxic Substance Control (DTSC) in California has released two documents on the Safer Consumer Products Regulation, previously called Green Chemistry. These two documents were included in the Alternative Assessment guidance and the amendment to the Safer Consumer Products Regulation for the candidate chemical list. Both documents can be found at: https://goo.gl/BT6j9t I encourage everyone to read these documents. Spray
Spray November 2015
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