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SprayApril 2017 Regulatory Issues Doug RaymonD Raymond Regulatory Resources 8 Spray April 2017 CARB SIP Finally, South Coast Air Quality Management District (SCAQMD) has finished its 2016 Air Quality Management Plan (AQMP). On March 23–24, the California Air Resources Board (CARB) adopted the 2016 AQMP. In performing this action, CARB will then submit the 2016 AQMP to the U.S. Environmental Protection Agency (EPA) as a revision to the California State Implementation Plan (SIP). The meeting was held in Riverside, CA instead of the capital, Sacramento, probably making it more convenient for SCAQMD members to comment. CARB has a part in the 2016 AQMP and has committed the reductions of emissions from numerous sources, from cars to trucks to locomotives, and yes, Consumer Products. The CARB commitment for reductions for Consumer Products is 1–2 tons of emissions per day. CARB needs to adopt these regulations between 2019 and 2021 to be effective in an early 2020 time frame. While one to two tons per day does not sound like much, with all of the product categories having very low limits today, this could be very hard to achieve. We will need to wait until the volatile organic compound (VOC) survey work is completed to see which VOC categories may be targeted for reduction. CARB will likely be done with the VOC survey work later this year. That will be good timing, because if regulations are to be adopted in the 2019-2021 timeframe, we need to start working with CARB in 2018. It takes between 18 months to two years to develop a feasible regulation. The good news is SCAQMD did not mention any Consumer Product regulations. However, it stated it will make changes to its Adhesives and Coatings rules; therefore, make sure to watch these closely. Best of all, there was no mention of changes to the low vapor pressure (LVP) definition or status, which is really good news. Multi-purpose lubricant report Any marketer, manufacturer or formulator was supposed to file a report with CARB by March 31, 2017. If you have not done so, make sure to do it now. This is your opportunity to tell CARB about your progress toward the future effective limit of 10% effective 12/31/2018. We hardly ever get to tell CARB how its limit will affect our products, so this is your chance. New legislative bills introduced in California Just introduced is Senate Bill No. 258 on ingredient disclosure. The bill calls for a list of each ingredient present in cleaning products at a concentration of one percent. Cleaning products are defined as any used for commercial, domestic or institutional cleaning purposes, including air care products, automotive products, floor maintenance products or any general cleaning products or polish. General cleaning products are further defined as soap, detergent or other chemically formulated consumer product for the purpose of cleaning and disinfecting fabrics, dishes, floors, furniture, counter tops, showers, baths, stove tops, microwaves and other appliances. This is a very poorly written bill that we need to amend or defeat. Two other bills have been introduced that would restrict the retail sale of butane into the state of California to very small amounts. This bill is being introduced in an attempt to stop the production of some illegal drugs. We need to amend these bills to exempt the manufacturing use of butane. Spray

SprayApril 2017
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