www.aeropres.com
www.inhalant.org
dscontainers.com
diversifiedcpc.com
formulatedsolutions.com
mbc-aerosol.com
powercontainer.com
terco.com
Regulatory Issues
Doug Raymond
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray April 2018
Article in Science
On Feb. 15, 2018, the journal Science published research titled “Volatile Chemical
Products Emerging as Largest Petrochemical Source of Urban Organic Emissions.”
This researched study is very significant to the consumer products and paint industries.
The lead author is Brian McDonald, along with numerous other scientists. This work
contradicts most of the findings to date.
The study states that current inventories of emissions are significantly
underestimated—by as much as two to three times. It also states that consumer products
emissions, including those from paints and personal care products, are close to the
emissions from cars. The study continues to state that fragrances are also a major source
of emissions because of limonene and pinene compounds. Additionally, the study questions
if low vapor pressure volatile organic compounds (LVP-VOCs) are a major source of
emissions as well by contributing to the formation of Secondary Organic Aerosols (SOA).
The reason that consumer product emissions appear greater is they are not being
reduced as fast as emissions from cars. Thus, the entire emissions universe is shrinking
but consumer products emissions now appear larger. This study was picked up by
numerous news agencies in the U.S. and in Europe. Headlines include “Consumer
Products overtake transportation as largest source of VOCs,” “Fragranced products to
blame for smog as much as cars” and “Household products now rival cars as source of
Air Pollution.” Obviously, this is not good news for the industry. Media like this puts
additional pressure on agencies such as the California Air Resources Board (CARB) to act
on regulating our categories more.
What will happen as a result of this study is not yet known. However, we can expect
more research in this area. Also, CARB will review its estimates of emissions and this
study will likely push it to release its survey data sooner than expected.
The only redeeming information in the study was a statement that says consumers
should only use the amount of product necessary to complete a task. I believe the aerosol
industry has been saying this for years. There is more to come on this issue.
CARB Survey Data
Over the last three years, the industry has filed survey data with CARB on all consumer
products sold into the state of California. This was the largest and most comprehensive set
of surveys that have been done on the industry to date. The Science study will likely make
CARB release its survey data soon.
These surveys should show the actual emissions from our products. It will be
interesting to see how CARB’s emissions data matches up with the Science study, which
industry believes used old data. Hopefully, this new data will show that consumer product
emissions have indeed declined over the years. Expect the data from the surveys sometime
in April.
CARB Multi-purpose Lubricant
The amendment on the Alternative Compliance Option for Multi-purpose Lubricants
(MPL) is continuing through its process. The amendment will provide industry with an
option to meet the 10% VOC mass based limit or meet an alternative reactivity-based
limit of 0.45 Maximum Incremental Reactivity (MIR). In addition, the future effective
limit has been delayed until July 1, 2019 for both options. The CARB Executive Board
will vote on these amendments in May. The comment period should begin in April.
Ozone Transport Commission
The Ozone Transport Commission (OTC) is in the process of developing yet another
Model Rule. OTC plans to have this Model Rule ready by the end of the first quarter of
2018. We need to work with them to narrow the amount of Model Rules out there for
states to adopt.
precisionglobal.com