www.aeropres.com
www.inhalant.org
dscontainers.com
diversifiedcpc.com
formulatedsolutions.com
ikimfg.com
mbc-aerosol.com
terco.com
Regulatory Issues
Doug RaymonD
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray August 2017
South Coast Air Quality Management District
The South Coast Air Quality Management District (SCAQMD) held a workgroup meeting at district headquarters
on June 22, 2017 on Rule 1168 Adhesives & Sealants.
SCAQMD had suspended this rulemaking in 2014. In May of this year, its staff announced that they
were reopening the development of amendments to Rule 1168, which drastically affect Consumer Product
Adhesives & Sealants, as well as Aerosol Adhesives. The amendments target all Consumer Adhesives not
regulated by the California Air Resources Board (CARB). Currently, we do not know all the products that
will be affected, although we do know that Foam Insulating Sealants and Clear/Paintable/Water Resistant
Caulks will be regulated.
In addition, SCAQMD is placing prohibition of use on all Consumer Adhesive used in the manufacturing
process. Also, Aerosol Adhesive will be restricted to sixteen ounces per day in the manufacturing process.
SCAQMD has set these restrictions, but has not accounted for any reductions from these restrictions.
It appears that this is a regulation that does not serve a purpose; SCAQMD is setting a regulation just to say
that the products are regulated, without any environmental benefit. In addition to the above, there will be
label requirements and reporting requirements. This is a real problem for Consumer Products. If SCAQMD
does this to Adhesives & Sealants, what will be its next target?
Also troubling is that SCAQMD is on a fast track to adopt this regulation, with a proposed adoption date
of October of 2017. SCAQMD does not need these reductions until 2023. Industry needs to be heard on
this issue. There was another workgroup meeting is in July; more on that in an upcoming issue.
CARB
No news yet on the Multi-purpose Lubricant Report required to be submitted to CARB staff, who will then
determine if the future effective limit of 10% volatile organic compounds (VOC) on 12/31/2018 is technologically
feasible. Currently, we only have eighteen months before the effective date. Hopefully, CARB staff
will give Industry some news soon.
Legislative Bills
Senate Bill 258, which deals with ingredient disclosure, is still being amended. Industry proponents of the
bill and the author’s office are working on trying to get some kind of workable bill. Industry is very worried
about Confidential Business Information (CBI) being disclosed.
Federal Ozone Standard Delayed
On June 6, the U.S. Environmental Protection Agency (EPA) provided a one-year extension for the deadline
to make final designation of attainment or non-attainment areas with the 2015 Ozone Standard.
The new timeline gives EPA until October 2018 to make fine decisions on areas that fail to meet the new
70 parts per billion (ppb) ozone standard.
This is good news; it should give states longer to come into compliance. Also, this will likely delay the
states from taking further action to regulate Consumer Products.
Maryland Proposes Amendments
On June 27, 2017 the Maryland Dept. of the Environment held a public hearing on amendments to its
Consumer Products rule. The amendments included eleven new VOC standards and more stringent restrictions
for fifteen current standards. In addition, there will be restrictions on the use of Methylene Chloride,
Perchloroethylene and Trichloroethylene. These changes are consistent with the Ozone Transport Commission
Model Rule.
The only real opposition to this rule is the effective date. The agency is proposing 1/1/2018 and Industry
is asking for 5/1/2018. This is to allow manufacturers more time to prepare for the changes. The agency will
let Industry know the outcome in August or September. Spray