IMPACT 2019
The BAMA/FEA Indoor Air Model is a tool, developed by the
British Aerosol Manufactures Association (BAMA) and European
Aerosol Federation (FEA), to predict the concentration of aerosol
components within a room after a suitable time interval after
spraying.
Aerosol Dispensers Directive (ADD) 75/324/EEC is one of the
oldest EU legislations related to product safety. It requires member
states to allow for the marketing of aerosol dispensers that comply
with the provisions of the ADD on their territory. Member states
may allow certain aerosol dispensers that do not comply with
the ADD to be marketed in an individual member state under a
national legislation.
Under the CLP, aerosols are divided into three categories:
Extremely Flammable Aerosols (Category 1), Flammable Aerosols
(Category 2) and Non-Flammable Aerosols
(Category 3).
Holger Behrsing, Principal Scientist,
Respiratory Toxicology Program, Institute
for InVitro Sciences, presented “IIVS:
Respiratory Toxicology Program.” There
is a plethora of toxicants that can potentially
harm respiratory tissue in the lungs,
including occupational exposures (e.g.
nanoparticles); household products (e.g.
cleaning agents); personal care products (e.g. talcs); fragrances (e.g.
perfumes and air fresheners); pharmaceuticals in development and
“next generation” tobacco products (e.g. e-cigarettes).
There is increased use and regulatory acceptance of in vitro/
ex vivo respiratory toxicology test systems, including reconstructed
airway models in 3D (in vitro) and precision-cut lung slices (ex vivo).
For cost and ethical reasons, these are becoming more popular
than in vivo test systems, which utilize animal testing.
Jessica Olson of Honeywell presented “Regulatory Update.”
20 Spray August 2019
The Kigali Amendment amends the
Montreal Protocol, which is a global
treaty to eliminate the use of ozone
depleting substances. Now, it is proposing
to phase down hydrofluorocarbons
(HFCs), which were adopted as a replacement
for ozone depleting substances.
HFCs, said Olson, are greenhouse
gases that trap heat in the atmosphere,
contributing to global warming. The
Kigali Amendment is an agreement to
globally phase down production and consumption of HFCs by
85% by 2036 in developed countries and 80% by 2045 in most
developing countries.
The Phase Down took effect on Jan. 1, 2019 in the 70 countries
that have ratified the Amendment so far. The U.S. has not ratified
the amendment, but the decision is under consideration. Any nonratifying
country is subject to trade restrictions in 2033.
The global HFC production/consumption Phase Down is not
an application-specific “phase-out” and each country will adopt its
own regulatory program to meet the Phase Down schedule.
Concerning U.S. State actions, the U.S. Climate Alliance is a bipartisan
coalition of governors committed to reducing greenhouse
gas emissions consistent with the goals of the Paris Agreement.
There are now 23 member states (plus Puerto Rico) representing
more than 50% of the U.S. population and a GDP of over $10
trillion. In June 2018, Climate Alliance members were committed
to take actions to comprehensively address HFCs and align state
regulations as closely as possible.
California has adopted U.S. Environmental Protection Agency
(EPA) Significant New Alternatives Policy (SNAP) transition dates,
effective Jan. 1, 2019 (representing 12% of the U.S. population).
New York has issued a pre-proposal outline to adopt SNAP dates
by the end of 2019 (6% of U.S. population). Washington State
legislation has adopted SNAP transition dates set for Jan. 1, 2020
for aerosols. Connecticut and Maryland have committed to adopt
regulations with SNAP dates and Vermont has introduced legislation
to adopt SNAP dates.
Canada has a two-part framework for bulk HFC Phase Down
that gradually reduces HFC consumption (imports) per Canada’s
obligations under the Kigali Amendment. This applies to companies
importing and/or exporting bulk HFCs and establishes
reduction steps in HFC consumption from a baseline level. The
permitting and reporting system has already been in place since
2016 and a quota system started on Jan. 1, 2019.
There will be prohibitions on the import and manufacture of
certain products that contain or are designed to contain HFCs
(similar to U.S. EPA SNAP). There are four affected sectors: aerosol
products; refrigeration and air-conditioning systems; mobile
air-conditioning systems and foam products. Product-specific
controls prohibit, by a specific year, the import and manufacture of
certain products or systems that contain or are designed to contain
any HFC with a global warming potential (GWP) greater than the
established limit or a blend that contains any HFC where that
blend has a GWP greater than the established limit. For aerosols,
the limit is 150 GWP, which took effect on Jan 1, 2019. Spray
Brock Manner, Regional Sales Manager at Diversified CPC International
and Chair of the Aerosol Products Division Survey Committee, presented the
2018 Aerosol Pressurized Products Survey, noting that aerosol production hit
an historic high in 2018, up 0.3% from 2017.
Behrsing
Olson
The next HCPA Mid-Year Meeting will be held April 21-24, 2020
at The Mayflower Hotel in Washington, DC...