www.aeropres.com www.inhalant.org coster.com dscontainers.com diversifiedcpc.com ikimfg.com mbc-aerosol.com precisepackaging.com terco.com Regulatory Issues Doug RaymonD Raymond Regulatory Resources CARB Survey Update, OTC Sets Timeline summitpackagingsystems.com CARB The California Air Resources Board (CARB) is performing a comprehensive study on Consumer Products. Phase 2 of the survey began July 1, 2015 and ended Nov. 1, 2015. This part of the survey was to update Phase 1 with the sales for 2014 and any new products introduced into California in 2014. CARB was not granting any formal extensions for this portion of the survey. However, if you didn’t get your survey in by Nov. 1, submit it as soon as possible.This information is very important; an accurate inventory is needed to determine emission reduction from Consumer Products. Next year (2016) will be the last year for this three-year survey and it will report on sales from 2015. LVP Do not forget that CARB has an ongoing study to determine the air quality impact of Low Vapor Pressure (LVP) compounds. The results of this study will be extremely important to Industry. Remember, this exemption has been in the Consumer Products Regulation since its inception; any change now will have a significant impact on our products. More updates to come. Short-lived Climate Pollutants (SLCP) CARB’s newest endeavor is to develop a strategy to reduce Green House Gas emissions. The strategy involves reducing emissions from Methane, Black Carbon and Fluorinated gases (F-gases). CARB held three California workshops in October in Sacramento, Diamond Bar and Fresno. Obviously, Industry is concerned with any reduction of F-gases. CARB’s target for F-gases is the following: Pollutant Inventory Forecast Target 2013 2030 2030 F-gases 40 65 24 Therefore, some emission reductions will be needed. In 2013, aerosols made up 13% of the tonnage of F-gases. In 2030, aerosols are projected to be only 6% of the emissions. The good news is that CARB is waiting to see how national and international regulations play out before developing a strategy. Next steps will be: • December 2015: Release Proposed Strategy • December 17, 2015: Present Proposed Strategy to the Board • Spring 2016: Present Final Strategy to the Board. We therefore have time to review the strategy. OTC The Ozone Transport Commission (OTC) held its Fall meeting on Nov. 5 in Baltimore, MD. A hot topic was the newly adopted Federal Ozone Standard, which was explained in detail in last month’s column. Of interest was the timeline for U.S. states to be in compliance with the new standard. Below are the timelines: • Oct. 1, 2015: Final Rule • Dec. 28, 2015: Effective date • Oct. 2016: Submittal of Non-attainment & Designation Recommendations by states, meaning status of the state. • Oct. 2017: EPA Non-attainment Area Designations • Oct. 2018: State Implementation Plan (SIP) Due • Attainment Dates for each of the different ozone designations include 2020: Marginal Designation; 2023: Moderate Designation; 2026: Serious Designation; more time will be given for Severe and Extreme Designation areas. 8 Spray December 2015 Continued on p. 53
Spray December 2015
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