www.aeropres.com
www.inhalant.org
dscontainers.com
diversifiedcpc.com
formulatedsolutions.com
lindalgroup.com
MBC Aerosol
Filling Machinery Specialists
mbc-aerosol.com
powercontainer.com
terco.com
Regulatory Issues
Doug Raymond
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray December 2018
SNAP
On Oct. 9, 2018, the Supreme Court refused to hear the appeal of the petitions from the Natural
Resources Defense Council (NRDC), Honeywell International and Chemours to review the U.S.
Court of Appeals, District of Columbia (DC) decision to overturn the Significant New Alternatives
Policy (SNAP) Rule 20.
The DC circuit determination invalidated the U.S. Environmental Protection Agency (EPA)
Snap Rule 20. The EPA earlier this year vacated Rule 20. Regarding the DC Appeals decision,
the NRDC argued in its petition that “allowing it to stand would gut the EPA’s authority, harm
the agency’s ability to fight climate change and disincentive investments in safer products, which
would hurt proactive companies.” Honeywell and Chemours argued that invalidating the SNAP
Rule 20 undermines the more than $1 billion they and their suppliers invested in hydrofluorocarbon
(HFC)-substitutes.
California, as reported last issue, adopted into California law the SNAP Rule 20. Other states
are moving that way. In addition, the EPA is scheduled to release a new rule on HFCs in January
of 2019. Therefore, if you use HFC-124a, the saga continues. Also, do not forget Canada’s rule
on HFC-134a becomes effective on Jan. 1, 2019.
New substitutes approved
On Oct. 4, 2018, the EPA published a list of acceptable substitutes for several sectors. For the
Aerosol sector, HFO-1336 mzz(z) was determined acceptable for precision cleaning and aerosol
solvents. This is something to look into.
Colorado
The Colorado Air Pollution Control Division (APCD) held a stakeholder meeting on Nov. 13 in
Denver to discuss and hear comments concerning volatile organic compound (VOC) regulations
pertaining to Consumer Products and Architectural & Industrial Maintenance (AIM) Coatings.
APCD discussed potential rulemakings to reduce VOC emissions in these categories. It also
discussed Ozone Transport Commission (OTC) model rules. More to come on these issues.
Rhode Island
The Rhode Island Dept. of Environmental Management (RIDEM) issued a
proposed amendment to its Consumer Product rule. The amendment is consistent
with OTC Model Rule 4 (2012/2013 OTC Model). RIDEM originally
proposed the regulation to become effective on 1/1/2019. This was a very
short time to comply. The effective date was then changed to 1/1/2020 due
to Industry comments.
CARB suggests Control Measure
The California Air Resources Board (CARB) is proposing to update its suggested Control Measure
(SCM) on AIM Coatings. The first workshop was held in Sacramento on Nov. 7, 2018. The
outcome of this workshop will be reported next month.
CARB Survey results
We are still awaiting the release of the results from the 2015 Consumer Products Survey, which
are expected this month. Additionally, CARB Staff has stated it will also release some fragrance
data as well.
After the release and review of the survey data, we can likely expect to start the next rulemaking
in the second quarter of 2019.
Merry Christmas and Happy New Year to All! This year has gone by quickly; 2019 promises to
be another full year of regulatory activity. Spray
precisionglobal.com