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Regulatory Issues
Doug Raymond
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray February 2018
We started out the year with a couple of meetings.
Department of Toxic Substance Control
On Jan. 8, the Dept. of Toxic Substance Control (DTSC) held a public hearing on its third proposed Priority
Product—Methylene Chloride Paint or Varnish Strippers. The hearing was held in Sacramento, CA at the
California Environmental Protection Agency building.
DTSC is working on the Safer Consumer Products Regulation,
which some will remember as “Green Chemistry.” The meeting
remained open until all speakers had presented and DTSC took
statements from both industry and non-governmental organizations
(NGOs). Industry commented on the adequacy of existing
regulations, issues related to hazard communication and deficiencies
in existing accident and injury information. Several public
interest NGOs entered testimony about the hazards of methylene
chloride. Listing it as a priority product would allow DTSC the
opportunity to work with industry to evaluate and minimize risks.
It will consider comment and make a decision. Once listed, manufacturers
have 180 days to conduct an alternatives assessment or
remove methylene chloride from products sold in California.
Written comments on the proposed regulation closed on Jan.
18, 2018. DTSC staff will review all oral comments and written
comments before proceeding with the regulation.
California Air Resources Board
California Air Resources Board (CARB) held a Public Workshop on Jan. 17, 2018 in Sacramento. The
public workshop was held to invite participants to comment on proposed amendments to the Consumer
Products regulations. These amendments propose to add an alternative compliance option for manufacturers
to meet the Multi-purpose Lubricant (MPL) future effective standard of 10% volatile organic compounds
(VOC).
The proposed amendment includes adding a reactivity limit that can be met as an alternative to meeting
the 10% mass-based limit. Reactivity limits measure the amount of ozone produced, unlike mass-based
limits that regulate the amount of VOC but do not measure ozone
creation. Therefore, a reduction in the reactivity of a product always
reduces ozone production. The same cannot be said for mass-based
reductions.
CARB staff has been working diligently on these proposed
changes. In this workshop, the proposed language was released
for review. This will likely be the last workshop on these proposed
changes. Included in the changes is a postponement of the limit until
July of 2019.
The next step will be a public hearing in front of the CARB Executive
Board to approve these changes, scheduled for May 2018.
CARB also released the 2014 Architectural Coating Survey data.
The survey collected data from architectural coating companies that
sold products in California during 2013. The survey can be viewed
at https://www.arb.ca.gov/coatings/arch/survey/2014/2014survey.
htm?utm_medium=email&utm_source=govdelivery
This survey will likely be used to develop a new model Architectural
Coating Suggested Control Measures. Timing on this development
is unknown.
Ozone Transport Commission
The Ozone Transport Commission (OTC) is in the process of developing yet another Model Rule, with
plans to have it ready by the end of the first quarter of 2018. OTC Model Rules now number three; we need
to work with the OTC to narrow the number of Model Rules out there. Spray
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