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Regulatory Issues
Doug RaymonD
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray January 2019
Happy New Year! Expect a very busy year in the regulatory world. The California Air Resources Board
(CARB) and Canada will be developing volatile organic compounds (VOC) regulations. The U.S. Environmental
Protection Agency (EPA) will be developing a new Significant New Alternatives Policy (SNAP) rule
and California and New York ingredient rules become effective.
CARB
On Dec. 6, 2018 CARB staff released Draft 2015 survey data for stakeholder review and feedback. This
information, as well as the 2013 and 2014 data already released, provided a detailed summary of consumer
product sales emissions, VOC content, chemical speciation and reactivity on more than 400 categories
of consumer products. More than 1,500 product manufacturers and formulators provided data for these
surveys, providing information on more than 300,000 products sold in California.
Industry now needs to review this data for any glaring discrepancies and report them back to CARB
staff.
CARB will hold a public webinar to discuss this survey data on Jan. 15 from 9:30am to 11:30am PST.
Remember, this is the information that will be used as CARB develops its next set of VOC amendments
to its Consumer Products Rule.
Also, remember that the Multi-purpose Lubricant future effective limit of 10% VOC or 0.45 maximum
incremental reactivity (MIR) limit becomes effective July 1, 2019. There are reporting requirements if you
use the 0.45 MIR option to comply.
Colorado
On Nov. 13, 2018, the Colorado Dept. of Public Health & Environment, in conjunction with the Regional
Air Quality Council, held a stakeholders’ meeting for the Consumer Products and Architectural &
Industrial Maintenance (AIM) Coatings industry. These two agencies will be working together to develop a
VOC regulation on Consumer Products and AIM Coatings.
The agencies explained their non-attainment status with the 2008 and 2015 ozone standard and, therefore,
their need to develop more ozone reductions in the area. It is mainly the area around Denver that is
not in attainment. The agencies are looking to use the Ozone Transport Commission (OTC) Model Rules.
The timing for rule development is sometime in first quarter of 2019.
NOAA
On Nov. 14, 2018, the American Coatings Association (ACA) and the National Aerosol Association (NAA)
met with the National Oceanic & Atmospheric Administration (NOAA) in Colorado. This is the group
that authored the paper in Science magazine that stated Consumer Products and AIM emissions are a
significant source of VOC emissions.
Dave Darling from ACA set up the meeting with the Director of NOAA and invited NAA to participate.
The meeting opened with an introduction to NOAA by its Director; it appears to be an impressive science
organization. Darling then presented AIM emissions data stating that what NOAA had reported appeared
high in emissions compared to CARB data. Regarding Consumer Products, the speciation of the products
appeared “off,” which led to higher emissions reporting.
Industry suggested that CARB information from its numerous surveys be reviewed. Hopefully, there is
a potential for CARB and NOAA to work together to get a better picture of AIM and Consumer Products
emissions. Thanks to Dave Darling from ACA for setting up the meeting.
SNAP
The U.S. EPA is working on a new SNAP Rule. Its original release date was to be January of 2019. This will
likely be delayed until possibly March of 2019. After the release, Industry will likely have 60 days to review
and comment. The saga continues.
CARB Date Code
This is my annual friendly reminder regarding Product Dating/Date coding. Date code information needs
to be reported to CARB every year by your company if you do not use CARB’s standard date coding.
California Section 94512 (b) product dating specifically requires all consumer products designated to be
sold into the state to display the day, month and year the product was manufactured or a code indicating
the date. CARB has been increasing its investigative activity and levying fines for non-compliance of this
section.
Continued on page 47
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