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Spray July 2016

Frauenheim July 2016 Spray 35 of tireless service to the CSMA Aerosol Division and CSPA Aerosol Products Division, serving as Division Chair, Committee Chair and Active Committee Member working to support the aerosol product form and promote the safe manufacture of aerosol products.” Sara Stickler, Executive Director of the Alliance for Consumer Education (ACE) gave an organizational update. ACE reached over 20 million consumers of all ages and stages in 2015 and 6.5 million consumers in Q1 2016 through its online and social media presence. ACE’s flagship program—the Inhalant Abuse Prevention Program—is now 15 years old and the Inhalant Abuse prevention kit is being reworked. Its goal is 100% awareness of the risks, dangers and effects of inhalant abuse. The Disease Prevention Program continues to help improve health through outreach and hygiene education and the upcoming Product Stewardship Program aims to increase consumer awareness of the full benefits of products through sustainable and responsible use, storage and disposal. Stickler urged CSPA members to get involved and sponsor ACE through engagement in its Operations Team and by spreading the word through the industry. Drew Lausch, U.S. EPA, Office of Resource Conservation & Recovery, Retail Sector Strategy, presented EPA RCRA Hazardous Waste Regulations of Aerosol Cans. The EPA published a Notice of Data Availability for the Retail Sector on Feb. 14, 2014 to better understand stakeholder concerns/ viewpoints regarding challenges the retail sector faces when complying with the Resource Conservation & Recovery Act (RCRA) regulations. A total of 44 comments were received from various stakeholder; the CSPA provided comments with a focus on aerosol cans. The EPA is developing a strategy to address the unique challenges faced by the retail sector in complying with RCRA regulations and this includes management of aerosol cans. A strategy will be released to the public, and in the meantime, EPA has already been implementing many aspects of this strategy. The propellant and/or product found in aerosol cans may be designated RCRA hazardous waste if disposed. A major retailer has estimated that aerosols constitute approximately 50% of total retail facility hazardous waste by pounds and 40% of the total items managed as hazardous waste. Information available to EPA indicates that the retail sector generates as much as 43 million pounds per year of aerosol cans as hazardous waste. However, explained Lausch, both the can and propellant can be recycled: the can as scrap metal and the propellant as a fuel (propane and butane for example). The actual product or contents of the aerosol can also have the possibility of being recycled. Some states, such as California and Colorado, manage aerosol cans as universal waste; these regulations that streamline the hazardous waste management standards for certain categories of hazardous waste that are commonly generated by a wide variety of establishments. Feedback from California and Colorado indicates that management of aerosol cans as universal waste works well and the EPA is exploring the potential for adding aerosol cans to the federal universal waste regulations. EPA also plans to clarify how existing federal RCRA regulations apply to the management of aerosol cans. Jim Bloome, Engineering Consultant, R. A Jones/Aerofill presented CSPA Propellant Safety Manual: Considerations for Effective Handling in the Plant & Laboratory, Fourth Edition. Re-write goals for the fourth edition included updating the Bloome manual per the latest versions of relevant standards and include new standards, especially NFPA 30B; incorporating the latest trends and industry practice; expanding to include new propellants now available; incorporating recommendations for compliance with new regulations; and adding to the definitions needed with new material. Over 50 codes, standards and industry guides were researched and referenced. There are 171 specific references tied to the text with exact location in the reference at the end of each chapter of the manual. The manual is available as a download at: http://www.cspa.org/ product-category/publications/ Bill Frauenheim, VP, Operations, Diversified CPC & Chair, ARR Executive Board presented Alliance for Responsible Regulation (ARR): Update on ARR, SCAQMD & CARB Activities. ARR Activities in 2015-2016 include: Legal/Advocacy • Monitoring development of South Coast Air Quality Management District (SCAQMD), Air Quality Management Plan (AQMP) and California Air Resources Board (CARB) state implementation plans (SIP) Lausch Stickler The 103rd CSPA Annual Meeting will take place Dec. 4-8 in Fort Lauderdale, FL (Continued on P.47)


Spray July 2016
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