www.aeropres.com www.inhalant.org coster.com dscontainers.com diversifiedcpc.com ikimfg.com mbc-aerosol.com terco.com Regulatory Issues Doug Raymond Raymond Regulatory Resources summitpackagingsystems.com 8 Spray July 2016 CARB The California Air Resources Board (CARB) released its proposed 2016 State Implementation Plan (SIP). SIP is the state’s strategy to attain the Federal Air Quality Standards. SIP is what drives the state agency (CARB) and the districts (South Coast Air Quality Management District SCAQMD for one) to regulate sources of emissions. CARB is responsible to develop SIP strategies for cars, trucks and other mobile sources as well as consumer products. The districts are primarily responsible for developing SIP measures for Stationary Sources. Remember, the Federal Ozone Standard was just lowered last fall and this puts even more pressure on CARB and the Districts. Two districts in California (Southern Coast and the San Joaquin Valley) are the only two areas in the nation to be classified as Extreme; this is the worst classification possible. There is significant pressure on these two districts to reduce emissions; there is also pressure on CARB to reduce emissions for Mobile Sources (cars and trucks) and Consumer Products. Obviously, our major concern is Consumer Product emission reduction strategies. According to the proposed SIP strategy, Consumer Products are the largest source of Reactive Organic Gases (ROGS) in the state. Thus, CARB staff will explore ways to continue to reduce the reactivity of consumer products. Statewide, CARB is proposing to achieve a ten-ton-per-day reduction of emissions from Consumer Products by 2031. Currently, CARB staff is in the process of quantifying the actual emissions from Consumer Products and is using the survey data that all of you have been submitting. The data is vital to the work CARB is attempting to do. For it to be able to regulate Consumer Products, a comprehensive inventory is needed in order to accurately calculate all emission reductions. Thus, be sure to keep the survey data flowing into CARB. The proposed strategy on Consumer Products is especially vague and not much detail is given. The SIP strategy proposes to bring control strategies (regulations) to the CARB executive board between 2019–2021 to reduce emissions. The proposed implementation dates are scheduled for 2020 through 2023. This means if the staff is going to present regulations to the board in 2019, then we need to start working on regulation development in 2017 because it normally takes between 18 and 24 months to develop a regulation. The SIP strategy does state that CARB staff will investigate alternate compliance options to provide flexibility to the Industry. This flexibility will likely be needed because ten tons of emission reductions per day will be difficult to achieve. Remember, all the easy or low hanging fruit emissions have been taken. Staff and the Industry will need to work cooperatively together to achieve meaningful emission reductions that do not negatively affect the performance of our products. Comments were due on this proposed strategy by July 1, 2016. The third and final phase of the CARB Survey begins July 1 and ends Nov. 1, 2016. Make sure to review the website, as many categories have been removed or are exempt from 2015 reporting. Review at http://www.arb.ca.gov/consprod/regact/2013surv/2013main.htm. OTC The Ozone Transport Commission (OTC) held its Spring Meeting on June 3 in Philadelphia, PA. All the OTC member states were present with the exception of Washington, DC. The states discussed the new Ozone Standard and when new information would be needed for meeting attainment. No discussion was had on the litigation around the new standard. Regarding Consumer Products, there is still discussion on the voluntary program, however no movement has been made. The stationary committee is planning to have something for stakeholders to review by September. We will wait and see on that. Maryland Maryland has moved its proposed effective date from 1/1/2017 to 1/1/2018. Thus, the new volatile organic compound (VOC) limits will become effective on 1/1/2018. Spray formulatedsolutions.com
Spray July 2016
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