CARB
Multi-purpose lubricant
As of July 1, 2019, any Multi-purpose Lubricant product manufactured must meet new volatile organic
compound (VOC) standards in California, according to the California Air Resources Board (CARB). The
new limits are either 10% VOC by weight or the Alternate Compliance option of 0.45 maximum incremental
reactivity (MIR) content with a maximum of 25% VOC.
If you did not register your product 90 days before July 1, 2019, you must then register your product after
July 1, 2019 and wait 30 days to sell the new reformulated product into California.
New Rule Development
On April 12, CARB kicked off a new rulemaking. CARB staff has identified 47 categories out of 491 categories
that have more than a half of ton per day of emissions that could be targeted for emission reductions. In
May 2019, CARB had four calls with Industry that covered 16 categories and will have had 11 calls altogether
going into July. These calls are an attempt to share information and be able to whittle down the 47 categories
to a number deemed reasonable for regulation. So far, Industry has been very reluctant to disclose any information
to CARB staff during these calls.
Whether you are involved with these categories or not, you should pay attention to what is happening with
each category. The simple reason is that this is a zero sum rulemaking—what one category does not give up
in emission reductions means that another category will then need to provide further emission reductions.
CARB staff stated before each call that the goals it needs to achieve are the following:
• 2–4 tons per day emission reductions statewide by 2023
• 8–10 tons per day emission reductions statewide by 2031
• This is cumulative, not additive, therefore the desired total is 8–10 tons
CARB is open to reactivity and other emission reduction strategies.
Also, further meetings will be scheduled in July to discuss definitional changes and other issues such as low
vapor pressure (LVP) exemptions and fragrance exemptions. Josh Berghouse of CARB is leading this entire
rulemaking, which is scheduled to be complete by the end of 2020.
Colorado
On May 21, 2019, the Colorado Air Quality Control Commission (CAQCC) held a status conference meeting
in Denver to discuss the adoption of its new Regulation No. 21, which proposes to regulate Consumer Products
and Architectural & Industrial Maintenance Coatings (AIM).
At the meeting, CAQCC explained the timeline for Regulation No. 21 adoption. There was also a discussion
of changes to the regulation. Several Industry members were present who expressed the following
concerns:
• Rules for Consumer Products and AIM Coatings, currently together, need to be separate.
• CAQCC should adopt the regulation in steps, such as Ozone Transport Commission (OTC) Model Rule 2,
followed by OTC Model Rule 4.
• Finally, the effective date needs to be at least a year after adoption. The next meeting was June 18 and the
hearing for adoption is July 18. The proposed effective date is May 2020.
New York
On May 29, 2019, the New York State Dept. of Environmental Conservation Division of Air Resources (DAR)
announced that it will be revising its Consumer Products Regulation. DAR had a very short webinar on this
issue. It appears DAR will be proposing going to OTC Model Rule 4, which is not the strictest rule. DAR said
the rule will be out soon and that the effective date is proposed for Jan. 1, 2021. DAR plans to have the rule
adopted by the end of 2019. More to come.
Canada
On May 8, 2019, Industry once again met with Environment & Climate Change Canada (ECCC) on its
proposed Consumer Products VOC Rule. Industry is still pushing ECCC to adopt all CARB definitions to
the Consumer Products VOC rule. ECCC is proposing to shorten or eliminate the definitions altogether. So
far Industry and ECCC agree on the following:
www.aeropres.com
dscontainers.com
diversifiedcpc.com
formulatedsolutions.com
fluorineproducts-honeywell.com/
solstice-propellants
ikimfg.com
lindalgroup.com
powercontainer.com
precisionglobal.com
terco.com
Regulatory Issues
Doug RaymonD
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray July 2019
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