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 June 2016 CARB The Air Quality Planning & Science Division of the California Air Resources Board (CARB) has released guidance documents for the first time. These guidance documents were released to clarify specific sections of the regulations and address two areas: 1. Guidance pertaining to the 2% Fragrance Exemption and Limonene This guidance clarifies that compounds such as Limonene, that can act as a solvent for removing soils, cannot be counted as fragrances in cleaning products. This is important because there is a 2% fragrance exemption from the volatile organic compound (VOC) limit. Some marketers were considering Limonene as a fragrance and taking the 2% VOC exemption. However, when CARB Enforcement would test the product, its analysis would show that the product was over the VOC limit, especially now that the General Purpose Cleaner non-aerosol and the General Purpose Degreaser non-aerosol limits are at 0.5% VOC. This means if you use 2% d-limonene in your product, the product will be four times over the limit. Thus, the whole point of this guidance is that only compounds that “solely impart an odor or scent” receive the 2% VOC exemption. Solvents such as d-limonene do not get the 2% VOC exemption for fragrances in cleaning products. D-limonene can still be used in these products, but the amount counts towards the VOC limits. Likewise, d-limonene does get the 2% fragrance exemption in Air Fresheners. 2. Gear, Chain or Wire Lubricant product labeling This guidance clarifies what labeling is needed to qualify for exclusion from the definition of Gear, Chain or Wire Lubricant. Under this category, if a product is intended “solely” for use on chains of chain driven vehicles (such as a chain lubricant on bikes, motorcycles and ATVs), then the product is not subject to the VOC limit. This document clarifies the wording on the label required to be excluded from the category. Obviously, if you state on the chain lubricant label that the product is “solely for use on chain driven vehicles” and you do not put any other claims on the label to contradict this, then the product is excluded from the category and the VOC limit. Remember, no other claims can be on the label other than “use on a chain driven vehicle.” In addition, if the only claims on the label are for a chain driven vehicle such as a bike, motorcycle or ATV, then the product is also excluded from the category and VOC limit. Again, no other claims are allowed. This is very specific and needs to be adhered to closely. Enforcement has been monitoring these products directly. These guidance documents may appear straightforward, but there has been confusion over the years and Industry has been asking CARB for Enforcement Advisories on these issues, but with no luck. Hopefully, we can look forward to more Guidance documents in the future, as they clarify regulations and provide the regulated community (the aerosol industry) with a way to comply. This should prevent unwarranted enforcement actions. CARB SLCP On April 26, 2016, CARB held a public workshop in Sacramento, CA on the proposed strategy to reduce Short Lived Climate Pollutants (SLCP). The compounds included under SLCP are methane, black carbon and HFCs. The workshop began with an overview of the strategy proposed by CARB, followed by public comment. The majority of comments were on the strategy to reduce methane, followed by comments to reduce black carbon and only a handful of comments on HFCs. The proposed strategy requires a 50% reduction of emissions from black carbon sources and a 40% reduction of emissions from both methane and HFC sources. The HFC sources being targeted are all from refrigeration at this time. Even though consumer products and foam products are mentioned, CARB staff does not appear to have any strategy to reduce HFCs from consumer products. CARB Survey The last of the CARB Survey information will be due this November. Reporting will begin July 1, 2016 and end Nov. 1, 2016. CARB staff plans to have a webinar on June 29, 2016 from 10am–1pm. Register for the webinar here: https://attendee.gotowebinar.com/register/2508322842602324481. SCAQMD The South Coast Air Quality Management District (SCAQMD) is still moving forward on the Air Quality Management Plan. We need to review this plan carefully to ensure no Consumer Product elements are included. Spray formulatedsolutions.com
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