www.aeropres.com www.inhalant.org dscontainers.com diversifiedcpc.com formulatedsolutions.com ikimfg.com mbc-aerosol.com terco.com Regulatory Issues Doug RaymonD Raymond Regulatory Resources summitpackagingsystems.com 8 Spray June 2017 CARB Fee On May 1, the California Air Resources Board (CARB) released the preliminary volatile organic compound (VOC) determinations for the 2017–2018 fiscal year. Companies whose total annual sales in California are 250 tons or more of VOC emissions are subject to the fee, which is based on the total VOC content of all Consumer Products sold in 2015. CARB used the reporting data from 2014 Survey data. The preliminary fee amount is $176 per ton. This may change if CARB makes changes to the number of companies paying the fee. If you receive this fee and do not think your VOC emissions warrant it, then you need to question CARB within 60 days of May 1, 2017. Failure to respond in 60 days forfeits your right to dispute the fee. Review closely and respond accordingly. CARB LVP-VOC Seminar Low vapor pressure-volatile organic compounds (LVP-VOCs) are a set of VOCs currently exempted for VOC content based on a combination of boiling point, vapor pressure and/or elution time from a gas chromatography (GC) column. David Cocker, PhD., from the University of California Riverside (one of the researchers that did studies on LVPs) gave a recent talk on LVP-VOC at CARB headquarters. It was webcast on May 16. This study explores evaporation rates and secondary pollutant formation from a series of individual LVP-VOCs associated with consumer products, select generic consumer products that include these LVP-VOCs and several hydrocarbon solvents. For more information, visit: http://www.arb.ca.gov/research/seminars/cocker/cocker.htm. I will report on the talk next month. South Coast Air Quality Management District The South Coast Air Quality Management District (SCAQMD) held a working group meeting on May 10 on Proposed Amended Rule 1168: Adhesives & Sealants. At this workgroup meeting, stakeholders were able to discuss and have the opportunity to provide comments to the amendments. I will report on this next month and whether the amendments dealt with tertiary butyl acetate (tBAc) issues and any other amendments that were proposed. Legislative Bills in California This is the time of year when legislative bills are moving through the California Legislature. We monitor the bills and make comment. Historically, what happens in California then heads east across the country. Below are three bills we are tracking. Ingredient disclosure • Senator Ricardo Lara introduced Senate Bill (SB) 258. The bill—known as the Cleaning Products Right to Know Act of 2017—requires full ingredient disclosure on the label for retail products and also affects institutional products. Therefore, the majority of cleaning products will be affected. These types of bills have been coming up since about 2010. Every year it appears that the bills gain more strength. We need to make an effort to try and find a solution to this issue. In the meantime, we need to monitor and comment on these bills to ensure that our business is not interrupted by these actions. Stay tuned for more info. Bills on Butane • Currently, two bills are in the legislature to restrict the sale of butane in California. Why, you ask? Butane is used to make hash oil and its use has been associated with house explosions. The first bill is Assembly Bill 1244 introduced by Assembly member Voepel. This bill requires an odorant be added to butane to discourage its use in producing hash oil. Obviously, we cannot have an odorant in butane propellants. Currently, propellant suppliers Aeropres and Diversified CPC are actively working with the author’s office on this issue. It has just become a two-year bill, meaning passage this year is unlikely, and we have time to amend it. • The next bill is Assembly Bill (AB) 1120, introduced by Assembly Members Cooper and Dale. This bill prohibits the sale of more than 600 milliliters of butane in a month. Obviously, the authors have not considered butane as a propellant. The bill has been amended to exempt manufacturers who re-package butane. Thus, the use of butane in aerosol products is exempted. Ozone Transport Commission Connecticut The State of Connecticut updated its proposed Consumer Product Regulation. The largest change was to the compliance date; the new effective date is May 1, 2018 changed from May 1, 2017. Another change suggested that the proposed rule removed seven product categories from the chlorinated compounds ban. The proposed rule can be reviewed at: https://eregulations.ct.gov/eRegsPortal/Search/RMRView/ PR2015-196. Ohio Remember, the State of Ohio is reviewing its Consumer Products regulation. Comments were due by April 25. We will likely hear something in the next 1–3 months on what, if any, action will be taken. Currently, Ohio is in compliance for ozone emission, thus no further action is required, but let’s see what the State thinks.
Spray June 2017
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