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 May 2017 CARB The California Air Resources Board (CARB) announced the appointment of Joseph Calavita as Supervisor of the Implementation Section in the Consumer Products & Air Quality Assessment Branch of the Air Quality Planning & Science Division, effective March 20, 2017. He replaces Dave Edwards. In his new role, Calavita will be responsible for implementing CARB’s consumer products regulations. Sixteen years of experience working at CARB in multiple and varied programs have provided Calavita much experience in development of innovative emission reduction strategies. He worked in the Mobile Source Control Division, where he led the development of CARB’s Innovative Technology Regulation. Prior to that, Calavita was lead staff for the Air Quality Improvement Program and the Carl Moyer Program. He has been a liaison to U.S. Environmental Protection Agency (EPA) Region 9 and has also worked in the Office of Legislative Affairs. Calavita earned a Bachelor’s degree in Economics from the University of Vermont, and Master’s degrees in Atmospheric Science, as well as Environmental Policy, from Indiana University. SIP As reported last month, on March 23–24, CARB held a Public Hearing of its Executive Board to adopt a new State Implementation Plan (SIP). The SIP is the guiding document for new CARB regulations. The section of the SIP that deals with Consumer Products was relatively vague, wherein the commitment for further volatile organic compound (VOC) emission reduction was labeled as Not Yet Quantified (NYQ). This is a change from previous documents, which had listed a one-to-two tons per day emission reduction, but the new document only listed “NYQ”. Is this good or bad? I interpret this as being good, because it means there is no “hard” number to meet. However, CARB has committed to go to its Board with an action on VOC emissions reductions between 2019–2021. Late in 2017, CARB staff will likely release the results of the Consumer Products Survey. This will start the process of trying to determine if or how much emission reductions can be obtained from the remaining inventory of Consumer Products. Great news—there is still no mention or hint of changing the low vapor pressure (LVP) VOC status. SLCP At the same board meeting in March, CARB also adopted its strategy to reduce short-lived climate pollutants (SLCP). SLCP are black carbon, methane and hydrofluorocarbons (HFCs). There are no specific commitments that affect aerosols in the plan; however, aerosols are mentioned. The plan focuses on refrigeration and the concern is that, if the decrease cannot be fulfilled through a reduction in refrigeration, CARB will then look next at aerosols. Therefore, we need to be vigilant and monitor this regulation closely. Hopefully, the methane and black carbon issues will keep CARB staff busy for a long time. DTSC The Dept. of Toxic Substance Control (DTSC) in California is moving on its second Priority Product regulation, which is Spray Polyurethane Foam System with Unreacted Methylene Diphenyl Dilisocynates. DTSC has announced the public comment period for this product opened at 8:00 am PDT on March 24, 2017 and will end at 5:00 pm PDT on May 16, 2017. DTSC will hold a public hearing from 1:30 PM–3:30 PM PDT on May 16, 2017 at the CAL EPA Building on 1001 “I” street, Sacramento, CA 95814. DTSC submitted the following documents to the Office of Administrative Law for review: • Notice of Proposed Action (NOPA) • Proposed Regulation Text Ohio Rule On March 24, the Ohio EPA released an Early Stakeholder Outreach notice regarding its review for the Ohio Consumer Products Rules (OAC Chapter 3745-112). Ohio EPA has acknowledged that it has just begun the review process and is not aware of any major modifications necessary at this time. What will likely happen is Ohio will adopt the current OTC regulation. Let’s wait and see. Please review this notice and the current rule as it is today. Deadline for comments was April 25.
Spray May 2017
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