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Regulatory Issues
Doug Raymond
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray May 2018
MPL
On April 3, 2018, The California Air Resources Board (CARB) released a 45-day notice for amendments
to its Consumer Products Regulation. These amendments mainly have to do with the multipurpose
lubricant (MPL) future effective limit.
CARB staff has been developing an Alternative Compliance Option for the MPL future effective
limit to provide flexibility for manufacturers to meet the requirements of the 10% by weight volatile
organic compound (VOC) limit for MPL products. The alternative compliance option would allow
manufacturers to comply by meeting a 25% by weight VOC limit and a reactivity limit of 0.45 grams
of ozone per gram of product. Staff is also proposing to extend the effective date of the existing 10%
by weight VOC limit from Dec. 31, 2018 to July 1, 2019 to provide adequate time for manufacturers
of MPL products to evaluate their products and decide whether to comply via the alternate compliance
option. Additionally, staff is proposing to prohibit the use of compounds with high global warming
potentials (GWP) in MPL products.
CARB staff is proposing amendments to the consumer products regulation to achieve three objectives:
the first is to maintain ozone air quality benefits and the benefits claimed in the State Implementation
Plan (SIP) that the 10% VOC limit would achieve. The 10% limit was expected to result
in 1.27 tons per day reduction in VOC emissions, which were claimed as part of the SIP submitted
to the U.S. Environmental Protection Agency (EPA) in 2010. The proposed amendments help ensure
that the emissions from products using the alternate compliance option have equal or less forming
potential than the 10%-by-weight compliant products.
The second objective is to provide compliance flexibility to manufacturers that would enable them
to continue to offer effective products to consumers but achieve similar ozone air quality benefits to
those that comply with the mass-based 10% by VOC weight limit.
The third objective is to achieve these goals without significantly impacting compliance costs or
increasing the cost of MPL products on the market.
The proposed amendments achieve all of the above. The use of the Reactivity Concept for reducing
ozone formation from consumer products is sound science. Any reduction in the maximum incremental
reactivity (MIR) value of a consumer product is also a reduction in ozone formation.
The public may present comments in writing from April 6–May 21, 2018 (5pm PT). Additionally
the public can comment at the board hearing on May 25 in Sacramento, CA.
Survey data
CARB staff has been working on finalizing the survey results from 2013 and 2014. We will likely see
the results in early May (hopefully).
The survey results will give us good insight into the next product categories that will be targeted for
VOC emission reduction in the next CARB rule development (to be completed in the 2020 timeframe).
In addition, this survey data should be an update to the actual consumer product emissions
in California, unlike the article in Science Magazine that was released earlier this year. By the way, no
mention of the Science Magazine article was made at the March CARB meeting, even though the meeting
was in Southern California and the South Coast Air Quality Management District (SCAQMD)
had the opportunity to comment. This was good news.
CARB Guidance Document on Fragrances
CARB’s Guidance Document on Fragrances is still being compiled. The document explains how to
treat certain compounds in your cleaning products. Discussions continue and future meetings are
likely. Stay tuned for more information.
Ozone Transport Commission
The Ozone Transport Commission (OTC) has been working on developing a new model rule for
Consumer Products. The chairman of the Stationary Source Committee for OTC was Ali Mirzakhalili
from Delaware. Mirzakhalili has since taken another job and is no longer in Delaware. Now we will
need to wait and see when or if a new model rule comes out. More on this in the next issue. Spray
precisionglobal.com