CARB
The California Air Resources Board (CARB) continues its rulemaking on Consumer Products.
The category field has been reduced from 47 to 17. As reported last month, CARB staff has been
conducting webinars.
On Sept. 20, CARB held its first webinar; it dealt with fragrance usage and the use of HFC-
152a. Regarding fragrance, staff is adjusting the amount of volatile organic compounds (VOC)
in fragrance for several categories. In the past, CARB had always
considered all fragrances as 100% VOC. Because of presentations
from the fragrance industry, CARB is lowering the VOC percentage
to 25% for certain categories and a maximum incremental reactivity
(MIR) value of 2.8. For other categories, mainly cleaning and degreasing
products, the fragrance profile will be maintained at 100% VOC
and a 4.04 MIR value.
CARB staff will also be adjusting the overall emission inventory.
This change will affect the VOC reductions that were planned for the categories where the VOC
percentage has been reduced to 25%. Because this rulemaking is a “zero sum game,” emission
reductions that cannot be attained in these categories will then need to be attained in other
categories. The overall reductions from the entire category will likely not have any effect on the
emission reductions that are needed.
Regarding HFC-152a—it is an exempt VOC compound, but is, however, a slight global warmer.
Currently, CARB regulations for Consumer Product and Refrigeration do not consider this
compound as a global warmer due to its low global warming potential. CARB is concerned about
increasing the use of HFC-152a with any new reformulation options. This puts CARB in a tough
position because HFC-152a has been an option to replace VOC propellants in the past, especially
in personal care products. During the webinar, CARB staff explained the issue but did not discuss
what actions will be taken on HFC-152a. We will need to wait and see what staff has planned for
us on this compound.
On Oct. 2, CARB had another webinar planned to discuss the following categories: Aerosol
Crawling Bug Insecticide, Charcoal Lighter Fluid, Aerosol Cooking Spray, Floor Wax Stripper
and Paint Stripper. Staff had to cancel this webinar due to technical difficulties, so these categories
were added to the Oct.17 webinar. There was a positive outcome of this cancellation—CARB staff
provided slides with further information on these categories and you are encouraged to review
them.
On Oct. 4, CARB held an in-person workshop to discuss definitional changes to the regulation.
Both Industry and CARB had some suggestions. Currently, there are only a few definitions
that CARB wants to discuss: Institutional or Industrial Products, Metal Polish, Aerosol Adhesive,
Energized Electronic & Electrical Cleaner, Disinfectant/Sanitizer, General Purpose Degreaser
and Paint Thinner. In addition, CARB would like to discuss a broad look at labeling of products
(which means claims on your website).
CARB has requested comments on this workshop by Nov. 1. Now is the time to request any
changes that you need on this workshop.
Webinars will continue. By early November, CARB plans to have another in-person meeting to
share its schedule and categories for moving forward in product regulation. More importantly, we
expect to see the VOC limits and dates proposed for each category.
Remember, CARB needs four tons of VOC emission reduction per day by 2023 and a total of
eight tons of emission reduction per day by 2031. CARB’s needs may go up slightly. This is a significant
amount of reduction needed. CARB plans to finish this rulemaking by the end of 2020.
Canada, New York & New Jersey
Comments were due in early Fall. We are waiting for announcements.
Colorado
Remember, the New Consumer Products Rule and Architectural & Industrial Maintenance
(AIM) Coatings Rule is effective May 1, 2020. Spray
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 November 2019