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Regulatory Issues
Doug RaymonD
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray October 2018
CARB 101
In August, the aerosol industry, led by National Aerosol Association (NAA)
with the assistance of the Western Aerosol Information Bureau (WAIB) and the
Household & Commercial Products Association (HCPA), held an Aerosol 101 for
the California Air Resources Board (CARB) staff. Read more about this on p. 34.
It is significant to realize that the aerosol industry needs to provide this type
of education to the people that regulate our products. I believe that the CARB
regulations have probably been the single largest influence on aerosol products
over the last 30 years. This will likely continue to be the case. Therefore, industry,
as the experts on these products, needs to provide knowledge on the product
categories that CARB is interested in learning about.
At the Aerosol 101, we had more than 700 years of aerosol experience from
industry alone. The meeting went extremely well. There was a full day of presentations
with approximately 25 CARB staff and two members of the Dept. of
Substance Control (DTSC) in attendance. There were many good questions asked
and it was a conducive setting to have a meaningful discussion, especially concerning
the categories CARB asked about: dry shampoo, body sprays, sunscreens, hair
sprays, disinfectants and electrical and electronic cleaners.
It was a great meeting; now we need to start planning an Aerosol 201.
CARB Survey
CARB staff is working on completing the 2015 survey data. They have been
contacting companies concerning the 2015 data in order to try to get this process
finished. Therefore, you may be getting a call from CARB staff if your company’s
information is not complete.
CARB is attempting to get the 2014 data finished by November 2018. This
means we will likely start rule development some time in 2019. Make sure you
review the survey data on your company’s product categories and start to get
prepared for 2019.
Remember to consider Reactivity when looking at options for reformulations.
Ozone Transport Commission
The Ozone Transport Commission (OTC) held its most recent meeting on Sept.
21. It was held online, which was a new venture for OTC. More on this meeting
in a future issue.
Canada
There are currently two issues with Canada.
VOC Regulation
I have been working with Environment & Climate
Change Canada (ECCC) on developing a
Consumer Product Volatile Organic Compound
(VOC) Regulation. These regulations will likely
mirror the current CARB regulation. The process is moving along, as I’m currently
working on definitions with the agency. Updates to follow.
HFCs
I have also been working with the ECCC to get some amendments to hydrofluorocarbon
(HFC) regulation in Canada. This has been a very slow process. Updates
will be forthcoming soon. Spray
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