Raymond Regulatory Resources
South Coast Air Quality Management District
The South Coast Air Quality Management District (SCAQMD) amended its Proposed Rule 1168 on Adhesive
On July 19, SCAQMD held a work group meeting on Rule 1168 where staff revealed that the Aerosol
Adhesive exemption would be maintained and proposed to restrict the use of Aerosol Adhesives in
manufacturing to 16 fluid ounces per day. SCAQMD staff stated that, after meeting with the California Air
Resources Board (CARB) staff, who are currently surveying and evaluating the current aerosol limits, that
SCAQMD staff would maintain the current exemption for Aerosol Adhesives.
This is great news! It means that all uses of Aerosol Adhesives in the SCAQMD are exempt from Rule
1168 volatile organic compound (VOC) limits. Even the uses of Aerosol Adhesives in manufacturing are
exempt. This is a very good thing.
As you may remember, what actions SCAQMD takes often move to the state level under CARB and even
across the country to the Ozone Transport Commission (OTC) states.
The proposed Rule 1168 still has reporting requirements for Aerosol Adhesives. In addition, it still
restricts the use of Non-Aerosol Adhesives that fall under the CARB Consumer Products Regulation from
being used in the manufacturing process; however these products can be used in repair and maintenance in
a manufacturing plant.
There was another workshop on Rule 1168 on August 17. More to follow.
On Aug. 1, CARB sent out the final fiscal year 2017–2018 VOC fee invoices to companies that reported
California sales of Consumer Products that contained more than 250 tons or more of VOC in the 2015
calendar year. This information was based on 2014 reporting to the CARB survey.
The final fee for 2017–2018 was $191.93 per ton. Companies have 60 days to pay the fee, which is higher
than the preliminary fee of $176 per ton and is based on the number of companies paying. CARB is authorized
8 SPRAY September 2017
to collect $17,922,000 per year from consumer products, facilities and architectural coatings. To review
the companies that have paid the VOC fee in the past, visit: http://www.arb.ca.gov/ei/nscpac_fees.htm.
The work on Ingredient Disclosure Bill SB258 continues. Industry is working on maintaining confidential
business information (CBI) status. As we go to press, I believe we will know more by the end of August.
Similarly, the bills that restrict butane are being amended. Currently, the use of butane in manufacturing
will be exempt, but we will need to wait and see how the bills wrap up.
The next Ozone Transport Commission (OTC) meeting is Sept. 7 in Washington D.C. On the agenda
will likely be the convening of the Consumer Products workgroup to discuss any changes to the Consumer
Products’ OTC Model Regulation.
Weights & Measures
The Weights & Measure requirement that all Bag-on-Valve (BOV) products be labeled by weight becomes
enforceable on Jan. 1, 2018. This means that as of this date, all BOV products need to declare their contents
Update: EPA SNAP Rule
On Aug. 8, there was a ruling on the EPA Significant New Alternatives Policy (SNAP) Rule (see Industry
News, p. 36–37 for more information on this ruling). The U.S. Court of Appeals for the District of Columbia
Circuit stated that the U.S. Environmental Protection Agency (EPA) had overreached its authority and
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