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Regulatory Issues
Doug RaymonD
Raymond Regulatory Resources
summitpackagingsystems.com
8 Spray September 2018
Canada
On July 10, 2018, the Canadian Consumer Specialty Products Association
(CCSPA) held a meeting with Environment Canada & Climate Change Canada
(ECCC) concerning volatile organic compounds (VOCs). Representing ECCC was
Tracey Spacek, Mary Ellen Perkins, Marie-France
Nguyen, Joe Devlin, and Rasha Abu-Meizer and
Mohamad Najibeddine.
ECCC had a proposed regulation that was
published but never finalized. Now, eight years
later, ECCC is proposing to publish final
regulations on Consumer Product VOC
regulations that will mirror the current California Air Resources Board (CARB)
regulations; Mary Ellen Perkins is the lead for the ECCC on this project.
Its time frame is to publish the final regulation in the next year and have the
regulation enforced in two years. All of the current categories and limits will be in
the regulation except for the windshield washer limit and the future effective limit
for Multi-purpose lubricant, which will be at 25%.
Most of the meeting was spent discussing the need for regulations and the
cost. Industry tried to explain that going from no regulation to the strictest
regulations in the world for VOCs will likely harm or impact Canadian manufacturers
the most.
Industry proposed a two-tier set of limits—one using limits that are not as stringent
as the final limits that will be enforced in two years. ECCC did not appear to
be receptive to this type of approach.
Industry has gone back to the ECCC asking that a proper survey be conducted,
as it does not appear to have the information needed to propose a realistic VOC
regulation.
Industry will continue to work with ECCC to come to an agreement on a
Consumer Products VOC regulation.
CARB
The aerosol industry needed to respond to the California
Air Resources Board (CARB) survey information
that had been released earlier this year concerning survey
data from 2013 and 2014.
If you submitted data to these surveys, you should
review all of the documents to see if the information appears
correct. With the large amount of information that
was gathered, this is a difficult feat.
CARB wanted the information by Aug. 1 and will continue
to update this data throughout this fall 2018. Currently,
CARB staff is working on finalizing the 2015 survey data. This
should be released this fall.
CARB Aerosol 101
The aerosol industry presented an Aerosol 101 to CARB staff on Aug. 23. The
National Aerosol Association (NAA), with assistance from the Western Aerosol
Information Board (WAIB), the Personal Care Products Council (PCPC) and the
Household & Commercial Products Association (HCPA), presented an Aerosol
101 to CARB staff on Aug. 23. More on this in the next issue. Spray
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