Spanish aerosol production
shows slight uptick...
Asociación Española de Aerosoles (AEDA) recently
released Spain’s aerosol production statistics for
2019. AEDA estimated that 2019
production totaled 328.8 million units, up
0.09% from 328.5 million in 2018. Statistical
breakdowns for various product categories
were not available. The research was
conducted by LANT Abogados on behalf of
AEDA. Spray
Pintyplus HOME, a range of water-based spray
paints from Novasol Spray, launched in 2019.
January 2021 Spray 29
Regs
Continued from page 8
Aerosol Crawling Bug
• Aerosol Crawling Bug category
o VOC limit proposed 8% in 2030
o CARB raised the proposed VOC limit from 6%
• Bed Bug category: a new product category formed in this rule
development
o VOC limit would remain at 15% after 2030
Two Percent Fragrance Exemption
The 2% Fragrance Exemption is proposed to sunset as of 2031 for
most products except:
• Non-Aerosol General Purpose Cleaners and General Purpose
Degreasers
o These two categories are proposed to be granted a 0.25%
monoterpene exemption that will be retained after 2031 and
effective immediately after the rule is approved
• Air Fresheners, Disinfectants and Sanitizers
o These categories are proposed to retain a 0.25% fragrance
exemption after 2031
Definitions
There were changes to some of the above categories in order to
clarify existing and new product categories. You are encouraged
to read the draft language of the regulation; see the end of this
column for the link.
MIR table
There are three compounds proposed to be added to the maximum
incremental reactivity (MIR) table:
1. Diethyl Carbonate
2. HFO-1233zd
3. Alkane-Mixed Minimally 90% C13 and higher carbon number
Chlorinated solvents, GWP and PCBTF prohibitions
CARB is proposing to prohibit the use of chlorinated solvents,
global warming potential (GWP) compounds greater than 150 and
parachlorobenzotrifluoride (PCBTF) in the product categories having
proposed new VOC limits.
IPE for compressed gas
CARB is proposing the use of the Innovative Product Exemption
(IPE) for allowing the replacement of HFC-152a with CO2,
nitrogen or compressed gas as a way to reduce GWP emissions.
Currently, as written, the proposal is flawed. Significant work will
be needed to make this proposal feasible.
Energized Electrical Cleaner
CARB has modified its proposal for the definition for this category,
proposing to prohibit the use of this product in automotive
repair shops as well as sales from automotive retailers. While this is
draconian wording, remember that since 2001, use of chlorinated
solvents in automotive repair shops has been prohibited. The
sales prohibition for automotive retailers is unfortunate. However,
this wording allows the sale of this product by other compliant
retailers. Thus, electricians and others can still purchase this safety
product for use around energized equipment and it will remain
available.
Aerosol PVC Pipe Cement
This is a new product category formed in this rule development.
The proposed 60% VOC limit will be effective as soon as regulation
is approved.
Multi-Purpose Solvent
A new provision is being added to the Multi-Purpose Solvent definition.
This new provision exempts denatured alcohol products to
public utilities.
Web-based claims
Big News! CARB is delaying work on using the website to classify
products. This has been a significant issue for the Industry.
Method 310
Method 310 has been totally rewritten; industry needs to review all
of the changes.
Next steps
• Comments were due by Nov. 24, 2020
• Jan. 8, 2021: The 45-day public comment period will begin with
CARB releasing its final draft
• Feb. 25–26, 2021: There will be a CARB Board hearing for
adoption of draft
Summary
Now is the time to comment on these draft amendments. Take
the opportunity now to review the slides and draft wording. All
the documents can be found at: https://ww2.arb.ca.gov/our-work/
programs/consumer-products-program/consumer-products-regulatory-activityworkshops.
This is likely the final draft and we need to review what is
published on Jan. 8, 2021. Spray