Southern Aerosol Technical Association September 25, 2015 Hilton
Head, South Carolina Aerosol Regulatory Update: Doug Raymond
Raymond Regulatory Resources (3R), LLC Slide 2 Major Industry
Issues Ozone Standard District CREEP LVP issue All others
manageable Slide 3 Ozone Standard Current Standard 75 ppb EPA
proposing to lower standard to 65- 70 ppb Industry working on
delaying this issue What are the implications of the change? Slide
4 Current Designated Ozone Nonattainment Areas As of 12/05/2013;
Based on data accessed from
http://www.epa.gov/airquality/greenbook/index.html on 6/2/2013
http://www.epa.gov/airquality/greenbook/index.html 227 counties in
46 areas Population = 123,003,795 (2010 US Census) 7 percent of US
counties 39 percent of US population Slide 5 Monitored Areas
Exceeding and Un-Monitored Areas Estimated To Exceed 65 ppb Slide 6
Industry Message Delay revision until all regulations are
implemented Determine benefits of regulations Then base the
revision on sound science, appropriate cost/benefit considerations
Slide 7 EPA Being pushed to reduce the standard passed 65 ppb-to 60
ppb Many environmental groups commented EPA needs Final Rule by
October 1 Slide 8 District Creep Industry has worked w/CARB since
early 90s on Consumer Product Rules Cannot let Districts regulate
Consumer Products District Regulation would be unmanageable 8 Slide
9 SCAQMD attempted several times to regulate Consumer Products Who
Remembers Lighter Fluid early 90s Aerosol Coating early 90s 9
District Creep Slide 10 District successful in 2010 Paint Thinners
Multi-Solvents District Successful in 2013 Further regulate LVPs
out of above categories Slide 11 District Creep District tries in
2014 Adhesive Rule 1168 All Adhesives not regulated by CARB
District Suspends Rule Slide 12 District Creep Industry galvanizes
together to try and prevent further regulation Meetings in February
and July To Date Successful (shocking) AQMP does not call for major
VOC reductions Slide 13 District Creep Slide 14 Consumer Products
and the LVP Exemption California Air Resources Board (CARB) and the
US EPA have defined certain volatile organic chemicals (VOCs) as
low vapor pressure (LVP) Has a vapor pressure of less than 0.1 mm
Hg at 20 C, or Consists of more than 12 carbon atoms, if the vapor
pressure is unknown. For ingredients which have a boiling point
above 216C LVP-VOCs are typically excluded from VOC limits when
used in consumer products. Slide 15 LVP Issue SCAQMD claims LVPs
should not be exempt Currently studies being conducted Doug Fratz
to explain studies Slide 16 LVP Issues ImplicationGame Changer LVPs
used to set majority of limits If LVP definition changes Guess
What? Slide 17 LVP Issue Slide 18 Issues Slide 19 CARB Survey
ongoing Next Deadline November 1, 2015 Doug Fratz will explain more
Slide 20 CARB Future Effective Limits 2016 Aerosol Multi-purpose
Solvent & Paint Thinner 2017 Aerosol Adhesives 2017 Aerosol
Coatings Slide 21 SCAQMD Working on AQMP Map for future Good News
Minimal VOC Reductions Does not attack LVP Doug Fratz will explain
Slide 22 SCAQMD Rules Currently 1168 on Adhesive is on hold Rule
1177 on LPG Gases amendments being considered Rule 1161 Mold
Releases coming next year likely First Quarter Remember Aerosols
exempt Slide 23 Snap Rule EPA Significant New Alternatives Policy
amended Amendments target HFC-134a use in aerosols Rule released on
July 20, 2015 Most Products have until July 20, 2016 Slide 24 SNAP
Rule Cleaning products for removal of grease, flux and other soils
from electrical equipment or electronics. Refrigerant flushes
Products for sensitivity testing of smoke detectors. Products
containing corrosion preventative compounds used in maintenance of
aircraft, electrical equipment, or electronics or military
equipment. Duster products specifically for removal of dust from
photographic negatives, semi conductor chips and specimens under
electron microscopes or for use on energized electrical equipment.
Adhesives and Sealants in large canisters. Lubricants and Freeze
sprays for electrical equipment or electronics. Products for
Aircraft maintenance. Products that retain the use of HFC 134a
Slide 25 SNAP Rule Pesticide products for use near electrical wires
or in aircraft, in total release insecticide foggers, or in
certified organic pesticides for which EPA has specifically
disallowed all other lower GWP Propellants. Mold release products
and mold cleaner products. Lubricants and cleaners for spinnerets
for synthetic fabrics. Products for document preservation sprays.
MDIa approved by the FDA for medical purposes. Products for wound
care sprays. Topical Coolant sprays for pain relief. Products for
removing bandage adhesive from skin. Products that retain the use
of HFC 134a Slide 26 SNAP Rule Products not getting extra time Tire
Inflators Air Horns Silly String Some of the amendments push
compliance to 1/1/2018 for specific products Slide 27 SNAP Rule
Good News!!! Any product made before the effective date can be sold
through. No drop dead date! Slide 28 California Weighs In! BUT WAIT
Slide 29 CARB Developing regulation for Short-Lived Climate
Pollutants (SLCP) Targets Methane, Carbon Black & F-Gases
Meeting held in June Draft Strategy due in fall of 2015 Slide 30
CARB SLCP Industry cannot let CARB interfere w/SNAP amendments on
F-Gases Need to monitor & comment CARB likely to push for more
then the SNAP Rule Slide 31 California Legislation AB 708 called
for Ingredient Disclosure Required 20 most prevalent ingredients on
the label for Automotive & Cleaning products Industry wide
opposition successful for NOW Bill now a 2-year bill Likely need to
work on this fall Slide 32 Safer Consumer Products Regulation
Strives to reduce toxic chemicals in products consumers buy and use
Identifies specific products containing potentially harmful
chemicals and asks manufacturers to answer two questions: Is this
chemical necessary? Is there a safer alternative? Requires
manufacturers to conduct a thorough analysis of alternatives to
make sure they don't pose environmental or health problems. Slide
33 Initial Priority Product Work Plan March 2014 Spray Polyurethane
Foam (SPF) Systems containing unreacted diisocyanates Childrens
Foam Padded Sleeping Products containing Tris
(1,3-dichloro-2-propyl) phosphate or TDCPP Paint and Varnish
Strippers with methylene chloride Slide 34 Draft Work Plan Sept.
2014 Addresses categories from which additional products will be
selected over the next three years Beauty, Personal Care and
Hygiene Products Building Products: Paints, Adhesives, Sealants,
and Flooring Household, Office Furniture and Furnishings Cleaning
Products Clothing Fishing and Angling Equipment Office Machinery
(Consumable Products) Slide 35 Draft Work Plan DTSC may impose
requirements on Priority Products, including: Product information
for consumers End-of-life product stewardship program Product sales
prohibition Engineered safety measures to control access or limit
exposure to the chemical of concern in the product Restrictions on
the use of the chemical Slide 36 Safer Consumer Product Regulation
Waiting for DTSC guidance on Alternative Assessments Slide 37 OTC
Delaware working on adopting Consumer Products Rule Proposed
Effective date 1/1/2017 Remember Utah and New Hampshire have
already adopted those regulations Slide 38 Summary Numerous Issues
Need to be Involved!!!! Slide 39 Thank You! Any questions?
