CONSUMER PRODUCT REGULATORY UPDATE
This update covers the latest developments in consumer product regulations discussed at the SPRING MEETING on March 22, 2012. Topics include CARB rule development, VOC fees, aerosol coatings, adhesives, and the California Air Resources Board's rulemaking status. Details on emissions data, upcoming workshops, and the ARB's goals in rulemaking are also provided.
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Presentation Transcript
SATA SPRING MEETING MARCH 22, 2012 CONSUMER PRODUCT REGULATORY UPDATE DOUG RAYMOND RAYMOND REGULATORY RESOURCES (3R), LLC
TOPICS 2
CARB Rule Development VOC Fee Multi-purpose Lubricant & Penetrant Enforcement Update Upcoming Effective Dates
CARB Aerosol Coating & Aerosol Adhesives Rule Development
CALIFORNIA AIR RESOURCES BOARD Status of Rulemaking Includes both aerosol coatings and aerosol adhesives Survey included additional product categories not currently regulated by reactivity (mold releases, silly string, etc.) Data has been released ARB still in analysis phase
CALIFORNIA AIR RESOURCES BOARD Schedule Sales and Emissions data released Feb. 2, 2012 Aerosol Technology Seminar for ARB staff on February 16 Industry comments ARB Workshop(s) anticipated in April Still scheduled for November 2012 Board Hearing for Adoption of Final Rule
CALIFORNIA AIR RESOURCES BOARD ARB Goal in rulemaking The Data 29.40 tpd emissions from coatings 4 tpd emissions ++ 1.29 emissions from adhesives
CALIFORNIA AIR RESOURCES BOARD Note: ARB Coatings Regulation has 36 regulated categories ARB requested data on an additional 33 categories Most undefined in the rule
CALIFORNIA AIR RESOURCES BOARD More data (coatings) 0 products reported in 13 undefined categories 1 product reported in 9 categories 2 products reported in 6 categories 3 to 9 products reported in 11 categories 10 to 19 products reported in 5 categories
CALIFORNIA AIR RESOURCES BOARD 30 to 100 products reported in art fixatives/sealants; EMF engine enamel; rubberized; HMC clear metallic; hi temp; auto body primers; auto bumper and trim; and HMC lacquer 20 to 29 products reported in Electrical; mold release; anti-rust; and wood stain categories
CALIFORNIA AIR RESOURCES BOARD Categories with 100 or more V/F/L/P; HMC enamel; EMF auto; EMF industrial Categories with 200 or more Ground traffic/marking Wood touch-up, repair, restoration
CALIFORNIA AIR RESOURCES BOARD General Categories Clear: 269 reported products Flat: 217 reported products Fluorescent: 37 reported products Metallic: 229 reported products NonFlat: 940 reported products Primers: 217 reported products
CALIFORNIA AIR RESOURCES BOARD 6 categories: 23.18 tpd emissions Non Flat (940/11.72) Flat (217/2.61) Ground traffic/marking coatings (229/2.54) Primers (226/2.46) Clear (269/2.11) Metallic (229/1.74)
CHANGES WE ANTICIPATE New Table of MIR Values New PWMIR standards New categories (Electrical coatings) Some categories eliminated Consistency with USA EPA National Rule eliminated
AEROSOL ADHESIVES Very low volume Very low in reactivity
CARB VOC FEE AB 10X VOC Fee (TAX) Imposed if sales over 250 tons of VOC/year First Year Fee 2003-2004 CARB runs 3 years behind Example Invoiced in 2012 for 2009 sales
CARB VOC FEE 2003-2004 Fee/$86.55/ton Top 3 Fee Payers: Sherwin Williams, WM Barr, SC Johnson First Year Fee 2003-2004 52 Companies paying Fee
CARB VOC FEE 2004-2005 2005-2006 2006-2007 2007-2008 2008-2009 2009-2010 2010-2011 2011-2012 $94.03/ton $106.59/ton $106.90/ton $120.11/ton $117.41/ton $131.11/ton $137.38/ton $173.00/ton
CARB VOC FEE Increased by $86.45 per ton in 9 years Almost a 100% increase Ironically more companies paying, not less Check your emissions!!
CARB VOC FEE Between 4 Million and 4.5 Million collected every year! CARB Increase tonnage every year whether your sales do or not!
CARB VOC FEE Review your emissions Because CARB is 3 years behind start reviewing emission from your 2010 sales now! Be prepared to supply update sales & emissions Final Point: May be financially beneficial
CARB MULTI-PURPOSE LUBRICANT & PENETRANT REPORT Responsible parties need to report by March 31, 2012 Report Delayed! Sales and formulas for 2011 Section 94513 (f) requires reporting Include evaluation of Raw Materials Hardware Test Results COSTS!! R & D efforts toward 25% limit
CARB MULTI-PURPOSE LUBRICANT & PENETRANT REPORT This is an OPPORTUNITY! Get on the record: Time & Resources, Degreased effectiveness, COSTS!! COSTS!! COSTS!!! We always complain about this let s supply information!!
CARB ENFORCEMENT UPDATE
CARB ENFORCEMENT UPDATE Prevention Make Specialty Product Labels SPECIAL No Generic Claims Like AND MORE ALL SURFACES OTHER PARTS Get the Idea!! Date codes report or use CARB standard Careful w/chlorinateds
CARB FUTURE EFFECTIVE LIMITS Product Category Adopted VOC Limit (wt%) Effective Date Current Limit Air Freshener Double Phase Aerosol 20 12/31/12 25 General Purpose Cleaner: Non-aerosol 0.5 12/31/12 4 General Purpose Degreaser Non-aerosol Glass Cleaner Non-aerosol 0.5 12/31/12 4 3 12/31/12 4
CARB FUTURE EFFECTIVE LIMITS Product Category Adopted VOC Limit (wt%) Effective Date Current Limit Metal Polish or Cleanser Aerosol Non-aerosol Spot Remover Aerosol Non-aerosol 15 3 12/31/12 12/31/12 30 30 15 3 12/31/12 12/31/12 25 8
CARB FUTURE EFFECTIVE LIMITS Product Category Adopted VOC Limit (wt%) Effective Date Current Limit Furniture Maintenance Product Aerosol Heavy-duty Hand Cleaner or Soap Non-aerosol Flying Bug Insecticide Aerosol 12 12/31/13 17 13 12/31/13 8 20 12/31/13 25 Wasp or Hornet Insecticide 10 12/31/13 40
CARB FUTURE EFFECTIVE LIMITS Product Category Adopted VOC Limit (wt%) Anti-Seize Lubricant Aerosol Non-aerosol 3 Cutting or Tapping Oil Aerosol Non-aerosol 3 Gear, Chain, or Wire Lubricant Aerosol Non-aerosol 3 Multi-purpose Lubricant (excluding solid or semisolid products) 10 Effective Date Current Limit 40 12/31/13 12/31/13 - - 25 12/31/13 12/31/13 - - 25 12/31/13 12/31/13 - - 25 12/31/13 12/31/15 50 25
CARB FUTURE EFFECTIVE LIMITS Product Category Adopted VOC Limit (wt%) 25 Effective Date Current Limit Penetrant Rust Preventative or Rust Control Lubricant Aerosol Non-aerosol Multi-purpose Solvent Paint Thinner 12/31/13 50 25 3 12/31/13 12/31/13 - - 3 12/31/13 30 3 12/31/13 30
ENVIRONMENT CANADA March 7 Stakeholder Meeting on Federal VOC Agenda (Aerosol Coatings) Survey Completed by Contractor Majority of products in compliance Need to wait for CARB Rule
GREEN CHEMISTRY Safer Consumer Products Regulation Draft Released Comments Received Expecting formal draft soon Need to Closely Monitor
PROP 65 OEHHA Listed Methanol Listed March 16, 2012 Proposed Maximum Allowable Dose Level (MADL) Comments on MADL due April 30 12 months to warn as a reproductive toxin
WEIGHTS & MEASURES Proposal before National Conference of Weights & Measures (NCWM) January 22-25,2012 Proposal: Bag on valve (BOV)products to be sold using volume not weight
WEIGHTS & MEASURES Proposal by Locke, Lord, Bissel & Lindell On behalf of Blue Magic Product of concern Air Freshener 100% Terpenes
WEIGHTS & MEASURES Calls for BOV products to be labeled NON- AEROSOL PRODUCT Effects all Barrier Packs that does not dispel the propellant At odds with numerous regulations Proposal Problematic
WEIGHTS & MEASURES Actions Several People opposed proposal Current Chairman NAA P & G Laws & Regulation Committee did not vote on issue Proposal sent to new Packaging & Labeling Committee
WEIGHTS & MEASURES What type of Declaration is appropriate to compare value & quantity? Information on BOV Products that are also filled in traditional aerosol (side by side comparison) Action Items Next Meeting July 15-19, 2012
FINAL WORDS! BE INVOLVED!! Thank you! Questions
