SOUTHERN AEROSOL TECHNICAL ASSOCIATION CONSUMER PRODUCT REGULATORY UPDATE. Doug Raymond Raymond Regulatory Resources (3R) March 25, 2010
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1 SOUTHERN AEROSOL TECHNICAL ASSOCIATION CONSUMER PRODUCT REGULATORY UPDATE Doug Raymond Raymond Regulatory Resources (3R) March 25, 2010
2 OVERVIEW CARB VOC Toxics Green house gas emissions Enforcement OTC Canada Consumer Products Aerosols Coatings Reactivity Legislation
3 CARB VOC January Tons per day of VOC reductions needed by January 2014 Consumer Product VOC Reductions Accredited Toward SIP Commitment Consumer Products Rulemaking VOC Reductions (tons per day) June 2008 Amendments 4.5 September 2009 Amendments (this proposal) 2010 Cleaning Products Amendments (under development) Additional Reductions from 2006 Survey Product Categories Totals Reductions by January 1,
4 CARB VOC April 13 First Workshop November 18, 2010 Cleaning products proposed Categories from 2006 survey
5 CARB VOC Category Proposed Limit Proposed Effective date Current Limit General Purpose Cleaner Non-Aerosol General Purpose Degreaser Non-Aerosol /31/ /31/ Glass Cleaner Non-Aerosol 1 12/31/ Furniture Maintenance Product Aerosol 10 12/31/
6 CARB VOC Tons/Day Deodorant Body Sprays 5.9 Crawling Bug (Aerosol) 2.9 Paint Remover & Stripper 1.3 Heavy-duty hand cleaner 0.8 Metal Polish/Cleaner 0.5 Automotive wax 0.5
7 CARB VOC Sunscreens (Aerosol) Silicone Lubricants Special Purpose Lubricants Gun Oil
8 CARB VOC Evaluation of Methylene Chloride use More than 50% products use MC Alternatives being considered Benzyl alcohol Dibasic esters others
9 CARB VOC Tire Sealants and Inflators HFC 134a alternatives evaluated Aerosol Dessert Toppings Nitrous oxide alternatives evaluated
10 CARB VOC Zero Sum Game CARB needs emission reductions Industry needs to maintain viable products Need to work together
11 CARB ENFORCEMENT cases involving consumer products Total fines $1.7 million cases Fine $2.5 million
12 CARB ENFORCEMENT Becoming Stricter Fines increasing Looking for Specialty products Date codes
13
14 OTC Planning to update Consumer Product Regulation OTC asked EPA to adopt Maintain consistency w/carb Add CARB Amendments through 2006 Restrictions on chlorinateds
15 OTC PROPOSED OTC VOC LIMITS Product Category Current OTC Limit Proposed OTC Model Rule Jan. 1, 2013 Adhesive Construction, Panel & Floor Covering 15 7 Anti-Static Aerosol - 80 Bathroom & Tile Cleaner Non-Aerosol 5 1 Brake Cleaner Carburetor or Fuel-injection Air Intake Cleaner Disinfectant Aerosol Non-aerosol 70 1
16 OTC PROPOSED OTC VOC LIMITS Product Category Current OTC Limit Proposed OTC Model Rule Jan. 1, 2013 Engine Degreaser Aerosol Floor Polish or Wax Resilient (Flexible) Flooring Material Non-resilient Flooring Material Furniture Maintenance Products Non-aerosol (except solid/paste forms) - 3 General Purpose Cleaner All Forms Aerosol 10 8 General Purpose Degreaser Aerosol
17 OTC PROPOSED OTC VOC LIMITS Product Category Current OTC Limit Proposed OTC Model Rule Jan. 1, 2013 Laundry Starch/Sizing/Fabric Finish Product Oven Cleaner Non-aerosol (including pump spray & liquid) 5 TBD Furniture Maintenance Products Non-aerosol (except solid/paste forms) - 3 Sanitizer Aerosol Non-Aerosol Shaving Gel 7 4 Temporary Hair Color (Aerosol)
18 CANADA Consumer Product Regulation due out this Spring Consistent with CARB through 2006 (excludes pesticides) Meeting on March 22 & 23
19 CANADA Consultation Meeting on March 22 & 23 Review of Discussion Paper New Categories Considered
20 CANADA Asphalt Cutbacks Portable Fuel Containers Cars, Vans, Light Trucks assembly coating Industrial & Commercial Adhesives & Sealants Aerosol Coatings Rubber Products Manufacturing & Plastic Parts Coating Printing
21 EPA Consumer Product Regulation in limbo Bruce Moore moved to a new position, outside of Consumer Products Bruce will be missed!!
22 REACTIVITY Reactivity Implementation Working Group Group formed to assist states in utilizing Reactivity CARB, SCAQMD, BAAQMD & OTC all active in group Bruce Moore was instrumental in starting this group Again Bruce will be missed
23 LEGISLATION 2010
24
25 SENATE BILL 98 Introduced by Senator Simitian Effects All Consumer Products Disclosure of All ingredients above 1/10 of 1% By March 30, 2011 on a website Currently no confidential business information protection
26 EXTENDED PRODUCER RESPONSIBILITY Will set a precedent Will initially contain residential pesticide For recycling Goal is set then a 5% increase until 95% goal is met! Will be easy to add other products
27
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