Written on: August 1, 2013 by Doug Raymond

In early July, the California Air Resources Board (CARB) staff released, for preliminary review, the Aerosol Coatings amendments. Remember, in May, CARB delayed the Board Hearing until September 2013. The good news is not much has changed in the Aerosol Coating amendments. The amendments change definitions, as well as volatile organic compound (VOC) limits, and some new categories have been added. The biggest change to this regulation is that all products that meet the definition of Aerosol Coating need to fit into a category. This is slightly different than Consumer Products, where a product can be exempt from the regulation. Therefore, if you make Aerosol Coatings, make sure you categorize them and that the product meets the appropriate VOC limit for that category.
I encourage all marketers and manufacturers of Aerosol Coatings to review these amendments.

No word yet on the Consumer Products amendments. These amendments have to do with some definition changes, changes to Aerosol Adhesive VOC limits and, of course, the LVP-VOC definition.

CARB has gone ahead and approved the study of LVP-VOC compounds. Hopefully, there will not be much change in position since CARB’s workshop in April, when CARB dropped the changes to the LVP-VOC definition. The staff needed to post its final draft by the end of July; thus the document needs to be released soon.

The executive Board meeting to adopt these amendments will be held on Sept. 26–27. We won’t know for a while exactly which day it will be on. Amendments can be found at

The Ozone Transport Commission (OTC) held its annual meeting in New Haven, CT on June 13. The meeting was well attended and all states were present.

The OTC had a day-long meeting to discuss numerous issues with air quality. Consumer Products are only one issue that OTC deals with. The most important topic the OTC has is migration of air pollution into and between OTC states. A significant amount of time was spent on this issue. At this year’s meeting, Janet McCabe, Deputy Assistant Administrator of the U.S. Environmental Protection Agency (EPA), stated that the OTC’s work on developing model rules is greatly appreciated.

This seemed to be a lead in to a topic raised by the head of the Stationary Source Committee for the OTC, Ali Mirzakhalili from Delaware. Mirzakhalili stated that the OTC would be requesting the EPA to adopt the OTC Model rules for Consumer Products and Architectural Coatings. Deputy McCabe stated EPA would consider such a request, but its resources are tied up. Later, OTC made the formal votes to have OTC request EPA to adopt the current model rules for Consumer Products and Architectural Coatings.

These requests will be formally sent to EPA for consideration. This means if EPA decides to adopt the OTC model rules then the original CARB rules become National Rules. This is the reason why working with California is extremely important. If the original rule developments are successful, then the industry can live with these regulations. Now we need to wait to see what EPA’s actions will be.

The National Conference on Weights & Measures (NCWM) met in Louisville, KY on July 14–18. The issue of whether bag-on-valve products will need to declare net contents by weight or volume was once again discussed. More on this in the September issue. SPRAY