CARB Survey and Consumer Products Amendments, SNAP and DTSC Priority Products

Written on: September 2, 2014 by Doug Raymond


Finally, the California Air Resources Board (CARB) staff has submitted the 2013 Board approved amendments to the Office of Administrative Law (OAL). On Aug. 5, 2014 the Final Rulemaking package for the September 2013 Amendments for Consumer Products was filed with OAL, which now has until September 17, 2014 to make a determination on the amendments. After all this time, there is no reason to believe that OAL will have any issues with the amendments. Remember, these amendments have all the new volatile organic compounds (VOC) limits for the Aerosol Coating, some of which are effective 1/1/2015. Therefore, Industry needs to be prepared to meet these limits. Other important amendments dealt with definition changes, such as single purpose degreaser and cleaner, as well as the addition of the HFO-1234ze to the VOC exemption list and the delay in the 10% VOC limit for Multi-purpose Lubricant from 12/31/2015 to 12/31/2018. Hopefully, the rest of the process will move along quickly.


CARB has been working on refining its next survey. As previously stated, this will be the most comprehensive survey ever for Consumer Products. The number of products surveyed, and the range of information requested, will be more than was ever required in previous surveys. Be prepared to begin working on the survey soon. Sept. 1 is the proposed date for the release of the new survey and a webinar is scheduled for Oct. 15 to answer survey questions and to provide clarification on the survey. Therefore, be sure to review the survey by October 15, 2014. More information will follow.


Rule 1168, which deals with Adhesives and Sealants in the South Coast Air Quality Management District (SCAQMD), has been put on hold indefinitely. Remember, this is the proposed regulation that was targeting Consumer Products for regulation by the district. Even though this rule is on hold, Industry needs to work with the district and CARB to maintain Consumer Product regulations. SCAQMD will focus on this regulation at a future time.

Currently, staff is preparing for a symposium on assessing and managing toxic risk from alternative VOC compounds, tentatively scheduled for Oct. 29 at SCAQMD.


The changes to the Significant New Alternative Policy (SNAP) Program at the U.S. Environmental Protection Agency (EPA) appeared in the Federal Register on Aug 6. You can download the rule here.

These changes affect the use of HFC-134a in most products. Currently, EPA is proposing to prohibit HFC-134a from all Consumer use and a majority of technical uses such as tire inflator, air horns, some duster applications, fire detector testers and more.

Currently, the following products are being allowed to maintain theuse of HFC-134a:

cleaning products for removal of grease, flux and other soils from electrical equipment or electronica; lubricants for electrical equipment or electronics; sprays for aircraft maintenance; pesticides for use near electrical wires, in aircraft, in total release insecticide foggers or in certified organic use pesticides for which EPA has specifically disallowed all other lower-GWP propellants; mold release agents; lubricants and cleaners for spinnerettes for synthetic fabrics; duster sprays specifically for removal of dust from photographic negatives, semiconductor chips and specimens under electron microscopes; document preservation sprays; metered dose inhalers for the treatment of asthma, chronic obstructive pulmonary disease, allergic rhinitis and other diseases where aerosols can be used for systemic delivery through lung, nose or other organs; wound care sprays; topical coolant sprays for pain alleviation; and products for removing bandage adhesives from skin.

On Aug. 1, Industry convened with EPA at a meeting with The U.S. Small Business Administration (SBA) to discuss these proposed changes. We are going to have a difficult time changing this proposal. There was a public hearing on these changes on Aug. 27 in Washington D.C. and the close of comments is on Oct. 6. If you need changes to be made, then your company needs to become involved—now!

Green Chemistry

The Dept. of Toxic Substance Control (DTSC) is still working on the Priority Products for their Safer Consumer Products Regulation. The two products which affect our Industry are Spray Foam and Paint Strippers. This process will likely be ongoing for a year or longer. DTSC will be hosting two workshops for its three-year work plan, the first of which was held Aug. 19 in DTSC’s Cypress office, and the second in the Byron Sher auditorium on Aug. 25.

It will be interesting to see which products are targeted next.