Regulatory Issues

Written on: November 1, 2017 by Doug Raymond


On Oct. 12, the California Air Resources Board (CARB) held a public workshop to discuss its proposal on Multi-purpose lubricants. Currently, Multi-purpose lubricants have a 25% volatile organic compound (VOC) limit and a future effective VOC limit of 10% as of 12/31/2018.

The CARB Staff is proposing to maintain the 10% VOC limit. However, it is also proposing to provide an alternative compliance option for products to meet a Maximum Incremental Reactivity (MRI) limit of 0.45 grams/ozone per gram product and not exceed the current 25% VOC limit. To be able to utilize this alternative compliance option, manufacturers need to pre-register the product formula with CARB before selling the product and provide annual reports to CARB on the products sold using this option. In addition, CARB is proposing to delay the effective date by six months. This is a great option. Using reactivity to regulate products for ozone is sound science and the most effective way to get emission reduction.

CARB Staff used the technical reports provided by industry on Multi-purpose lubricants to develop this proposal. The results did not appear to show that the majority of products reported could meet the 10% future effective VOC limit. Currently, with a little over a year to go before the new limit is effective, only 8% compliant products include oils that are typically at 0% VOC.

Comments on this proposal were due by the end of October 2017. However, the next workshop is not likely to be held until early 2018. Thus, review the proposal in detail and make your comments to CARB if you have products that are in the Multi-purpose lubricant category. This is your opportunity to affect the regulation of these products.

The next steps are for staff to evaluate industry’s comments; then early next year, staff will hold another workshop. By then, regulatory language should be completed. The Board hearing to adopt these changes is scheduled for May 2018.

Rule 1168

South Coast Air Quality Management District (SCAQMD) held its Board Meeting to adopt the amendments to Rule 1168 on Adhesives and Sealants on Oct. 6, 2017 in Los Angeles, CA.

The board adopted the amendments to the Rule, which are too numerous to list here. I suggest that, if you make adhesives and sealants, you review the amended regulation closely. Below are just some of the highlights:

  • Aerosol Adhesives maintain an exemption for use in the rule, but will be subject to reporting requirements.
  • Consumer Adhesives subject to the CARB regulation are prohibited from use in manufacturing unless the product is compliant with Rule 1168 VOC limits.
  • Reporting of sales is due every three years until 2015 and then every five years until 2040, when the reporting ends.
  • Labeling is required on all products. Consumer Products subject to CARB regulations can use weight percent as long as grams per liter calculations are provided elsewhere i.e.: a technical data sheet or website.
  • Spray foam sealant has a VOC limit of 250 g/l with a future effective limit on 1/1/2023 of 50 g/l. Foam seal will have a technical review before the effective date.
  • Clear, Paintable and Immediately Water Resistant Sealants have a VOC limit of 380 g/l and a future effective limit in 2023 of 250 g/l.

Again, these are just the highlights of the Rule. Please review in detail for your products at South Coast-Proposed Rules & Proposed Amended Rules


There are two updates from California on the legislative front: The Governor vetoed Bill AB1120 concerning Butane. He stated that the Dept. of Public Health would be working on regulations on this issue.

Secondly, Bill SB 258—an important bill concerning Ingredient Disclosure—was signed by the Governor and will become law. This is the first law to pass on Ingredient Disclosure for cleaning products; more to come on the specifics of this bill.


On Nov. 15, 2017, the Ozone Transport Commission (OTC) will hold its Fall meeting in Washington D.C. More to come as information becomes available.