Regulatory Issues

Written on: October 1, 2018 by Doug Raymond

CARB 101

In August, the aerosol industry led by National Aerosol Association (NAA) with the assistance of the Western Aerosol Information Bureau (WAIB) and the Household & Commercial Products Association (HCPA) held an Aerosol 101 for the California Air Resources Board (CARB) staff. Read more about this on p. 34 of the October SPRAY.

It is significant to realize that the aerosol industry needs to provide this type of education to the people that regulate our products. I believe that the CARB regulations have probably been the single largest influence on aerosol products over the last 30 years. This will likely continue to be the case. Therefore, industry, as the experts on these products, needs to provide knowledge on the product categories that CARB is interested in learning about.

At the Aerosol 101, we had more than 700 years of aerosol experience from industry alone. The meeting went extremely well. There was a full day of presentations with approximately 25 CARB staff and two members of the Dept. of Substance Control (DTSC) in attendance. There were many good questions asked and it was a conducive setting to have a meaningful discussion, especially concerning the categories CARB asked about: dry shampoo, body sprays, sunscreens, hair sprays, disinfectants and electrical and electronic cleaners.

It was a great meeting; now we need to start planning an Aerosol 201.

CARB Survey

CARB staff is working on completing the 2015 survey data. They have been contacting companies concerning the 2015 data in order to try to get this process finished. Therefore, you may be getting a call from CARB staff if your company’s information is not complete.

CARB is attempting to get the 2014 data finished by November 2018. This means we will likely start rule development some time in 2019. Make sure you review the survey data on your company’s product categories and start to get prepared for 2019.

Remember to consider Reactivity when looking at options for reformulations.

Ozone Transport Commission

The Ozone Transport Commission (OTC) held its most recent meeting on Sept. 21. It was held online, which was a new venture for OTC. More on this meeting in a future issue.


There are currently two issues with Canada.

Canada flag

VOC Regulation

I have been working with Environment & Climate Change Canada (ECCC) on developing a Consumer Product Volatile Organic Compound (VOC) Regulation. These regulations will likely mirror the current CARB regulation. The process is moving along, as I’m currently working on definitions with the agency. Updates to follow.


I have also been working with the ECCC to get some amendments to hydrofluorocarbon (HFC) regulation in Canada. This has been a very slow process. Updates will be forthcoming soon. SPRAY