Regulatory Issues

Written on: February 1, 2019 by Doug Raymond


On Jan. 15, 2019 the California Air Resources Board (CARB) held a public webinar concerning the results of Drafts 2013, 2014 and 2015 of the Consumer Product Survey Data. The results were released on Dec. 6, 2018 and are on the CARB website.

It is important to review this information. The data from this survey will be used in the next round of rulemaking, which will likely start the last week of March or the first week of April. Tentatively, this is the time that CARB staff will have its first Survey Data workshop and will likely announce the list of categories that will be considered for rulemaking.

Lastly, the Multi-purpose lubricant rulemaking process is still moving along. The Office of Administrative Law (OAL) has sent the final packet to the Secretary of State. This should be finalized any day. Remember, the new effective date is July 1, 2019.

For those manufacturers of Architectural Coatings, there is a CARB public workshop on Architectural & Industrial Maintenance (AIM) Coatings Suggested Control Measure (SCM) on Feb. 19 from 9:00am–12 noon Pacific time.


The Dept. of Toxic Substance Control (DTSC) has adopted a regulation listing paint or varnish strippers containing methylene chloride as a Priority Product. Effective Jan. 1, 2019, the Priority Product listing triggers the next steps in the Safer Consumer Products program in which responsible entities determine if they will conduct an Alternatives Analysis (AA). Through the AA process, manufacturers can undertake the search for safer alternatives to paint or varnish strippers containing methylene chloride to help achieve the goal of protecting workers and consumers from exposure to methylene chloride. Manufacturers must complete the first step in the process, Priority Product Notification, by March 4, 2019.


The Colorado Dept. of Public Health & Environment scheduled a conference call on Jan. 10 with Consumer Products and AIM Coatings industry stakeholders to provide an update on potential rulemaking. More to come on this issue.

Rhode Island


The Rhode Island Dept. of Environmental Management (RI DEM) issued its Final Consumer Products Rule Amendments. RI DEM only made minor changes to the volatile organic compounds (VOC) limits in a limited number of categories to ensure consistency with neighboring states’ rules and the 2013/2014 Ozone Transport Commission (OTC) model Rule for Consumer Products. SPRAY