Written on: July 1, 2022 by Nicholas Georges
A little over five years ago, I stopped working in the aerosol industry and started working for the industry. I had big shoes to fill, replacing Doug Fratz at the Consumer Specialty Products Association (CSPA), now the Household & Commercial Products Association (HCPA). I was no longer helping put products in the hands of customers for one company. Instead, I became a representative for the entire supply chain, helping to communicate how aerosol products are safe and beneficial to consumers and workers. One way I do this is by sharing timely and relevant information with you, the readers of SPRAY Technology & Marketing.
When I joined the industry, I kept hearing that we were constantly reacting to legislative and regulatory issues. As I’m sure you’ll agree, there’s been plenty to react to in the last five years, such as the California Cleaning Product Right to Know Act of 2017, legislative limits on 1,4-dioxane in products, the American Innovation & Manufacturing (AIM) Act, the 2021 California Air Resources Board (CARB) amendments and Extended Producer Responsibility.
These changes seem to be coming at us faster than before, but change is something businesses need to accept—whether it’s due to new legislation, updated regulations or changes in consumer behavior. Failure to adapt and innovate could cause businesses to be left behind.
There’s even more on the horizon that we, as an industry, need to prepare for. In the next five years, there will be changes to the Occupational Safety & Health Administration’s (OSHA) Hazard Communication Standard, updates to the Federal Trade Commission’s (FTC) Green Guides, different labeling requirements for Proposition 65, additional activity by CARB on the next round of amendments to the volatile organic compound (VOC) regulation for consumer products, risk management actions under the Toxic Substances Control Act (TSCA) and a changing landscape on how we dispose of products and manage sustainability efforts. Since I started writing this column in August 2017, it’s been my goal to provide HCPA members and SPRAY readers with as much time as possible to prepare for and react to these changes.
Another goal of mine working for the industry is being proactive, which can take considerable time and resources to achieve. One activity HCPA has undertaken is a 20+ year effort to develop the data and information needed to convince the U.S. Environmental Protection Agency (EPA) to add aerosol containers to universal waste programs. So far, 32 States have modified their hazardous waste regulations to include aerosol containers, and HCPA will continue to advocate in the remaining 18 States and the District of Columbia.
More recently, HCPA and the Can Manufacturers Institute (CMI) launched the Aerosol Recycling Initiative, which aims to increase recycling and onpack recyclability messaging. The initiative’s goals are to achieve at least an 85% recycling access rate for all aerosol containers by 2030, which means that households have the ability to recycle their empty cans in their local recycling programs and label at least 90% of aerosol containers as recyclable with messaging about how to properly do so.
Working with a team of consultants (Gersham, Brickner & Bratton [GBB], Eunomia Research & Consulting and Jensen Hughes), the Initiative will:
• Develop data on the perceived risks of recycling aerosol products.
• Conduct an economic and environmental assessment to demonstrate the benefits of recycling aerosol products.
• Consult with material recovery facilities (MRFs) regarding their operations related to the handling of aerosol containers.
• Establish best practices to communicate with consumers how to recycle aerosol products when they are finished.
While it’s difficult to be proactive when there are so many issues that require our immediate attention, we must always be thinking about ways to grow and sustain the aerosol industry, such as streamlining shipping requirements, looking more closely at inhalation toxicity or continuing to showcase the sustainability of the aerosol delivery form.
One of the strongest predictive tools—and something I write about regularly for SPRAY—is the Aerosol Pressurized Products Survey. The Survey reports on the unit production of aerosol products, valves and containers in the U.S. to provide a comprehensive snapshot of the aerosol industry. This helps identify potential opportunities within product categories, reassess sales strategies and plan for future production and investments. It is also beneficial information to have when communicating with external stakeholders, such as legislators and regulators. That’s why I always make such a strong push for participation in the Survey. Without your input, we can’t generate accurate results, and that is detrimental to the aerosol industry.
I’d like to close by saying Thank You for letting me represent the aerosol industry. It’s been an amazing five years and I look forward to the next five, working on your behalf. For more information or to get involved, please contact me at firstname.lastname@example.org. SPRAY