Regulatory Issues

Written on: July 1, 2023 by Doug Raymond

In May, the aerosol industry presented an educational program to the California Air Resources Board (CARB). The event was held jointly by the National Aerosol Association (NAA), the Household Commercial Products Association (HCPA), the Western Aerosol Information Bureau (WAIB) and the Personal Care Products Council (PCPC) at CARB Enforcement offices in Sacramento.

Day One
On May 16, the NAA and WAIB took the lead on a full day of presentations on the aerosol package. The 25 CARB staff members in attendance were from the Consumer Products & Air Quality Assessment Branch, the Consumer Products Enforcement Branch and the Northern Laboratory Branch (Special Analysis section). This is the staff that writes amendments to, as well as enforces, the Consumer Product rules. The Northern Laboratory Branch staff is responsible for testing Consumer Products for compliance with Consumer Products Regulations. It works closely with the Enforcement Branch. The turnout and interest from the CARB staff was amazing.
Industry had 14 presenters on the following topics:

• Aerosol industry overview
• Aerosol valves
• Packaging containers
• Propellants
• Solvents/low vapor pressure (LVP) solvents
• Aerosol caps
• Aerosol R&D
• Manufacturing overview
• Aerosol coatings
• Innovative product exemption

In attendance were 25 Industry members representing a combined 450 years (at least) of experience in the aerosol industry.

The meeting kicked off at 9:00am and lasted until 4:30pm. CARB staff asked great questions and significant dialogue continued throughout the day. This was an excellent opportunity for Industry to educate CARB staff on the aerosol product form. Likewise, it was also an excellent opportunity for CARB staff to ask questions and discuss areas of concern in a laid-back atmosphere without the pending pressure of rule amendments hanging in the air. It truly was a win-win event for both CARB and the Aerosol Industry. Ravi Ramalingam, Chief of Consumer Products & Air Quality Assessment Branch, stated:

The Aerosol Summit provided a truly excellent forum for CARB staff to glean invaluable insights from, and share perspectives with, participating industry experts on a wide variety of topics. Hearty thanks to all who organized the events and traveled to meet with us! —Ravi Ramalingam

In my 35 years in the industry, I cannot think of another single agency that has had such a significant and long-lasting effect on the aerosol industry as CARB. This event was a strategic opportunity for us to work with CARB and we should initiate similar events on a more routine basis.

Day Two
On May 17, HCPA and PCPC held an educational program on Consumer Products, specifically non-aerosol issues. Similar to the first day, the same staff attended the following presentations:

• R&D on new consumer products and reformulations
• Considerations for cosmetics and over-the-counter products
• Considerations for Federal Insecticide, Fungicide & Rodenticide Act (FIFRA)-regulated products
• Fragrances
• Ethanol vs. isopropyl alcohol (IPA)
• Multi-purpose lubricants alternative compliance options

Again, 25 CARB staff members were present. Fourteen industry members were in attendance, with eight presenting. As with the day before, CARB and Industry had very healthy dialogues; CARB asked numerous questions and was engaged throughout the day.

The entire educational program, held over two days, was truly beneficial for all involved. SPRAY