Written on: April 1, 2025 by Doug Raymond
There are several different rules to discuss this month—Colorado, Oregon, SCAQMD and, of course, CARB.
CARB
As discussed in detail last month, the California Air Resources Board (CARB) is seeking information from Industry on numerous product categories. CARB has released a Consumer Product Survey that has a deadline of April 8, 2025. Therefore, by the time this column appears in the April issue of SPRAY, you should have already completed it. It is imperative that Industry submit as much accurate data as possible, which will then be used in CARB’s next rulemaking. Remember, just because your product category is being surveyed does not mean that the product category will be regulated.
The better the information submitted, the easier it will be for CARB to determine if the product should be regulated or not. This next rulemaking will more than likely use the concept of “Reactivity.” We are hoping that, by using Reactivity, limits will be more reasonable. In addition, the use of Reactivity should provide more flexibility for Industry. Lastly, if your company did not meet the deadline of April 8, make sure to inform CARB staff immediately with a date that you can supply the information. Good luck!
Colorado
Currently, Industry is working with the Regional Air Quality Council (RAQC) in the State of Colorado on Consumer Products. The RAQC is considering moving the contingency provision—which uses Ozone Transport Commission (OTC) Model Rule V—in Colorado Regulation 21 to a current regulation. Currently, no other U.S. State uses OTC Model V. This has been a complicated and frustrating issue to deal with. The problem stems from the RAQC not having accurate volatile organic compound (VOC) emission numbers. Their presentations are full of errors and misconceptions about VOC emissions. Nicholas Georges from the Household & Commercial Products Association and I have been on several calls with the State of Colorado to deal with this issue. We are hopeful that we will have this sorted out by this Summer. There will be more to come.
Oregon
Work continues with the State of Oregon on a Consumer Products VOC rule. Remember, the biggest issue with Oregon is that it is currently not out of attainment for ozone. This is my first time in 35 years that a State has proposed to develop an Air Quality regulation when a problem does not exist. These are crazy times; more to come.
SCAQMD
The California South Coast Air Quality Management District (SCAQMD) is working on amendments to SCAQMD Rule 1171 on degreasing products. Staff is proposing to change a long-established provision that allows for 160 fluid ounces of aerosol cleaner product not compliant with Rule 1171 a strict VOC limit of 25 g/l to be used by a facility. The proposed changes are to list what aerosol cleaning products are acceptable and how many. In addition, for general aerosol cleaning use, the provision is being changed from 160 fluid ounces a day to 160 fluid ounces per year. This is not feasible.
Also, SCAQMD is proposing banning para-chlorobenzotrifluoride (PCBTF) and tertiary-butyl acetate (T-BAC) in all degreasing products used in the district.
We have much work to do here. SPRAY
