About the Author

Doug Raymond
Doug Raymond
Doug Raymond is owner of Raymond Regulatory Resources (3R), consulting in the regulatory and governmental arena concerning consumer products. He has worked in the aerosol industry for the past twenty-two years. Doug has extensive experience interfacing with regulatory agencies, legislative bodies, corporations and trade associations. He has been a critical leader for the aerosol industry in dealing with regulations that affect the industry. Doug has been successful in building coalitions and effective compliance strategies for the consumer products industry. Currently Doug is Consultant for the National Aerosol Association (NAA) and a regular monthly contributor of “Regulatory Issues” for Spray Technology.
Articles by Doug Raymond
CARB On April 12, 2019, the California Air Resources Board (CARB) staff held its first Public Workshop on its new round of rule development for Consumer Products. CARB staff is proposing to evaluate consumer product…
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CARB Are you ready for the next round of California Air Resources Board (CARB) Consumer Product Regulations? On April 12, CARB held its first workshop for this next rule development. It is looking to reduce…
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CARB The California Air Resources Board (CARB) staff has announced that it will be starting its next Consumer Product rulemaking on April 12, 2019. Over the past 30 year, CARB has regulated over 120 categories…
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CARB On Jan. 15, 2019, the California Air Resources Board (CARB) held a public webinar to discuss the results of the Draft 2013, 2014 and 2015 Consumer Products data. The results of the survey were…
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CARB 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…
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Happy New Year! Expect a very busy year in the regulatory world. The California Air Resources Board (CARB) and Canada will be developing volatile organic compounds (VOC) regulations. The U.S. Environmental Protection Agency (EPA) will…
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SNAP On Oct. 9, 2018, the Supreme Court refused to hear the appeal of the petitions from the Natural Resources Defense Council (NRDC), Honeywell International and Chemours to review the U.S. Court of Appeals, District…
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California Legislation In September, California Governor Jerry Brown signed in to law Senate Bill (SB) 1013. Senator Ricardo Lara authored SB1013 to put in place the original U.S. Environmental Protection Agency (EPA) Significant New Alternatives…
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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…
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Canada On July 10, 2018, the Canadian Consumer Specialty Products Association (CCSPA) held a meeting with Environment Canada & Climate Change Canada (ECCC) concerning volatile organic compounds (VOCs). Representing ECCC was Tracey Spacek, Mary Ellen…
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  CARB California Air Resources Board (CARB) staff conducted a webinar on June 19 concerning the Consumer Products Survey Data from 2013 and 2014. The scope of the surveys is very impressive. An overview included:…
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CARB amendments adopted On May 25, the California Air Resources Board (CARB) adopted new amendments to the Consumer Products Regulation. The new amendments affect the Multi-Purpose Lubricant (MPL) category. CARB staff has been working on…
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Proposition 65 As a reminder, as of Aug. 30, 2018 the new wording for the Proposition 65 warning becomes effective. If you have products that require a Proposition 65 warning, then everything produced after Aug.…
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  MPL On April 3, 2018, The California Air Resources Board (CARB) released a 45-day notice for amendments to its Consumer Products Regulation. These amendments mainly have to do with the multi-purpose lubricant (MPL) future…
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Article in Science On Feb. 15, 2018, the journal Science published research titled “Volatile Chemical Products Emerging as Largest Petrochemical Source of Urban Organic Emissions.” This researched study is very significant to the consumer products…
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SNAP Rule On Jan. 26, the U.S. Court of Appeals for the District of Columbia rejected an appeal by The Natural Resources Defense Council, Honeywell and Chemours on the Court’s original decision to overturn the…
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  The year is starting out busy. We started out the year with a couple of meetings.  Department of Toxic Substance Control On Jan. 8, the Dept. of Toxic Substance Control (DTSC) held a public…
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Happy New Year! CARB The California Air Resources Board (CARB) has announced the next public workshop for the amendments to the Multi-purpose lubricants (MPL) effective date and the volatile organic compound (VOC) limit. CARB is…
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California On Oct. 15, 2017, California Governor Jerry Brown signed Legislative Senate Bill (SB) 258, authored by State Senator Ricardo Lara, Democrat for Bell Gardens. SB258 is the Cleaning Product Right to Know Act and…
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CARB On Oct. 12, the California Air Resources Board (CARB) held a public workshop to discuss its proposal on Multi-purpose lubricants. Currently, Multi-purpose lubricants have a 25% volatile organic compound (VOC) limit and a future…
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CARB The California Air Resources Board (CARB) has finished its review of the Multi-purpose Lubricant reports. On Oct. 12, 2017 CARB Staff held a public workshop to discuss the upcoming future effective limit of 10%…
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CARB Update Multi-purpose Lubricant Report This will be your last notice to report on Multi-purpose Lubricant products. On Dec. 20, 2016, the California Air Resources Board (CARB) released the documents that need to be filled…
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Canada Canada takes the front spot this month. On Nov. 26, 2016, the Dept. of the Environment and the Dept. of Health in Canada released a proposed regulation on the use of hydrofluorocarbons (HFCs). This…
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Happy New Year!  CARB Date Code Let’s start with my friendly reminder about Product Dating/Date Coding. Remember, date code information needs to be reported to the California Air Resources Board (CARB) every year by your…
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Upcoming effective dates As of Jan. 1, 2017, the California Air Resources Board (CARB) has future effective volatile organic compounds (VOC) limits that come into effect. Future VOC limits for Aerosol Adhesives and Aerosol Coatings…
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CARB Industry members presented the California Air Resources Board (CARB) with an Aerosol 101 on Oct. 5 in Sacramento, CA. In attendance were approximately 20 industry members and 25 CARB personnel, including those from the…
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California The Legislative session is over for 2016. Several bills could have had an effect on our industry. Assembly Bill 708 on Ingredient Disclosure failed early in the year; it would have required full ingredient…
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CARB As of Jan.1, 2017, the California Air Resources Board (CARB) will have volatile organic compound (VOC) limits that become effective for the following Consumer Product categories. Aerosol Adhesive categories with future effective limits are…
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Happy New Year! This year we will have many “opportunities” to work with regulators to maintain our product sales. A short summary of what to expect from each agency is provided. California Air Resources Board…
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EPA The U.S. Environmental Protection Agency (EPA) finalized the new Ozone Standard limit at 70ppb. The Ozone Standard limit is the level at which all states are regulated. This means if a state or area…
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CARB/SCAQMD Meetings with South Coast Air Quality Management District (SCAQMD) and California Air Resources Board (CARB) management continued on July 8 in Sacramento, CA. Industry representatives met to discuss future regulation of Consumer Products targeted…
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Federal EPA The Significant New Alternatives Policy (SNAP) rule amendments from the U.S. Environmental Protection Agency (EPA) were finalized on July 20, 2015. The effective date is one year after the rule was published. This…
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  SNAP Rule Finally, The U.S. Environmental Protection Agency (EPA) has released its final version of the Significant New Alternatives Policy (SNAP) rule dealing with Global Warming Potential (GWP) Compounds. The compound of note for…
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California Legislation Just last month, we reported that there was a legislative bill called Assembly Bill 708 (AB708) moving through the California Legislature. The bill deals with ingredient disclosure and affects cleaning, automotive, air care…
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CARB The California Air Resources Board (CARB) released a concept paper on May 7 concerning a way to reduce greenhouse gases in a shorter time frame than by working on carbon dioxide reductions. CARB’s concept…
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The aerosol industry has been working on numerous issues this year. The following will be a short summary of each issue. Industry has been busy! CARB Survey work Even though the deadline for the California…
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CARB Most responsible parties should be done with their California Air Resources Board (CARB) Consumer & Commercial Products Survey by now. For small businesses and formulators, the work may possibly continue. This survey has been…
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EPA The U.S. Environmental Protection Agency (EPA) held three hearings to discuss the changing of the new Ozone Standard. Currently the Ozone Standard is 75 parts per billion (ppb). This means that if the Ozone…
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CARB Survey By now you should be working on your California Air Resources Board (CARB) Consumer Product Survey. This very comprehensive survey needs to be completed by March 1, 2015. Some of the items that…
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Happy New Year! CARB The Consumer Product Survey is ongoing. CARB held a webinar on December 15 to assist consumer product companies in filling out their surveys. This is a time consuming activity. Remember, the…
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CARB The California Air Resources Board (CARB) continues with its 2013 Consumer Product Survey. If you sold a Consumer Product into the state of California in 2013 and your product is on the CARB survey…
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CARB Finally, the Office of Administrative Law (OAL) approved the California Air Resources Board (CARB) Consumer Product regulation on Sept. 17, 2014. This action finalizes the amendments and the U.S. Secretary of State has endorsed…
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CARB As of 1/1/2015, the new limits for the California Air Resources Board (CARB) Specialty Coating Categories (B) become effective. There are two points to consider. The first is that the Specialty Coating Categories (B)…
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CARB Finally, the California Air Resources Board (CARB) staff has submitted the 2013 Board approved amendments to the Office of Administrative Law (OAL). On Aug. 5, 2014 the Final Rulemaking package for the September 2013…
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CARB The California Air Resources Board (CARB) September 2013 Amendments are still not finalized by CARB staff. The 15-day comment period has come and gone. CARB staff has indicated that the amendments will be finalized…
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CARB Finally, the California Air Resources Board (CARB) has released its 15-day changes to the amendments from the September 2013 board hearing. The changes can be found at http://www.arb.ca.gov/regact/2013/cp2013/cp2013.htm and include modifications made to some…
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CARB News from the California Air Resources Board (CARB) is that its 15-day comment notice will have expired by the end of March. By the time you’re reading this, you will have hopefully seen the…
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Weights & Measures Update On Jan. 20-21, the National Conference of Weights & Measures (NCWM) held a meeting in Albuquerque, NM. During this meeting, the Laws & Regulations (L&R) committee held its Open Hearings, when…
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  CARB The California Air Resources Board (CARB) continues to work on finalizing the amendments to the Consumer Products and Aerosol Coating regulation. The fifteen-day notice should be released around the first of the year.…
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    CARB The California Air Resources Board (CARB) continues their work on Consumer Products. On Oct. 23, the CARB research division held its first meeting on the  Low Vapor Pressure (LVP) Research Study Contracts…
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    CARB On Sept 26, 2013 The California Air Resources Board (CARB) held an Executive Board hearing to adopt amendments to the Consumer Products regulation and to the Aerosol Coating Products regulation. The formation…
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  CARB The California Air Resources Board (CARB) amendments to the Consumer Products Regulation and the Aerosol Coatings Regulation are still the top priority for Industry. The board hearing was held Sept. 26, 2013. There…
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  CARB On August 7, the California Air Resources Board (CARB) released their proposed amendments for the Consumer Products rule and the Aerosol Coating rule. There are now 45 days to review and comment on…
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CARB In early July, the California Air Resources Board (CARB) staff released, for preliminary review, the Aerosol Coatings amendments. Remember, in May, CARB delayed the Board Hearing until September 2013. The good news is not…
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  CARB In April, the California Air Resources Board (CARB) made some significant modifications to their proposed amendments to their Consumer Products volatile organic compound (VOC) regulations. CARB modified the proposed limits for the Aerosol…
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  California Air Resources Board (CARB) issues remain the topic of the industry. On April 24, CARB staff held a workshop to discuss amendments to the Consumer Products VOC regulation. CARB amendments to volatile organic…
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  CARB There are changes at the California Air Resources Board (CARB). James Goldstene had been the Executive Officer at CARB since 2007 and has now moved to a new position. Richard Corey is now…
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CARB On Feb. 24, 2013 the California Air Resources Board (CARB) staff held their second public workshop on their current rule development. This rule development is mainly focused on modifications to Aerosol Coatings and Aerosol…
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  This year is starting off very busily. We have the South Coast Air Quality Management District (SCAQMD) and California Air Resources Board (CARB) issue with low vapor pressue (LVPs). Now, SCAQMD will begin work…
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LVP–VOCs On Jan. 25, the California Air Resources Board (CARB) held their executive Board meeting to consider adoption of the South Coast Air Quality Management Plan (AQMP). Remember, this is the AQMP that in December…
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SCAQMD On Dec. 7, 2012 the South Coast Air Quality Management District (SCAQMD) held their board hearing to adopt their Air Quality Management Plan (AQMP). The AQMP included four provisions that would affect Coatings and…
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SCAQMD On Dec. 7, 2012, The South Coast Air Quality Management District (SCAQMD) will hold a hearing on their Air Quality Management Plan (AQMP). At this hearing, the board will vote on the AQMP. One…
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There have been further attacks on the low vapor pressure (LVP) definition. Readers may recall that in May, the California Air Resources Board (CARB) discussed the LVP definition, but put off further discussions until Fall 2012. However,…
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CARB The California Air Resources Board (CARB) has posted proposed amendments to the Consumer Products Regulation. These proposed amendments are for Aerosol Coatings and Aerosol Adhesives. For Aerosol Coatings, these eight categories have proposed limits that…
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This month there is only one significant issue that affects our Industry. South Coast Air Quality Management District (SCAQMD) has proposed to remove the Low Vapor Pressure Volatile Organic Compounds (LVP-VOC) exemption from Consumer Products. This…
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Green Chemistry The Dept. of Toxic Substance Control (DTSC) in California released their informal Draft Green Chemistry Regulation for a short preview on May 18 and asked for comments by May 29. The Draft Green Chemistry Regulation…
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CARB The California Air Resources Board (CARB) has had a drastic change in focus this month. The aerosol coating and adhesive rule has been delayed. The staff will focus their attention on Windshield Washer Fluid, Paint Thinner…
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