About

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.

Regulatory Issues

AIM Technology Transition The American Innovation & Manufacturing Act (AIM) Technology Transition section regulates hydrofluorocarbons (HFCs) in Consumer Aerosol Products and Technical Aerosol Products. This regulation was adopted Oct. 24, 2023, and becomes effective Jan. 1, 2025; as of this date, any Consumer Aerosol Product that has an HFC compound with a Global Warming Potential […]

Regulatory Issues

CARB On July 23, Nicholas Georges from the Household & Commercial Product Association (HCPA) and I, representing the National Aerosol Association (NAA) and Personal Care Products Council (PCPC), met with numerous members of the California Air Resources Board (CARB) to discuss the progress on the next Consumer Products Rule amendments. The meeting was very informative. […]

Regulatory Issues

SCAQMD On July 11, the South Coast Air Quality Management District (SCAQMD) held its third work group meeting for Proposed Amendments to Rule 1151 Motor Vehicle & Mobile Equipment Non-Assembly Line Coating Operations—more often referred to as the Auto Refinish rule. This was a continuation from the last two work group meetings. The focus of […]

Regulatory Issues

SCAQMD In May, the South Coast Air Quality Management District (SCAQMD) held two workgroup meetings. May 21 SCAQMD staff held its second workgroup meeting concerning Rule 1151 Automotive Refinish Coatings. SCAQMD is attempting to prohibit parachlorobenzotrifluoride (PCBTF) and tertiary butyl acetate (tBAc) from Automotive Refinish Coatings. SCAQMD amended its rule 1168 on Adhesives last year […]

Regulatory Issues

OTC Meeting On April 22, the Ozone Transport Commission (OTC) held its Spring virtual meeting, during which it was mentioned that the Consumer Model Rules were edited. Changes included administrative and formatting updates, such as modified dates and rules. As well, it was reported that the Consumer Products Phase I, II, III and IV were […]

Regulatory Issues

New York On March 13, the State of New York held a webinar to accept comments on amendments to 6 NYCRR Part 494 on the use of hydrofluorocarbon substances (HFCs). This affects aerosol products and small containers of automotive refrigerants. The amendments mainly align with the newly-finalized Technology Transitions Program by the U.S. Environmental Protection […]

Regulatory Issues

SCAQMD In March, the South Coast Air Quality Management District (SCAQMD) in California held its second Work Group meeting on Rule 1151 Motor Vehicle & Mobile Equipment Non-Assembly Line Coating Operations, commonly called the Auto Refinish Rule, to discuss amendments. The Rule is primarily being amended to prohibit the use of two compounds: Para-Chlorobenzotrifluoride (PCBTF […]

Regulatory Issues

NYSDEC replaces CARB this month as the agency at the top of the list to deal with… NYSDEC The New York State Dept. of Environmental Conservation (NYSDEC) proposed amendments to Hydrofluorocarbon Standards & Reporting, its Rule 6 NYCRR Part 494. Even though the U.S. Environmental Protection Agency (EPA) has adopted the Technology Transition Final Rule […]

Regulatory Issues

CARB In my most recent meeting with the California Air Resources Board (CARB), its staff mentioned that the survey it will use in the next rule development should be out in the first quarter of 2024. Expect Aerosol Coatings, Cleaning Products and Hand Sanitizers to be on the list. Other possible categories are Aerosol Sunscreens, […]

Regulatory Issues

Happy New Year! As the New Year begins, we have a new Canadian volatile organic compound (VOC) Consumer Products Regulation, we will need to continue to deal with the California Air Resources Board (CARB) and will work with Nevada’s Clark County, Oregon and (likely) New Jersey on VOC Regulations. Lastly, we will need to work […]