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

December 1, 2023

At the Western Aerosol Information Bureau (WAIB) meeting in October, Industry received updates from the U.S. Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) concerning ongoing activities. EPA AIM ACT As reported in the last issue, the EPA released its Technology Transitions Final Rule under its American Innovation & Manufacturing (AIM) Act. […]

Regulatory Issues

November 1, 2023

There was significant activity last month. AIM The Technology Transitions Final Rule under The U.S. Environmental Protection Agency’s (EPA) American Innovation & Manufacturing (AIM) Act was made publicly available on Oct. 6 as a pre-publication. We expect the Final Rule to be the same. The Technology Transitions Rule restricts the use of hydrofluorocarbons (HFCs) by […]

Regulatory Issues

October 1, 2023

CARB Industry awaits the California Air Resources Board (CARB) release of its next survey request. It was expected to be released during the Summer, but Summer has come and gone and there is still no survey. From discussions with CARB staff, it’s thought that the survey might cover products used during the COVID-19 pandemic to […]

Regulatory Issues

September 1, 2023

CARB There has been no notice yet on the proposed Consumer Product Survey that California Air Resources Board (CARB) staff proposed earlier this year. Originally, staff had stated that the Survey would be out this Summer. Well, Summer is all but gone and it has not yet appeared. CARB has stated that the Survey would […]

Regulatory Issues

August 1, 2023

Canada Friendly reminder, Environment & Climate Change Canada (ECCC) adopted the Volatile Organic Compound (VOC) Concentration Limits for Certain Products Regulation. This is the Canadian version of the VOC regulation for Consumer Products. This rule was adopted in 2022 and comes into effect Jan. 1, 2024 for the majority of products. For Disinfectants, the regulation […]

Regulatory Issues

July 1, 2023

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 […]

Regulatory Issues

June 1, 2023

Michigan On April 18, the Air Quality Division of the Michigan Dept. of Environment, Great Lakes & Energy finally promulgated its Final Rule for both Consumer Products and Architectural Coatings. Having gone through the legislative process, this ruling is now complete. Please remember that Michigan had placed a Jan. 1, 2023, compliance date on both […]

Regulatory Issues

May 1, 2023

California Industry is preparing to provide the California Air Resources Board (CARB) with some training. The National Aerosol Association (NAA), Western Aerosol Information Bureau (WAIB), Household & Commercial Products Association (HCPA) and Personal Care Product Council (PCPC) will be in Sacramento on May 16–17 to present information to CARB staff on our products. On May […]

Regulatory Issues

April 1, 2023

CARB As discussed in the March issue, the California Air Resources Board (CARB) was working on the Innovative Product Exemption (IPE) Guidelines for the compressed and liquefied products provision. This provision was added to the CARB regulation during the last rule development. I predicted the guidelines would be out by the end of the first […]

Regulatory Issues

March 1, 2023

CARB Currently, the California Air Resources Board (CARB) is working on developing a survey for product categories, due out this year. I believe the survey will concern cleaning products, disinfectants, sanitizers and possibly hand sanitizer, as well. We will need to wait and see which product categories CARB decides to target. CARB staff is also […]