April 2015

Consistency needed across air districts, CARB survey deadline passes

REGS415
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 a significant amount of work and taken up a significant amount of time. Hopefully, it will be worth it. The information gathered by CARB staff should aid the industry in dealing with upcoming amendments to the Consumer Products Rule.
CARB needs updated information on products to be able to develop regulations on our products. This new information will replace information from surveys performed in 2003 and 2006. This updated inventory should go a long way in clearing up some discrepancies in product inventories that we have experienced in the last rule makings. The new survey data will make the next rulemaking simpler and with fewer errors.
In addition, the new survey data will update the Consumer Products Inventory for the next State Implementation Plan (SIP). This new inventory will be the basis for future volatile organic compound (VOC) reductions from Consumer Products. The survey may help with the SIP because products that have been reformulated to meet current effective dates will have been “captured,” which means products will have lower VOC content. In turn, there will be fewer VOCs emitted by our products. Therefore, the survey is worth the effort. For more information on the CARB Survey, visit:
http://www.arb.ca.gov/consprod/regact/2013surv/2013main.htm.
LVPs
Updates from CARB on its low vapor pressure (LVP) studies were discussed late in March. An update will be provided in the next issue. Remember, LVPs are a very important issue for our industry!
CALStatewide Regulation
For several years, the aerosol industry has been dealing with the issue of overlapping regulation or patchwork regulations between the air districts in California and CARB. Industry needs statewide regulation on consumer products; having both district and CARB regulation on our products would be a nightmare.
Industry met with CARB and South Coast Air Quality Management (SCAQMD) earlier this year. The meeting was to discuss how industry could work with the two agencies to ensure statewide regulation of consumer products. Industry was considering running legislation in 2015 to deal with this issue. However, the meeting was successful in that CARB, SCAQMD and industry plan to meet during the year to get updates on future regulatory issues. Therefore, no legislation is needed at this time.
Hopefully this working relationship will provide much needed statewide consistency. I will be providing details as these meetings proceed. Our goal is consistent regulation that is technologically and commercially feasible.