March 2020

NAA encourages industry involvement with CARB concerning Reactivity

From the National Aerosol Association (NAA):

NAA as a whole has always supported the concept of Reactivity.  We believe this is the best Science.  See below and please highly consider sending a letter to the California Air Resources Board (CARB) from your company.

After almost 10 months of rule development, on March 10, 2020, the California Air Resources Board (CARB) staff announced its intentions to NOT propose the use of Reactivity.  Industry has been possibly considering the use of Reactivity for the future effective limits for some categories; mainly Dry Shampoo and Hairspray.

The Industry should push back on this issue.  Reactivity should be considered in every rule-making.  Below please find and review some points on Reactivity.  Please consider writing a letter to CARB urging the use of Reactivity. Send your comments via e-mail to Ravi Ramalingam at [email protected] and Joe Calavita at [email protected]

Here are some points to put in a letter on Reactivity to CARB.

  • Reactivity is sound Science.  The reduction of the MIR of a product ALWAYS leads to a reduction in Ozone.  Mass based regulations do not always reduce ozone production from a product.  
  • Reactivity has been implemented by CARB for Aerosol Coatings for over 18 years.  Just recently adopted for Multi-purpose lubricants.  Lastly, Reactivity has been implemented by US EPA on Aerosol Coatings.
  • Reactivity provides the Manufacturer/Marketer flexibility in reformulation of their products.  Reactivity also creates more flexibility to develop effective products while obtaining emission reductions.  
  • Industry supplied three years of data including reactivity data to CARB staff.  This information was supplied in good faith with the thought that CARB would use this data to provide a more productive rule-making.
  • Industry should be the one to decide how best to regulate our products.  CARB is in possession of all of the Reactivity data to regulate our products.  This data should be given to the Industry.  If a Reactivity limit can be used to achieve an equivalent VOC reduction and provide Industry with Flexibility this is a win for the Agency and a win for the Industry meaning a Win-Win situation.
  • Industry has offered to work with CARB staff in providing information and tests for CARB to regulate these products under Reactivity.  To date CARB staff has not asked for any information.
  • Throughout this process CARB has stated this is a transparent activity.  Not sharing this intention was far from transparent. 
  • Throughout the Rule-making Reactivity was discussed.  As of November 7, 2019, in the staff Power Point the issue of Reactivity consideration was proposed. 
  • CARB staff in late February agreed to provide Reactivity equivalent VOC values for the product categories.  Thus, providing hope that Reactivity limits might be considered.
  • Then on March 10, 2020, due to a question that was asked, the staff admitted that no Reactivity limits would be proposed.  This was the first time this was announced.  Nearly 10 months into the Rule-making this announcement was made.