March 2017

Regulatory Issues

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 out for the CARB report.

If you are a manufacturer, marketer or formulator of Multi-purpose Lubricants, then this report is mandatory; it is necessary for CARB staff to determine if the future effective limit of 10%—effective Dec. 31, 2018—is feasible. This is the aerosol industry’s opportunity to provide feedback to CARB on whether the 10% limit is technically and commercially feasible.

It does not happen often that our industry can provide this type of input into CARB. Thus, any and all data from reformulation work should be supplied to CARB. If the future 10% limit for Multi-purpose Lubricant will not provide a feasible product then now is when to comment on this. In addition, if the cost of a reformulated product is also not feasible, now is the time to comment.

All comments are due by March 31, 2017. As stated before, if you are a formulator, your comments are also due by the same date. Therefore, contact your clients to find out if their products are sold into California.

The Reporting Tool for Multi-purpose Lubricants can be found at https://www.arb.ca.gov/consprod/regact/2016mpl/2016instruction.pdf

Let me stress one last time, report by March 31, 2017.

LVP Update
The last low vapor pressure compounds (LVP) study by CARB has been completed and is being finalized by CARB staff. The study is extremely complicated, as are the results, and it appears it will take a while for CARB to sort them out. More to come on this issue.

CARB SIP update
It has been a while since there has been an update on the State Implementation Plan (SIP) for California. Remember, the SIP is what guides the CARB staff to develop new rules on our products. Currently, CARB staff is waiting for the South Coast Air Quality Management District (SCAQMD) to finish its SIP. Currently, there are no Consumer Product requirements in the SCAQMD SIP—this is good! The SIP process will go quickly once SCAQMD is done.

It is not anticipated that Consumer Products will need to make significant reductions; however, it is very likely that some reductions will be needed.

Ozone Transport Committee
At the last Ozone Transport Committee (OTC) meeting, the committee that develops the new model rules was charged with updating the current model rule. Typically, OTC is a few years behind the CARB rule, waiting for them to become effective. Well, there has been a long delay in the OTC updating this current model rule and most of the CARB rules have become effective. Thus, some of the OTC states that have not updated their rule to the current model are asking for the current model to be updated before they adopt. This is the first time we have been in this predicament. We will need to wait and see how it goes.

Currently, Connecticut is working on a rule and we expect New York to propose a rule soon.