April 2018

Regulatory Issues

Article in Science

On Feb. 15, 2018, the journal Science published research titled “Volatile Chemical Products Emerging as Largest Petrochemical Source of Urban Organic Emissions.” This researched study is very significant to the consumer products and paint industries. The lead author is Brian McDonald, along with numerous other scientists. This work contradicts most of the findings to date.

The study states that current inventories of emissions are significantly underestimated—by as much as two to three times. It also states that consumer products emissions, including those from paints and personal care products, are close to the emissions from cars. The study continues to state that fragrances are also a major source of emissions because of limonene and pinene compounds. Additionally, the study asks the question if low vapor pressure volatile organic compounds (LVP-VOCs) are a major source of emissions as well by contributing to the formation of Secondary Organic Aerosols (SOA).

The reason that consumer product emissions appear greater is they are not being reduced as fast as emission from cars. Thus, the entire emissions universe is shrinking but consumer products emissions now appear larger. This study was picked up by numerous news agencies in the U.S. and in Europe. Headlines include “Consumer Products overtake transportation as largest source of VOCs,” “Fragranced products to blame for smog as much as cars” and “Household products now rival cars as source of Air Pollution.” Obviously, this is not good news for the industry. Media like this puts additional pressure on agencies such as the California Air Resources Board (CARB) to act on regulating our categories more.

What will happen as a result of this study is not yet known. However, we can expect more research in this area. Also, CARB will review its estimates of emissions and this study will likely push it to release its survey data sooner than expected.

The only redeeming information in the study was a statement that says consumers should only use the amount of product necessary to complete a task. I believe the aerosol industry has been saying this for years. There is more to come on this issue.

CARB Survey data

Over the last three years, the industry has filed survey data with CARB on all consumer products sold into the state of California. This was the largest and most comprehensive set of surveys that have been done on the industry to date. The Science study will likely make CARB release its survey data soon.

These surveys should show the actual emissions from our products. It will be interesting to see how CARB’s emissions data matched up with the Science study, which industry believes used old data. Hopefully, this new data will show that consumer product emissions have indeed declined over the years. Expect the data from the surveys sometime in April.

CARB Multi-purpose Lubricant

The amendment on the Alternative Compliance Option for Multi-purpose Lubricants (MPL) is continuing through its process. The amendment will provide industry with an option to meet the 10% VOC mass based limit or meet an alternative reactivity-based limit of 0.45 Maximum Incremental Reactivity (MIR). In addition, the future effective limit has been delayed until July 1, 2019 for both options. The CARB Executive Board will vote on these amendments in May. The comment period should begin in April.

Ozone Transport Commission

The Ozone Transport Commission (OTC) is in the process of developing yet another Model Rule. OTC plans to have this Model Rule ready by the end of the first quarter of 2018. We need to work with them to narrow the amount of Model Rules out there for states to adopt. SPRAY