Written on: September 1, 2024 by Doug Raymond
CARB
On July 23, Nicholas Georges from the Household & Commercial Product Association (HCPA) and I, representing the National Aerosol Association (NAA) and Personal Care Products Council (PCPC), met with numerous members of the California Air Resources Board (CARB) to discuss the progress on the next Consumer Products Rule amendments.
The meeting was very informative. As we know, there needs to be a survey of product categories and, for the first time, we were provided an expected number—between 40 and 50. Most of these categories will be based on the higher volatile organic compound (VOC)-emitting products, whether by mass-based VOC or reactivity-based VOC. Thus, we can look back at the 2013–2015 survey data and get an idea of which categories will be impacted. However, while this is just speculation, we are expecting the survey to be released soon. My guess for expected survey timing is now October.
In addition to higher VOC-emitting categories, CARB will also be targeting product categories with toxic compounds. For months, we have been trying to discover which compounds CARB will target as toxic.
There was also a long discussion of toxic compounds and the product categories that contain them. The good news is that there were no surprises. Topping the list is parachlorobenzotrifluoride (PCBTF). This compound is also being targeted by the South Coast Air Quality Management District (SCAQMD) in numerous district rules. Next on the list are methylene chloride and perchloroethylene. Again, no surprises there, as CARB had previously targeted these compounds and the product categories that contain them. Topping the Consumer Product category list for containing toxics is Paint Remover or Stripper and Energized Electrical Cleaner. Both of these categories have been targets of CARB in past rulemakings. However, with the U.S. Environmental Protection Agency (EPA) prohibition on methylene chloride in Paint Strippers, this category may move lower on the targeted list, depending on with what the manufacturers have reformulated the Paint Strippers.
CARB implemented a very comprehensive and complicated method to rate the toxicity of both compounds and product categories; it must have taken CARB staff a significant amount of time and effort to comb through all of the existing data to develop this process and some of the product categories that will be included on the survey will be from this exercise.
New CARB Manager
CARB has announced that the new Manager of the Implementation Section is Moslem Hossein Mardi, who comes from the Mobile Source Control Division of CARB. More information on Hossein Mardi can be found on p. 29 and on Spraytm.com. We look forward to working with him.
CARB Enforcement
We met with Shannon Downey, CARB Enforcement Manager of Consumer Products, who stated that, as always, CARB is looking at Consumer Products and finding products with no date codes. This incurs an automatic fine, so be sure your products are date-coded.
If you use a code different from CARB’s standard date code, remember to send it to CARB for its records. It’s as easy as that, and will ultimately save you time and money.
Oregon
On Aug. 1, the State of Oregon Air Quality Division held a meeting to discuss the development of VOC regulations on Consumer Products and Architectural Coatings. The meeting lasted two hours as staff explained the reasons and potential pathways it will take to develop the regulation. Staff will more than likely use Ozone Transport Commission (OTC) existing rules. This is the strange part—Oregon is already in compliance with VOC regulation. So why a new regulation? We have yet to find out. SPRAY
