Written on: November 1, 2024 by Doug Raymond
CARB
The California Air Resources Board (CARB) should be releasing information on its next volatile organic compound (VOC) survey soon. In discussions with CARB management, it was determined that the potential number of categories for the next survey is likely to be between 40 and 50. CARB used the 2013–2015 survey results to choose the following categories:
• High VOC by mass
• High VOC by reactivity
• Where toxics are present
The following are the top ten categories for High VOC by mass:
1. Hairspray
2. Hand Sanitizer
3. Personal Fragrance Product: 20% or less
4. Rubbing Alcohol
5. Disinfectant (aerosol)
6. General Purpose Cleaner (non-aerosol)
7. Air Freshener (liquid pump)
8. Detergent
9. Sunscreen
10. Charcoal lighter material
The following are the top ten categories for High VOC by Reactivity:
1. General Purpose Cleaner (non-aerosol)
2. Detergent
3. Air Freshener (liquid pump)
4. Personal Fragrance Product: less than 20%
5. Hand Sanitizer
6. Hair Finishing Spray
7. Hand & Body Cleaner (Soap)
8. Liquid Fabric Softener
9. Scented Candles
10. Floor Wax Stripper
Also included in the Reactivity top 25 are the following:
• Shampoo
• Multi-purpose Solvent
• Pet Care Products
• Paint Thinner
• Sunscreen
• Rubbing Alcohol
• General Use Hand Soap
These categories are listed because CARB will likely—for the first time—choose to regulate categories by reactivity instead of mass.
Remember that Hairspray and Personal Fragrance Products were regulated in the last rulemaking, so it is questionable as to whether these product categories will be on the list. My guess is that they will be, so that CARB can update its emission numbers on high VOC categories. However, that remains to be seen.
CARB has stated that it will also survey products that include toxics. CARB did an in-depth review of product categories and developed an elaborate mechanism to rate toxics. The top five toxic compounds were:
1. PCBTF
2. Methylene Chloride
3. Perchloroetylene
4. 1,4-Dichlorobenzene
5. Trichloroethylene
None of these compounds are a surprise, nor are the following top five product categories containing these compounds:
1. Paint Remover or Stripper
2. Energized Electrical Cleaner
3. Thinner (Motor Vehicle Coatings)
4. Mothballs
5. Paint Thinner
Again, no surprises there. My only comment on these categories is that, with the Federal ban on Methylene Chloride, the Paint Stripper category will likely be moved farther down on the list.
As reported in the last issue, CARB will be holding preliminary meetings with Industry on its choice of product categories for the survey; this will likely have started in late October. This is our opportunity to comment to CARB on product categories. This is likely our only opportunity to comment on which categories are added to the survey, so Industry needs to take advantage. However, there is nothing that guarantees our comments will influence CARB’s decision.
Finally, it appears the process will begin for the next rulemaking.
Oregon
Oregon held its second advisory committee meeting on Sept. 13. It is uncertain in which direction the State will go on its rulemaking. If Oregon goes right to the CARB regulation, it will be the first State to take this approach. Oregon has said that it will reveal its position at the next advisory committee meeting.
This whole process has been bizarre due to the fact that Oregon is a State in Attainment and therefore does not need emission reductions.
New Jersey
We are expecting New Jersey to adopt OTC Model Rule IV. A virtual meeting was held on Oct. 15; more information will be provided in a future issue.
Clark County, Nevada
Still no news!
AIM Technology Transition Rule
The American Innovation & Manufacturing Act (AIM) Technology Transition Section has requirements for labeling, effective Jan. 1, 2025. Therefore, there are only two months left to get a four-digit date code onto products. Please review the October 2024 edition of Regulatory Issues for complete information.
Reporting starts in March 2025. SPRAY
