Written on: February 1, 2025 by Doug Raymond
The Year In Review
During 2024, several significant regulatory changes occurred in respect to the use of Reactivity. First, the California Air Resources Board (CARB) decided that the next rule-making amendments will use Reactivity limits to regulate Consumer Products. This is a historic change to the way CARB has operated over the last 34 years. While it is true that CARB did adopt the Aerosol Coating Rule in 2001 solely using Reactivity, it had been reluctant to use Reactivity for Consumer Products. This changed in 2019 with the Alternate Compliance Option for Multi-Purpose Lubricants. Then again, in the last rulemaking, the new provisions for the Innovative Product Exemption (IPE) for hair spray, dry shampoo and personal fragrance were solely based on Reactivity. This next rulemaking should be interesting.
Did you know that the South Coast Air Quality Management District (SCAQMD) also incorporated Reactivity into its amendments for Rule 1151 on Auto Refinish Coatings? Historically, SCAQMD has been the toughest agency in the country—if not the whole world—on reducing volatile organic compounds (VOCs) in products. The SCAQMD region (Southern California) has the worst air quality in the country, thus its tough stance on reducing VOCs. In November 2024, SCAQMD adopted alternative Maximum Incremental Reactivity (MIR) limits and effective dates for two coating categories, as well as thinners. I know it is only three categories, but it is a start. These limits become effective on Jan. 1, 2028.
For years, Industry has been fighting for Reactivity. Now is the start of a new way to regulate our products. Remember, a reduction in the MIR content is a reduction in ozone produced. This cannot be said about a reduction in mass VOC content. Thus, this should be a more scientific way to regulate smog production.
CARB
The new CARB survey is out for the Industry to complete by April 8, 2025. If a company manufactures a Consumer Product that appears on the CARB survey list, it is required to submit a completed survey by the April 8 deadline.
In addition, CARB held a webinar on Jan. 16 regarding its Toxicity Ranking Methodology. We learned CARB’s logic on this topic as staff gave an in-depth explanation of the calculations used to determine the toxicity scores that were used to select the categories for the 2023 Consumer Products Survey. In addition, CARB discussed its next steps for prohibiting toxic compounds, including parachlorobenzotrifluoride (PCBTF), which I will share in next month’s column.
SCAQMD 1151
Now that I referred to the SCAQMD Rule, let me provide more information. As stated, these are historic amendments from SCAQMD, with the Reactivity limits coming into play. Even more impressive is that the SCAQMD staff relaxed (yes, relaxed) some of the VOC limits in the regulation. SCAQMD is attempting to prohibit PCBTF and tertiary-Butyl Acetate (tBAc) from being exempt or used in the rules. Starting with Rule 1168 on Adhesive, staff is working through rules to eliminate the use of these two compounds. In Rule 1151, SCAQMD relaxed the VOC limits to the National limits for anywhere from 4–6 years for numerous categories.
The loosening of the VOC limits allows manufacturers time to reformulate SCAQMD products. This allows manufacturers to supply customers in the SCAQMD with products and phase-out of PCBTF. This phase-out of PCBTF starts as early as May 1, 2025, for some products and allows a one-year sell-through and an additional year for use. Other categories have a phase-out of Nov. 1, 2025, with sell-through and use-through dates also of one year.
Again, these are historic times, as I never thought I would see SCAQMD relax VOC limit to National limits. SPRAY
