About

Doug Raymond

Doug Raymond is owner of Raymond Regulatory Resources (3R), consulting in the regulatory and governmental arena concerning consumer products. He has worked in the aerosol industry for the past twenty-two years. Doug has extensive experience interfacing with regulatory agencies, legislative bodies, corporations and trade associations. He has been a critical leader for the aerosol industry in dealing with regulations that affect the industry. Doug has been successful in building coalitions and effective compliance strategies for the consumer products industry. Currently Doug is Consultant for the National Aerosol Association (NAA) and a regular monthly contributor of “Regulatory Issues” for Spray Technology.

Regulatory Issues

SCAQMD In May, the South Coast Air Quality Management District (SCAQMD) held two workgroup meetings. May 21 SCAQMD staff held its second workgroup meeting concerning Rule 1151 Automotive Refinish Coatings. SCAQMD is attempting to prohibit parachlorobenzotrifluoride (PCBTF) and tertiary butyl acetate (tBAc) from Automotive Refinish Coatings. SCAQMD amended its rule 1168 on Adhesives last year […]

Regulatory Issues

OTC Meeting On April 22, the Ozone Transport Commission (OTC) held its Spring virtual meeting, during which it was mentioned that the Consumer Model Rules were edited. Changes included administrative and formatting updates, such as modified dates and rules. As well, it was reported that the Consumer Products Phase I, II, III and IV were […]

Regulatory Issues

New York On March 13, the State of New York held a webinar to accept comments on amendments to 6 NYCRR Part 494 on the use of hydrofluorocarbon substances (HFCs). This affects aerosol products and small containers of automotive refrigerants. The amendments mainly align with the newly-finalized Technology Transitions Program by the U.S. Environmental Protection […]

Regulatory Issues

SCAQMD In March, the South Coast Air Quality Management District (SCAQMD) in California held its second Work Group meeting on Rule 1151 Motor Vehicle & Mobile Equipment Non-Assembly Line Coating Operations, commonly called the Auto Refinish Rule, to discuss amendments. The Rule is primarily being amended to prohibit the use of two compounds: Para-Chlorobenzotrifluoride (PCBTF […]

Regulatory Issues

NYSDEC replaces CARB this month as the agency at the top of the list to deal with… NYSDEC The New York State Dept. of Environmental Conservation (NYSDEC) proposed amendments to Hydrofluorocarbon Standards & Reporting, its Rule 6 NYCRR Part 494. Even though the U.S. Environmental Protection Agency (EPA) has adopted the Technology Transition Final Rule […]

Regulatory Issues

CARB In my most recent meeting with the California Air Resources Board (CARB), its staff mentioned that the survey it will use in the next rule development should be out in the first quarter of 2024. Expect Aerosol Coatings, Cleaning Products and Hand Sanitizers to be on the list. Other possible categories are Aerosol Sunscreens, […]

Regulatory Issues

Happy New Year! As the New Year begins, we have a new Canadian volatile organic compound (VOC) Consumer Products Regulation, we will need to continue to deal with the California Air Resources Board (CARB) and will work with Nevada’s Clark County, Oregon and (likely) New Jersey on VOC Regulations. Lastly, we will need to work […]

Regulatory Issues

At the Western Aerosol Information Bureau (WAIB) meeting in October, Industry received updates from the U.S. Environmental Protection Agency (EPA) and the California Air Resources Board (CARB) concerning ongoing activities. EPA AIM ACT As reported in the last issue, the EPA released its Technology Transitions Final Rule under its American Innovation & Manufacturing (AIM) Act. […]

Regulatory Issues

There was significant activity last month. AIM The Technology Transitions Final Rule under The U.S. Environmental Protection Agency’s (EPA) American Innovation & Manufacturing (AIM) Act was made publicly available on Oct. 6 as a pre-publication. We expect the Final Rule to be the same. The Technology Transitions Rule restricts the use of hydrofluorocarbons (HFCs) by […]

Regulatory Issues

CARB Industry awaits the California Air Resources Board (CARB) release of its next survey request. It was expected to be released during the Summer, but Summer has come and gone and there is still no survey. From discussions with CARB staff, it’s thought that the survey might cover products used during the COVID-19 pandemic to […]