Critical Dates

ARR Pre-Meeting CARB Meeting Sept 25-26, 2013

The California Air Resources Board (CARB) posted notice of the public hearing on the Amendments to the Antiperspirants and Deodorants Regulation; Consumer Products Regulation; Aerosol Coating Products Regulation; The Tables of Maximum Incremental Reactivity Values; Test Method 310; and Proposed Repeal of the Hairspray Credit Program scheduled for Thursday, September 26.  The public comment period begins on August 12 and closes at 12:00 pm PDT on September 25.  A link to access the public notice, Initial Statement of Reasons (ISOR) and rulemaking text is provided below as are links to the appendices B and F related to consumer products.

Public Notice, ISOR and Regulation TextCARB Meeting Webcast Access

For those attending the meeting, a pre-meeting is scheduled as noted below.  A link to access the CARB meeting webcast is also provided below for those not able to participate in person.

ARR Pre-Meeting & CARB Meeting

o   ARR Pre-meeting, California Manufacturers & Technology Association, 1115 11th Street, Sacramento

§  Wednesday, September 25, 4:30-6 pm

o   CARB Meeting, 1001 I Street, Sacramento

§  Thursday, September 26, 9 am

Appendix B – Proposed Amendments to the Regulation for Reducing Emissions from Consumer Products (LVP issue see pages 17-21)

Appendix F – Proposed Amendments to Method 310: Determination of Volatile Organic Compounds (VOC) in Consumer Products and Reactive Organic Compounds in Aerosol Coating Products

CARB Meeting Webcast Access


Dear NAA Members:,

On Wednesday, April 24, 2013 the California Air Resources Board (CARB) staff held a public workshop on their current amendments to the Consumer Products rule.  At the workshop CARB announced for the first time that reference to changing the LVP-VOC definition would be withdrawn from consideration in this rule making, pending the outcome of the LVP-VOC studies that are to be performed.  This is a significant step forward for the Industry.  The Industry has been advocating to CARB to refrain from moving forward on changes to the LVP-VOC definition until the results of the scientific studies were completed and reviewed.  CARB staff had initially resisted this approach, however through additional information being supplied CARB has finally agreed to the delay.

While this means Industry dodged a bullet at this time, there is still much more work to be done.  Industry needs to be very diligent on monitoring these scientific studies and performing some of our own studies as well.  The NAA should be extremely proud of this outcome.  Significant time and resources have gone into this effort.  This has truly been a grass root effort.  The NAA deserves the credit for raising this issue to everyone’s attention and remaining actively involved in this effort.  Lets take a moment to enjoy this win….  Okay, now time to make sure that we monitor CARB to ensure that this last proposal is followed through at the Board Hearing on July 26, 2013.  This means Industry needs to comment by May 8 that this new proposal is scientifically sound and encourage CARB to adopt this proposal.

Draft letters will be sent out early next week for your review.

Highlights of the meeting

  • LVP-VOC definition changes dropped
  • Changes to Multi-purpose Solvent and Paint Thinner are still significant, especially in the SCAQMD
  • Multi-purpose Lubricant 10% VOC limit proposed to be delayed until 12/31/2018
  • HFO 1234ze proposed for VOC exemption
  • Changes to aerosol coatings MIR limit were raised for certain general coating categories
  • Numerous definition changes
  • Addition of Specialty Cleaner and Specialty Degreaser categories are significant improvement

Some challenges still remain

  • Aerosol Adhesives Limits still very low
  • Changes to Hair Finishing Spray definition extremely troubling

However, overall the rule making is starting to become more feasible.  Industry needs to continue to be very diligent thru the July timeframe for this rule.

In addition, the LVP-VOC studies could take up to three years to complete.  We as an Industry need to support this effort with all our resources.

In summary, this workshop was a turning point.  Lets keep this going in the right direction.

Thank you to all involved and all of your hard work!

On behalf of the NAA,

Doug Raymond