On Sept. 26, the California Air Resources Board (CARB) commissioners approved proposed amendments to the Aerosol Coatings Regulation, the Consumer Products Regulation, and Method 310, the test method used to calculate volatile organic compounds (VOC) in consumer products and reactive ingredients in aerosol coatings. ACA and its Caulks, Sealants and Adhesives and Spray Paint Manufacturers Committees have been very actively engaged with CARB throughout the development of this rulemaking, providing multiple sets of comments and data, proposing new standards and categories, discussing the nuances of definitions and testing methods, and considering solvent substitutions and reformulations. The importance of these efforts cannot be understated: while many of the new reactivity standards for aerosol coatings are extremely challenging, ACA's efforts to mitigate more onerous standards was largely successful. ACA and many of its members participated in several CARB-held public workshops, offering alternative proposals for several of the product categories, and also hosted an Aerosol Technology Seminar for CARB, intended to provide CARB staff a better understanding of the aerosol delivery system, to highlight specific formulation challenges for aerosol coatings and aerosol adhesives, and to demonstrate the significant impact that major changes to the standards for aerosol coatings and adhesives will have on manufacturers, formulators, fillers, and marketers.
ACA's efforts began in earnest more than a year ago when reviewing CARB's preliminary data summaries for aerosol coatings and aerosol adhesives. The preliminary data summaries — for both currently regulated products and categories not currently regulated by a reactivity standard in the aerosol coatings regulation — are the reported results of the agency's data collection and analysis. These points became the database upon which a Product Weighted Maximum Incremental Reactivity (PWMIR) standard is based and which ultimately result in stricter air quality standards for the regulated products. The reactivity standard regulates VOC emissions in a product based on its likelihood of reacting to form ozone.
CARB had said that the goal for this rulemaking is the maximum feasible VOC emission reductions, including the four tons per day required emissions reductions for the current State Implementation Plan (SIP). ACA, on several occasions, has stressed to CARB that the 2010 ARB Survey results indicate that aerosol coatings are formulated below the current reactivity standards. By ACA calculations, this has resulted in an additional 2.23 tons per day of emission reductions that are not included in the total emissions reductions for this rulemaking. While understanding the complexities involved in attempting to recognize these emission reductions and apply them to California's current SIP requirements, ACA continues to seek some appropriate resolution which accounts for these "lost" emission reductions — reductions which have resulted in better air quality.
The proposed rule provides that the newly proposed PWMIRs for General Categories and Specialty Category A become effective on Jan. 1, 2017, while the Specialty Category B products must meet the new revised standards by Jan.1, 2015. The General Categories include the largest categories by volume, including Clears, Flat, Non Flat, and Primers, and make up more than 90 percent of the products reported in the survey. According to the ARB 2010 Survey, the Non Flat category is the largest, at 1,053 products reported. There are 225 products reported in the Flat category, 251 products reported in the Clear category, and 226 reported in the Primer category. Reformulating over 1,700 formulas will take some aggressive and careful management by manufacturers, which would be virtually impossible without the bifurcated compliance deadline.
CARB, however, did adjust the proposed mass-based standards for aerosol adhesives, increasing the standard for web spray adhesives from 30 to 40 percent, and developed a new subcategory for screen print adhesives with a VOC content standard of 55 percent.
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