Current CSPA Issues and Projects Impacting the Aerosol Products Industry March 21, 2013 SATA Spring Meeting Marriott Perimeter Center Atlanta, Georgia D. Douglas Fratz Senior Science Fellow & Aerosol Products Division Staff Executive Washington, DC - USA
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Current CSPA Issues and Projects Impacting the Aerosol Products Industry
March 21, 2013 SATA Spring Meeting Marriott Perimeter Center Atlanta, Georgia
D. Douglas Fratz Senior Science Fellow & Aerosol Products Division Staff Executive
Washington, DC - USA
OR
“Why You Must Play to Win”
Today’s Presentation • CSPA General Committee Issues
and Projects
• CSPA Aerosol Products Division Issues and Projects
• CSPA Affiliates Issues and Projects
CSPA General Committee Issues and Projects
• California Air Quality Plans and Regulations •CSPA Air Quality Committee and Alliance for Responsible Regulation
• California Safer Consumer Products Regulation • CSPA SAC Green Chemistry Task Force and State GAAC
• Ingredient Communication • CSPA Chemicals Management Team and State GAAC
• Issue: Bright Line Between Rules; No Dual Regulation
CARB 2013 Amendments
• CSPA Proactive Changes Being Sought
• Clarify Line Between Consumer and Manufacturer-Use Products • Clarify Line Between General/Multipurpose and Specialty • Clarify That Concentrates Can Have Dilutions for Multiple Limits • Extension for 10% Limit for Multipurpose Lubricants
• Schedule for Completing 2014 Amendments • February – 2nd Workshop/New Draft Proposals • March – Written Comments Due • April – 3rd Workshop • May – Proposed Rule • June – Rule Adoption
Retailer VOC Compliance Initiative
• 2010 - 2012 - Wal-Mart VOC Compliance Data Call-Ins • 2012 – Wal-Mart to CSPA: Work with The Wercs
• CSPA Critique of The Wercs Coatings VOC Portal
• CSPA Agrees to Assist The Wercs on Making Portal Reliable
• 2013 – Wercs Agrees to Work with CSPA to Improve VOC Portal • Assure Consumer Products Categories and Limits Are Accurate • Assure Ingredients Consistent with CSPA Dictionary • CSPA VOC Compliance Webinars
Other 2013
Air Quality Initiatives
• 2014 Ozone Transport Commission (OTC) Model Rule
• Utah Consumer Products Regulation
• VOC Limits in Green Seal Standards
• Canadian Consumer Products Regulation
DTSC Safer Consumer Products Regulation
Key CSPA Concerns About SCP • Inadequate protection of confidential business information
& trade secrets • Practical Quantitation Level & lack of de minimus threshold • Alternative Analyses Process
– Potential cost and barriers – Inappropriate timelines – Removal of certified assessors is improvement – Public review & comment raises confidentiality & trade issues
• Product-Chemical Identification and Prioritization Factors • Duplication and overlap of regulations • Concerns with Candidate Lists
Ingredient Communication
Current Status
• New York State DEC Still Focused on Fracking
• Federal Legislation in Senate and House Expected
• California Legislation in 2013?
• EPA OPP 25(b) Inert Ingredients Disclosure PR 12/31/12 • CSPA Developing Comments - Due April 1, 2013
• EPA DfE Most Recent Ingredient Communication Fully
• NCWM Net Quantity Declaration Issue • CSPA Comments to DOT on COSTHA Petition • CSPA/RILA Initiative with EPA on RCRA • Aerosol Fire Codes – NFPA 30B and IFC • CSPA Aerosol Recycling Promotion Campaign • International Liaison Meeting & Congress • EPA Aerosol Sector Stakeholder Workshop • Aerosol Sunscreen Flammability Testing • CSPA Aerosol Pressurized Product Survey
National Conference on Weights & Measures Net Quantity Declaration Issue
• Aerosol Products (and Similar Terms) Defined in Numerous Federal & State Regulations
• FTC Regulations per NIST Handbooks 130/133 Require Net Weight for Aerosol Products
• CSPA Consensus Position for BOV Aerosols: Dual Weight/Volume or Just Weight Allowable
• NCWM Prefers Net Weight But Remains Open
CSPA Comments to DOT on COSTHA Petition
• Council on Safe Transportation of Hazardous Articles (COSTHA) Petition to DOT in 2012
• International Harmonization of Aerosol Definition • Standard Criteria for Hot Water Bath Exemption (BOVs)
• DOT Considering Petition, Asked CSPA for Comments • CSPA Comments in March or April 2013
• Agree on Aerosol Definition (Propellant-Only Products) • Concerns with Specific Criteria for Exemptions • Recommend Special Permit Consolidation
Issues CSPA is Seeking to Have Addressed by DOT
• Potential Barriers to International Trade Due to Differences in Definition of Aerosol Between DOT and EU, UN, ICAO, etc.
• Include Propellant-Only Products (Dusters, etc.)
• More Than 20 Current Special Permits for Aerosol Products • Plastic, BOV, Metal Aerosols • Various Alternative Testing in Lieu of Hot Water Bath • Various limitations regarding contents flammability
CSPA/RILA Initiative with EPA on RCRA
• Goal to Increase Materials Recovery for Rejected (Filled) Aerosol Products
• CSPA Providing Support for Walmart and RILA Proposals to EPA to Decrease RCRA Barriers to Sending Rejects for Recovery
• CSPA/RILA Meeting in November 2012 with EPA to Provide Answers to Questions About Current Aerosol Technology and Reject Aerosol Recycling and Materials Recovery
• EPA Plans to Issue Notice in June or July 2013 to Solicit Public Comments to Resolve Retailer Issues
Aerosol Fire Code Issues
• NFPA Code 30B Revision 2012-2014 • Aerosol Cooking Spray Classification • Plastic Aerosol Container TIA • All Fire and Building Code Issues Coordinated in CSPA APD Manufacturing & Storage Standards Committee
• Numerous CSPA Committee Members Participating on NFPA 30B Technical Committee
• International Fire Code • Inclusion of Plastic Aerosol Container TIA
NFPA Code 30B Issues to Be Resolved
• Plastic Aerosols Coverage • CSPA TIA Submitted in 2011 and Approved 2012 • Allow Storage of No-Flammables Products as Level 1 • Issue Raised with Below-4-Ounce Exemption (L2/L3)
• Aerosol Cooking Sprays • Change in 30B Resulted in Level 3 Classification • CSPA/ISEO TIA Submitted in 2012 and Nearing Approval • FM Testing in 2012/2013 to Demonstrate Lower Level
• Aerosol Products vs. Aerosols Terminology • Inclusion of BOVs in 30B (CSPA Analysis: 30B Better Than 30)
CSPA Aerosol Recycling Promotion Campaign
• Goals of Campaign • Increased Acceptance in Curbside Recycling and Consumer Recognition
• Increased Use of “Please Recycle” Logo on Aerosol Products • 2012 Division Marketer/Filler Survey on Current Labeling – 30-50% • 2012 Survey Identified Barriers to Labeling as
• FTC and EPA Regulations (Need to Assure Compliance) • Label Space (Replace CFC Labeling?)
• Ongoing Efforts • Assure That Sufficient Data Exists on Recycling Availability to Justify Unqualified Claim to “Please Recycle When Empty” • Standardize Logos and Claims • Promote Product Labeling in Compliance with FTC Green Guides • Provide CAPCO with Information to Promote Consumer Awareness
International Liaison Meeting and International Aerosol Congress
• FEA Meetings in Madrid, Spain – September 23 • Numerous Issues of Interest
• International Aerosol Congress - September 24-26 • 3-Day Congress and Exhibition
• International Liaison Meeting – September 27 • CSPA Delegation Representing USA • Full Day Discussion by Aerosol Industry Representatives from Around the World
EPA Aerosol Sector Stakeholder Workshop
• Office of Atmospheric Programs Stratospheric Protection Division • March 19, 2013 Meeting in Washington, DC • CSPA APD Atmospheric Policy Committee
• Chairs: Phil Lapin (Falcon Safety) and John Leuszler (DuPont)
• Information Exchange • Transition to Ozone-Depleting Alternatives • Aerosols One of Eight Sectors • Significant New Alternatives Policy (SNAP) • Many CSPA APD Members Participated
Aerosol Sunscreen Flammability Testing
• 2012 Incident Relating to Residual Flammability • BOV Aerosol Skin Sprays • Canada Asking for Safety Testing • No Standard Testing Protocol • Company Inquiry: Could CSPA Develop? • CSPA APD Tests and Standard Methods Committee? • CSPA Product Ingredient Review (PIR) Program?
CSPA Aerosol Pressurized Product Survey
• 2012 Aerosol Fillings/ Containers/ Valves • Aerosol Units Filled and Components Delivered • Total USA and Total North America
• CSPA Mid-Year Meeting Aerosol Products Division Program
CSPA Affiliates Update
• Product Ingredient Review (PIR) • 37 Active Joint Venture Projects • Plastic Aerosol Research Group (PARG)
• Consumer Aerosol Products Council (CAPCO) • www.AerosolProducts.org and Social Media: Twitter and Facebook • Promoting Aerosol Recycling and Recyclability - NSTA • Keep America Beautiful Niche Recycling Webinar • Partnering with ACE
• Alliance for Consumer Education (ACE) • www.Consumered.org - www.inhalant.org – www.StopGerms.org • Inhalant Abuse, Poison Prevention, Disease Prevention • Social Media: Facebook, Twitter, Linked In • Latest Super Hero Partner: Batman!
• Handling these critical issues and projects successfully is essential for our industry. • These issues will not solve themselves. • Your help is needed.
Thank You! Questions?
D. DOUGLAS FRATZ Senior Science Fellow & Aerosol Products Division Staff Executive