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ACA comments on California Air Resources Board's preliminary data summaries for aerosol and aerosol adhesive products.

ACA and its Spray Paint Manufacturers Committee submitted comments on October 24 to California's Air Resources Board (ARB) on its preliminary data summaries for aerosol coatings and aerosol adhesives. The preliminary data summaries are the reported results of the agency's data collection and analysis. These data points become the database upon which a Product Weighted Maximum Incremental Reactivity rulemaking is based and which ultimately result in stricter air quality standards for the regulated products.

ACA's comments were detailed and comprehensive for the vast array of categories for which ARB is collecting information, since it is critical that the preliminary data summaries are as accurate as possible in order to devise reasonable reactivity standards.

ARB is collecting data for both currently regulated products and categories not currently regulated by a reactivity standard in the aerosol coatings regulation. The reactivity standard limits emissions of the VOC in a product based on its likelihood of reacting to form ozone.

In its comments, ACA noted that the preliminary data summaries indicate that there are several categories which contain a small number of products or a small number of companies reporting. ACA underscored that providing emissions data and sales data for these small categories will breach confidentiality requirements in the California regulation, and urged ARB to "group" together such categories and release the emission and sales data as "miscellaneous regulated categories."

ACA and its Spray Paint Manufacturers Committee is preparing an Aerosol Coatings Technology Seminar to provide ARB staff with some additional insight into the aerosol delivery system and the formulation of coatings and adhesives products. The seminar will include modules on the can, the valve, propellants, and specific formulating challenges for adhesives and sealants as well as coatings.

Following submission of its comments, ACA was alerted by ARB staff that the board would require some time before they could respond to ACA's comments as well as those of others. ARB staff did, however, indicate that there was a consensus realization that January 1, 2014 (the effective date of new standards that is being imposed by the current State Implementation Plan) will come very quickly, and that both the rulemaking work, and the fact that manufacturers typically require 18 to 24 months to reformulate product lines, will make it likely that the effective date will "slip later into 2014."

Moreover, ARB staff also noted that because of the sheer number of product categories that are regulated by PWMIR standards and those additional product categories for which ARB collected data, the board would be willing to work towards a bifurcated schedule--where the focus on the largest categories would be set for 2012, and then after finalizing those standards, focus on the remaining categories, and establish a later effective date for those.

For more Information, contact ACA's Heidi McAuliffe (

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Title Annotation:ACA Issues In-Depth
Publication:JCT CoatingsTech
Date:Nov 1, 2011
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