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CARB to survey architectural and industrial maintenance coatings, consumer and commercial products, and aerosol coatings.

California's Air Resources Board (CARB) is undertaking its largest product survey initiative to date. In 2014, CARB will conduct a survey of architectural and industrial maintenance (AIM) coatings, consumer and commercial products, and aerosol coatings sold in or supplied to California. The surveys will require manufacturers' and suppliers' participation in a multi-year data collection, whereby sales and product ingredient data, including information on volatile organic compound (VOC) content, will be required. CARB will use the information provided through these surveys to update the state's inventory of emissions of VOCs and low-vapor-pressure VOCs (LVP-VOCs), after which it will determine the feasibility of further reducing VOC emissions. The survey is part of CARB's effort to control ozone pollution by limiting VOC emissions, and CARB stated that such data is necessary to establish the scientific basis for the clean air plans and related rulemakings to address the stricter national standards for ozone and fine particulates.

The seven product categories subject to the survey include (1) adhesives, sealants and related products; (2) household and institutional products; (3) personal care products; (4) pesticide products; (5) solvents and thinning-related products: (6) vehicle and marine vessel aftermarket products: and (7) aerosol coating products.

Companies will have until March 1, 2015, to submit sales data and detailed formulation data for products used by households or institutional consumers sold in or supplied to California during 2013. Sales data also must be reported in 2014 and 2015, but only for formulations with VOC contents that have a weight change greater than 0.5%. According to CARB, similar products may be grouped for reporting as long as the variation in VOC composition is less than 0.5% by weight and variance of non-VOC ingredients is less than 1%. Different sizes of products also may be grouped as long as the formulas are the same. Also, products that vary by color and botanical extract may be combined if their ingredient composition varies by no more than 1%.

Due to ACA's efforts, companies supplying and selling aerosol coatings and aerosol adhesive products only need to report sales data for 2013. ACA was successful in convincing CARB to delay further survey for this category of products until 2017.

The aerosol coatings and consumer and commercial products survey is scheduled to be released on September 1, 2015, and manufacturers of aerosol coatings and consumer and commercial products will be able to start uploading data on January 1, 2015. All 2013 data is due to CARB by March 1, 2015; all 2014 consumer products data is clue on November 1, 2015; and all 2015 data is due on November 1, 2016.

CARB is still working on the details associated with the AIM coatings survey, although it is tentatively scheduled to release the AIM coatings survey on October 15, 2014. Manufacturers can start uploading data on January 1, 2015, and all 2013 data is due by March 1, 2015.

At an August 27 stakeholder meeting hosted by CARB to discuss survey details, ACA and other members of industry raised several concerns. First, ACA stated that the March 1, 2015 due date is problematic given that many companies will be completing all three surveys--AIM, Consumer Products, and Aerosol Coatings--and that there are several other major regulatory reporting requirements due in the March timeframe, including, but not limited, to labeling changes as result of OSHA's adoption of the Globally Harmonized System of Classification and Labelling of Chemicals. Chemical manufacturers, distributors, and employers are required to reclassify chemicals using adopted GHS criteria and to update labels and safety data sheets by June 1, 2015. As such, that same group required to complete CARB's survey will be in the midst of revising material safety data sheets to comply with the GHS. Additionally, California's South Coast Air Quality Management District Rule 314 (AIM Fees) annual quality and emissions reports will be ongoing at the same time.

ACA also opposed the proposed survey requirement to submit all product labels, since product labels are constantly changing. Given the GHS relabeling effort. ACA maintained that the CARB reporting requirements are too burdensome, for very little benefit.

Contact ACA's Heidi McAuliffe ( for more information related to aerosol coatings, and consumer and commercial products. Contact ACA's David Darling ( or Tim Serie ( for more information related to AIM coatings.
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Comment:CARB to survey architectural and industrial maintenance coatings, consumer and commercial products, and aerosol coatings.
Publication:JCT CoatingsTech
Geographic Code:1U9CA
Date:Oct 1, 2014
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