Formulator News December 15, 2016
Accessible by: anyone
This email is intended to update you on legislative and regulatory subjects of interest to formulator members of ISSA. In this issue, we cover the following:
1. EPA Clarifies Placement of Required First Aid Statements on Pesticide Product Labels
2. Comments Due on Green Seal Proposed Revisions to Cleaning Product Standards
3. New California VOC Limits and Restrictions Effective January 1, 2017
4. Revised New Hampshire VOC Limits Effective Jan. 1, 2017
5. Canada Finds Four Cleaning Chemicals Non-Toxic
EPA Clarifies Placement of Required First Aid Statements on Pesticide Product Labels
EPA has issued a memorandum that clarifies where first aid statements must be placed on pesticide product labels, including disinfectants and sanitizers. According to the recently released memo, first aid statements must be immediately visible on a pesticide product when the product is sold or distributed. I t should not require opening a booklet or other manipulation of the label to read the first aid statement.
According to EPA, for the most hazardous products (Toxicity Category I), the first aid statement must appear on the front panel unless the Agency has approved something different. Moreover, by front panel, EPA means on the outer cover of the label format regardless of the type of label (i.e., extended text, accordion, saddle stitched, pull-out, etc.) so that it is immediately visible on a shelf to a user or the consumer; and the label does NOT need to be opened to access the first aid information.
For Toxicity Categories II or III, the first aid statement can appear on the front, side or back panel, but again it must be visible without manipulation of the label (i.e., opening a booklet or unfolding an accordion style label).
If a registrant chooses to list first aid statements for Toxicity Category IV products, this language must also appear on a visible panel.
Because of the importance of first aid information, the Agency decided to make it clearer to registrants where first aid statements must appear on labels by issuing its most recent memo on the subject.
EPA has invited comments from all interested parties. Comments are due January 6, 2017.
Comments Due on Green Seal Proposed Revisions to Cleaning Product Standards
Reminder: Comments are due by Jan. 9, 2017 on Green Seal’s proposed revisions to its family of green cleaning product standards.
According to Green Seal, the purpose of the proposed revisions is to “improve the clarity, consistency, and readability of the standards.” In addition, Green Seal indicated that the proposed revisions are also intended to modify certain requirements where necessary so that they are practical to review during the certification process.
Affected Standards. The standards that are the subject of the proposed revisions include: GS-8 (Standard for Cleaning Products for Household Use), GS-34 (Standard for Cleaning and Degreasing Agents), GS-37 (Standard for Cleaning Products for Industrial and Institutional Use), GS-40 (Standard for Floor Care Products for Industrial and Institutional Use), GS-41 (Standard for Hand Cleaners for Industrial and Institutional Use), GS-48 (Standard for Laundry Care for Household Use), GS-51 (Standard for Laundry Care Products for Industrial and Institutional Use), GS-52 (Standard for Specialty Cleaning Products for Household Use), GS-53 (Standard for Specialty Cleaning Products for Industrial and Institutional Use).
Opportunity to Comment. ISSA members have two ways to weigh in and comment on the proposed revisions:
1. You can submit your comments directly to Green Seal, but first you will need to register. Individuals can register by clicking here. Note: Comments are due by Jan. 16, 2017; and/or
2. ISSA members can submit their comments on the proposed revisions to Bill Balek, ISSA, [email protected]. ISSA will assemble and file comments on behalf of the industry in regard to the proposed revisions to the Green Seal standards. Please submit your comments to ISSA no later than Jan. 9, 2017.
Proposed Revisions. Green Seal has posted detailed summaries of the proposed revisions to its family of green cleaning product standards online for your review and reference.
In addition, Green Seal will host a webinar on December 15, 2016 at 3:00 p.m. Eastern, that will provide an overview of the proposed revisions also. For more info on the Dec. 15 webinar, please click here.
New California VOC Limits and Restrictions Effective January 1, 2017
ISSA members are reminded that several new regulatory requirements become effective on Jan. 1, 2017 under the California VOC regulations. The regulatory changes are summarized below. Please contact Bill Balek, ISSA, [email protected] if you would like more information.
Global Warming Potential and VOC Limits
|
Product Category |
GWP Limit* |
VOC Limit (percent by weight)** |
Effective Date |
Sell-Thru Date |
|
Mist Spray Adhesive |
150 |
30 |
1/1/17 |
1/1/20 |
|
Web Spray Adhesive |
150 |
40 |
1/1/17 |
1/1/20 |
|
Screen Printing Adhesive |
150 |
55 |
1/1/17 |
1/1/20 |
* Global Warming Potential value or “GWP value” as specified in the Intergovernmental Panel on Climate Change’s (IPPC) Second Assessment Report (SAR). Use of any chemical compound that has a GWP value of 150 or greater is prohibited.
** The regulation contains exemptions for fragrances (in an amount of up to 2 percent by weight) and low vapor pressure VOCs. See sections 94510(c) and (d), respectively of the CARB Consumer Product Regulations.
Consumer Product Categories in Which Use of Methylene Chloride, Perchloroethylene, and Trichloroethylene is Prohibited
|
Product Category |
Effective Date |
Sell-Thru Date |
|
Screening Printing Adhesive (aerosol) |
1/1/17 |
1/1/20 |
|
Single Purpose Cleaner |
1/1/17 |
1/1/20 |
|
Single Purpose Degreaser |
1/1/17 |
1/1/20 |
The “sell-through” provisions in the California VOC regulations allow for the supply or sale of noncomplying products for up to three years if they were manufactured prior to the effective date. It is important to note, in order to qualify for the sell-through provisions:
- The products must be marked with the date of manufacture or an appropriate code date that has been filed with CARB; and
- The date or code date must be displayed on containers beginning at least 12 months prior to the effective date.
For a complete summary of all state and federal VOC limits, please visit www.issa.com/vocsum.
Revised New Hampshire VOC Limits Effective Jan. 1, 2017
Effective Jan. 1, 2017, the State of New Hampshire will be implementing new VOC limits for a variety of product categories as set forth below. Please note that New Hampshire regulations allow for the sell-through of affected products provided they were manufactured prior to the effective date and that the product containers display the date of manufacture or a code date indicating such. The new limits and product categories are set forth below.
New Hampshire VOC Limits Effective Jan. 1, 2017
|
Product Category |
VOC Limit (percent by weight) |
|
Dual Purpose Air Freshener/Disinfectant Aerosols |
60 |
|
Anti-Static Products (aerosol) |
80 |
|
Bathroom and Tile Cleaners (non-aerosol) |
1 |
|
Carburetor and Fuel Injection Air Intake Cleaners |
10 |
|
Disinfectant (aerosol) |
70 |
|
Disinfectant (non-aerosol) |
1 |
|
Engine Degreaser (aerosol) |
10 |
|
Floor Polishes/Waxes (for resilient flooring) |
1 |
|
Floor Polishes/Waxes (for non-resilient flooring) |
1 |
|
Furniture Maintenance Products (non-aerosol) |
3 |
|
General Purpose Cleaner (aerosol) |
8 |
|
General Purpose Degreaser (aerosol) |
10 |
|
Laundry Starch (Sizing/ Fabric Finish) Products |
4.5 |
|
Multi-Purpose Solvent |
3 |
|
Nail Polish Remover |
1 |
|
Oven Cleaner (non-aerosols including pump sprays) |
4 |
|
Paint Thinner |
3 |
|
Sanitizers (aerosol) |
70 |
|
Sanitizers (non-aerosol) |
1 |
For a complete summary of all state and federal VOC limits, please visit www.issa.com/vocsum.
Canada Finds Four Cleaning Chemicals Non-Toxic
Canada proposes finding four chemicals used in cleaning products as non-toxic but will continue to track exposure to them to ensure they don’t pose a future risk to the environment.
A draft screening assessment of the substances—triethanolamine lauryl sulfate, sodium lauryl sulfate, ammonium lauryl sulfate and sodium C14-16 olefin sulfonate—concluded that they meet no toxicity criteria under the Canadian Environmental Protection Act, the government said Dec. 10.
They currently pose a low risk to the environment and human health, but would raise concerns for potential ecological effects if their use significantly increased so follow-up activities are being considered to track increases in commercial uses, it said.
The substances are used in laundry and dishwashing products and consumer products including shampoos, toothpastes, soaps, cosmetics and bubble bath products, and sodium lauryl sulfate is used in food packaging and as a food additive. Both are manufactured in Canada and imported in significant quantities.
The draft assessment is open to comment through Feb. 8, 2017 and a final version is expected to be published in December 2017.
