Fall Virtual Learning Conference Programs Expand Scope
To Feature Important Regulatory and Labeling Issues
Responding to requests for increased
guidance on regulatory and legislative
issues, the NPCA/FSCT will host a new
series of Virtual Learning Conferences
(VLC) this fall. On October 1, “
Chemical Management Policy: Impacts on
Coatings Formulations” will be offered
by Lynn Bergeson, Esq., and Lisa Campbell, Esq., of Begeson & Campbell, P.C.
NPCA/FSCT staff experts Steve Sides
and Stacey-Ann Taylor will follow on
October 8 with a course on “Basic Product Labeling: Make Sure Your Product
Meets All Legal and Regulatory Requirements.” Rounding out the offerings will
be a one-hour program on October 15
dedicated to “Technology-forcing Regulations: VOC and Air Toxic Controls on
Paint and Coatings Products.” Instructors for the program are Dave Darling
and Alison Keane, NPCA/FSCT.
Chemical Management Policy:
Impacts on Coatings Formulations
Paint and coatings manufacturers are
critically dependent on the availability
of raw materials to formulate products.
Innovation and the development of
new coatings products often is done in
close cooperation with raw material
suppliers, whose new chemical technologies must first pass through rigorous pre-manufacture regulatory
controls. In the U.S., both new and
existing chemicals used by the industry
are managed according to Toxic Substances Control Act (TSCA) regulations,
which have evolved over the last 30
years to become a workable regime recognized worldwide. However, recent
changes in chemicals management policy around the globe have increasingly
moved towards registration of formulating activities and authorization of “
use-based” controls that have the potential
to disrupt global commerce. As policy-makers in the U.S. grapple with modernizing TSCA, it is important for the
paint industry to understand the current
regulatory requirements governing manufacturing and processing (formulating)
chemicals, and to prepare for additional
regulatory responsibilities aimed at supporting critical uses.
This VLC will provide summary
details on current TSCA compliance
requirements for paint formulators,
explore stakeholder concerns about
chemical management policy and revi-
sions to TSCA, and identify various
international and state chemicals management initiatives that will have an
impact on coatings formulations. In
addition, critical international chemicals management concerns will be identified along with emerging chemical-specific legislative and regulatory proposals at the federal, state, and local
level in the U.S.
LEARNING OBJECTIVES:
• Understand the requirements of
the TSCA as they apply to chemical
manufacturers and the processors
(paint formulators)
• Learn what you need to do when
exporting a paint to another country if it contains a “chemical of
concern”
• Be able to understand when the
use of a chemical may pose “
substantial risk” to human health and
the environment
• Understand what a “Significant
New Use” rule requires a coatings
manufacturer to do
• Be able to deal with inventory
updates and other reporting
requirements
• When developing new polymers,
understand the scope of regulatory
exemptions that would not consider them a “new chemical”
• Advise your R&D team on available regulatory exemptions for new
product development
Basic Product Labeling: Make Sure
Your Product Meets All Legal and
Regulatory Requirements
Developing proper labels for paint
and coatings products requires a clear
understanding of the hazards that can
emerge from their use, or potential misuse, and ways in which they can be
avoided. Hazard and precautionary
labeling practices are strictly regulated
by OSHA under its Hazard Communication Standard (Industrial Products),
the Consumer Product Safety Commission (CPSC) under the Federal Hazardous Substances Act (Consumer
Products), and by the U.S. EPA for
products that make a pesticidal claim.
Each of these agencies has detailed
requirements that NPCA/FSCT has summarized in its Industry Labeling Guide.
Participants of this course will learn
about the proper approach to labeling a
formulated product, be able to undertake limited qualitative risk assessments
to determine “appropriate hazard warnings,” and make use of industry guidance in support of regulatory
compliance and effective product stewardship. In addition to current federal,
state, and local requirements, participants will also learn of U.S. efforts to
revise labeling regulations to reflect the
United Nation’s Globally Harmonized
System (GHS) for Labeling of Hazardous Chemicals.
LEARNING OBJECTIVES:
• Learn what is required for product
labels that conform to the OSHA
Hazard Communication Standards
(HCS)
• Understand the product safety consideration for consumer products
subject to the Federal Hazardous
Substances Act (FHSA)
• Know when formulating a paint
and coatings product requires your
company to pursue its registration
as a pesticide, and the critical role
product labels play in ensuring
safe use
• Be able to complete a labeling risk
assessment for your company’s
products
• Understand and conform to state
and local labeling requirements
• Be prepared for the coming
changes from the UN Globally
Harmonized System (GHS) for
Labeling of Chemicals
Technology-forcing Regulations:
VOC and Air Toxic Controls on
Paint and Coatings Products
The Federal Clean Air Act Amendments of 1990 resulted in a dramatic
expansion of EPA development and
enforcement of regulations that have
affected the formulation of paint and
coatings products. Limitations on VOCs
and use of HAPs in formulations continue to drive research and development
activities and shape product offerings.
In addition to federal requirements for
product content, various state and
regional requirements must be considered, along with related facility (manu-
