ILMA Compoundings – December 2019 - 15
list, which was published in February 2019. "The fines can
be enormously expensive - $25,000 per day per violation,"
he said. "Either you find it as an individually listed CASS
number or that if you're using a mix that you have a letter
saying your supplier is assuring you that confidentially
withheld substance identity is on the active inventory."
During the ILMA's SHERA Committee meeting at the
Association's annual meeting, Ann Ball, product health
and safety manager, regulatory affairs, CIMCOOL,
recommended that ILMA members receive additional
documentation from suppliers. "We make every one of
our suppliers provide us a statement on letterhead that the
materials are on the active inventory," she said. "We don't
take the word of the SDS [safety data sheets]."
There are several state-specific issues that could affect ILMA
members. California's SB 258, which addresses cleaning products, begins taking effect in 2020. "On Jan. 1, 2020, online
disclosure requirements trigger. On Jan. 1, 2021, on-label
disclosure, and on Jan. 1, 2023, intentionally added Prop
65 ingredients must be added to the label," said Jeff Leiter,
ILMA's general counsel. "If you have products going into
California, you have to go through the process here."
SB 258 applies to manufacturers of designated products,
Leiter explained. According to the rule, a "manufacturer" is a
"person or entity who manufactures the designated product
and whose name appears on the product label" or a "person
or entity who the product is manufactured for or distributed
by, as identified on the product label pursuant to the federal
Fair Packaging and Labeling Act."
A "designated product" is a "finished product that is an air
care product, automotive product, general cleaning product,
or a polish or floor maintenance product used primarily for
janitorial, domestic, or institutional cleaning purposes."
The act specifically identifies 23 authoritative chemical
lists published in California. "The lists are not static," Leiter
said. "Subsequent revisions to these lists are incorporated
into SB 258."
Mike Ogburn, corporate program manager for August
Mack Environmental Inc., said the EPA is tightening air
regulations as part of its three-year initiative, which will
affect ILMA members. "Just recently, it was announced in
Chicago and some of the surrounding counties, they are
cutting in half the allowable emissions from companies and
certain type of permits," he said, adding that he expects to
see similar initiatives in major metropolitan areas, including
Los Angeles, New York, Houston and Dallas. "It is the
nonattainment zones. Instead of severe nonattainment, it is
critical nonattainment."
Ogburn said businesses have until October 2020 to file
new permits and paperwork. "That is going to be a huge
burden for industry," he said, adding that companies may
have to change products they're using if the VOC [volatile
organic compounds] content is too high or modify equipment with some type of pollution control device to make
sure VOCs are not getting out.
Manufacturers should watch for increased enforcement
within the U.S. "The EPA is becoming more aggressive and
more assertive with enforcement actions," Eggenschwiler
said. "They are looking for issues that they've become
increasingly aware of through the TSCA reset process."
That includes imported chemicals that are not eligible
because they're not on the TSCA inventory. "They may
not be active or may not be on it at all, and it has to do
with their suppliers not disclosing all of their ingredients to
them," Eggenschwiler said, adding that the EPA is inspecting broadly to look at those issues when performing a site
visit. "They're not bashful at levying the fines, especially if
they feel they need to get someone's attention."
"The EPA is becoming more
aggressive and more assertive
with enforcement actions."
James Eggenschwiler, ILMA consultant and
director of global trade, the Redstone Group
15
ILMA Compoundings – December 2019
Table of Contents for the Digital Edition of ILMA Compoundings – December 2019
LETTER FROM THE CEO
INSIDE ILMA
WHAT’S COMING UP
NEW MEMBERS
INDUSTRY RUNDOWN
In the Know
International Insight
Market Report
PEERING INTO THE FUTURE
BREEDING PERFORMANCE
IT’S IN THE DETAILS
BUSINESS HUB
COUNSEL COMPOUND
WASHINGTON LANDSCAPE
IN NETWORK
Member Connections
Cross Connections
PORTRAIT
ILMA Compoundings – December 2019 - Cover1
ILMA Compoundings – December 2019 - Cover2
ILMA Compoundings – December 2019 - 1
ILMA Compoundings – December 2019 - 2
ILMA Compoundings – December 2019 - LETTER FROM THE CEO
ILMA Compoundings – December 2019 - INSIDE ILMA
ILMA Compoundings – December 2019 - 5
ILMA Compoundings – December 2019 - WHAT’S COMING UP
ILMA Compoundings – December 2019 - NEW MEMBERS
ILMA Compoundings – December 2019 - INDUSTRY RUNDOWN
ILMA Compoundings – December 2019 - In the Know
ILMA Compoundings – December 2019 - International Insight
ILMA Compoundings – December 2019 - 11
ILMA Compoundings – December 2019 - Market Report
ILMA Compoundings – December 2019 - 13
ILMA Compoundings – December 2019 - PEERING INTO THE FUTURE
ILMA Compoundings – December 2019 - 15
ILMA Compoundings – December 2019 - 16
ILMA Compoundings – December 2019 - 17
ILMA Compoundings – December 2019 - BREEDING PERFORMANCE
ILMA Compoundings – December 2019 - 19
ILMA Compoundings – December 2019 - 20
ILMA Compoundings – December 2019 - 21
ILMA Compoundings – December 2019 - IT’S IN THE DETAILS
ILMA Compoundings – December 2019 - 23
ILMA Compoundings – December 2019 - 24
ILMA Compoundings – December 2019 - 25
ILMA Compoundings – December 2019 - BUSINESS HUB
ILMA Compoundings – December 2019 - 27
ILMA Compoundings – December 2019 - COUNSEL COMPOUND
ILMA Compoundings – December 2019 - 29
ILMA Compoundings – December 2019 - WASHINGTON LANDSCAPE
ILMA Compoundings – December 2019 - 31
ILMA Compoundings – December 2019 - Member Connections
ILMA Compoundings – December 2019 - 33
ILMA Compoundings – December 2019 - Cross Connections
ILMA Compoundings – December 2019 - 35
ILMA Compoundings – December 2019 - PORTRAIT
ILMA Compoundings – December 2019 - Cover3
ILMA Compoundings – December 2019 - Cover4
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