With a longstanding approach to advocacy that includes defining what the Association supports while also opposing legislation that would negatively impact its member companies, CSPA has a unique opportunity to proactively promote its positions to legislators, regulators, non-government organizations and other stakeholders. As such, the Association has built a strong reputation as a trusted, reliable and reasonable voice for industry.
CSPA’s advocacy team manages a multitude of issues of interest to all seven divisions of the Association with the goal in mind to preserve and promote the industry’s ability to be innovative in order to deliver sustainable and efficacious products to the marketplace and protect member company bottom lines.
Bringing Results To Members
CSPA has a long history of achieving results for its members. The Association worked to keep aerosol products viable in the marketplace in California and other states; celebrated the 60th anniversary of the Aerosol Products Division in 2009 with a video of U.S. Senators and Representatives congratulating the industry and commending companies for providing jobs to their constituents that contribute to roughly 3 billion aerosol products produced in the nation each year; worked with the California Air Resources Board (CARB) and other states on actions to protect member company products from onerous air quality regulations; led a coalition along with non-government organizations (NGOs) to work with Congress to support legislation that is now law and provides predictable timeframes for new and reduced-risk pesticides and antimicrobials to enter the marketplace while also stabilizing funding for the U.S. Environmental Protection Agency (EPA); worked with the Humane Society of the United to support legislation that passed in 15 states that requires companies that produce antifreeze to add a bittering agent to the product and that provides protections to the manufacturer; protected the air freshener industry while working with NGOs and EPA on ingredient transparency; protected members’ intellectual property from onerous legislation on ingredient disclosure while trying to find common ground with NGOs and EPA; established a voluntary pilot project on disclosure of inert ingredients in antimicrobial and pesticide products with EPA’s Office of Pesticides Program. These are only a few of the results the Association has delivered to its members.
Federal Legislative & Regulatory
The primary federal regulatory agencies with which CSPA works are the Consumer Product Safety Commission (Commission) and the EPA. Since passage of the Consumer Product Safety Improvement Act in 2008, which amended the Consumer Product Safety Act, CSPA has actively worked with the Commission on implementation of the subsequent regulations.
EPA is the authority of all products that are regulated under the Federal Insecticide, Fungicide and Rodenticide Act, which places extensive regulatory requirements on antimicrobial and pesticide products, such as 158W and registration requirements and fees under the Pesticide Registration Improvement Act . EPA also is the regulatory authority for the Toxic Substances Control Act of 1976, which impacts household and institutional products. CSPA has been heavily engaged in discussions surrounding TSCA modernization for a number of years and is specifically focusing on how the industry can help provide information to EPA on exposure and use. CSPA also is engaged in discussions about the prioritization of chemicals, development of a new safety standard and other relevant issue of interest to the household and institutional products industry.
At The State Level
On the state level, CSPA is well positioned with staff in Washington, DC and Sacramento, CA, along with a network of long-standing lobbyists in key states that are well connected and enjoy a rich history of success in managing the many issues impacting our members including ingredient communication, “green chemistry,” choice on “green cleaning” in schools, antifreeze laws also supported by the Humane Society of the U.S. and working to halt overly burdensome increases on companies pursuing registration of pesticide products, to name a few.
On the international level, CSPA is working with the Occupational Safety and Health Administration in developing the U.S. position before the United Nations Committee of Experts on a proposal on international transport flammability labeling for aerosol products. CSPA commented on and continues to work and monitor OSHA and other Federal agencies as relates to adoption and compliance with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The Association also keeps its members apprised of activity under other countries’ chemical regulations, particularly Europe’s ongoing implementation of REACH and Canada’s Chemical Management Program (CMP).