The Issues

Facing Our Industry

CSPA’s advocacy team serves as a business partner to the representatives of the formulated products industry, non-governmental organizations, and federal, state and international regulators and legislators. CSPA’s expertise spans a wide array of industry issues including the following listed below.

Air Quality Issues

Improving Air Quality
CSPA member companies take seriously the environmental health and safety benefits of our products, and continuously seek to improve them. Therefore, CSPA member companies commit to expend the time and money to develop the new technologies necessary to reformulate their products to meet the regulatory requirements that limit the emission of volatile organic compounds (VOCs) while still maintaining the efficacy of their products.

Maintaining Critical Compliance Mechanisms in California Consumer Products Regulation

In June 2012, the California South Coast Air Quality Management District (SCAQMD) initiated development of a 2012 Air Quality Management Plan (AQMP) for the District which eventually became part of the overall California State Implementation Plan (SIP) developed by the California Air Resources Board (CARB) and submitted to the U.S. Environmental Protection Agency (EPA).

Automotive Issues

Making Antifreeze and Engine Coolant Unpalatable to Humans and Animals
In 2012, CSPA was awarded the Humane Society of the United States’ top award for the protection of pets in recognition of CSPA efforts to address concerns about accidental ingestion of antifreeze by pets. CSPA worked in tandem with the Humane Society of the United States to develop model state legislation that requires engine coolant and antifreeze to contain a bittering agent so as to render it unpalatable to humans and animals. The Association has been active in the successful passage of such legislation in several states.

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Clarifying Aerosol Product Issues

The Download on Aerosol Products
Aerosol products are found throughout the retail environment, from the household cleaning aisle to personal care, hardware and the grocery section. This unique packaging form allows products to be dispensed in foams and fine sprays and allows manufacturers to create innovative products and packaging. Clearly there are many benefits to this packaging form, but there is also much confusion.

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Consumer Education Issues

Supporting Education Efforts to Prevent Inhalant Abuse and the Intentional Misuse of Consumer Products
Inhalation abuse is the intentional misuse of certain consumer products.  Practical experience has demonstrated education is our best weapon to combat this problem.  Everyone should understand the dangers of inhalation abuse and why legitimate products should not be abused.
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Ingredient Disclosure Issues

Sharing With Consumers Information About Ingredients in our Products

Over the past 25 years, several states have enacted statutes requiring business to provide health, safety and environmental information to government and the public.  These measures, sometimes referred to as “right-to-know”, include labeling, emergency response preparation, chemical or toxics use data, and other types of environmental, health and safety performance information.

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Lawn & Horticultural Issues

Lawn and Horticultural Products Implementation and Administration of Science-based Laws and Regulations
The Lawn and Horticultural Products Work Group (LHPWG) formed on October 1, 2012 to promote the implementation and administration of science-based laws and regulations affecting the sale, distribution and use of lawn and horticultural products in a manner that advocates environmental stewardship while preserving the ability of member companies engaged in this industry to operate efficiently, effectively, and productively.

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Pesticide Registration Issues

Ensuring the U.S. EPA’s Pesticide Registration Program is Properly Funded and Implemented

The Pesticide Registration Improvement Act (PRIA) provides the U.S. Environmental Protection Agency (EPA) with resources to more fully and expeditiously evaluate pesticides and their risks based upon sound science. President Obama signed the PRIA III legislation on September, 29, 2012.  A compilation and breakout of the registration actions and successful implementation are reported by EPA in their annual report.

Requiring Limited Data Submissions to Register FIFRA (25b) Minimum-Risk Pesticides
The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and its implementing regulations exempt from registration and data submission requirements a limited group of pesticides that are known as “minimum-risk” pesticides or FIFRA §25(b) products.  These products contain one or more minimum risk active ingredient, such as castor oil, and can only contain inert ingredients specified by the U.S. Environmental Protection Agency.

Defeating Unreasonable Increases in State Pesticide Registration Fees

Consumer protection and health benefit products include disinfectants, sanitizers, germicides, antibacterial products, and insect and rodent control products. Consumers use these products to protect themselves, their children and their residential premises. Institutions such as hospitals, schools, restaurants, hotels and others use these products to protect public health. Under federal and state law, consumer protection and health benefit products are defined, registered and regulated as pesticides.

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Supporting Reasonable Integrated Pest Management (IPM) in Schools and Other Public Facilities

The term “integrated pest management” (IPM) refers to broadly defined pest management measures intended to effectively manage pest populations to acceptable levels, while reducing or minimizing the use of pesticide products. These measures include: using non-chemical controls, redesigning and repairing structures, improving sanitation, employing pest resistant plant varieties, altering watering and mowing practices in landscapes and applying pesticides judiciously.

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Regulatory Compliance Issues

Modernizing the Toxic Substances Control Act of 1976

CSPA is committed to engaging with all stakeholders to provide input on legislation that will direct how chemicals in commerce are regulated under the Toxic Substances Control Act 1976 (TSCA). CSPA member companies believe that TSCA should be updated to recognize the changes in science and technology during the past four decades.

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Supporting  the Responsible and Appropriate Use of Biomonitoring

CSPA supports the responsible and appropriate use of biomonitoring information in risk assessment in creating public policy. Biomonitoring is the measurement of human exposure to specific substances through an analysis of human bodily tissues or fluids. Human bodies absorb trace amounts of many substances from the surrounding environment. Increasingly advanced technology allows researchers to identify and measure their concentrations of these substances and metabolites in the body.

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Helping to Expedite U.S. Regulatory Agency Compliance with GHS

The United Nations (U.N.) developed a new system of classifying chemicals, known as the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) in response to extensive global trade in chemicals and the need to develop national programs to facilitate their safe use, transport, and disposal. The starting point of the U.N.’s approach was its belief that unifying existing systems would help in the development of a single, globally harmonized system for classifying chemicals, labels, and safety data sheets.

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Ensuring Uniformity in Packaging Standards and Disposal/Recyclability

Consumer and industrial products often require special packaging to provide for adequate package integrity in transport and sale and efficient and safe use by consumers and workers. Thus, CSPA members have both an economic and a practical interest in selecting the type of packaging that best matches consumers’ needs and the characteristics of the product. Many CSPA members also incorporate environmental policy objectives, including use of recycled content in their packaging and utilizing packaging materials that may easily be recycled in existing curbside collection programs, where practical and permissible.

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Expanding Visibility of the U.S. EPA’s Safer Choice Program (formerly the Design for the Environment Program)

The U.S. Environmental Protection Agency’s (EPA) Safer Choice Program, part of EPA’s Office of Pollution Prevention and Toxics, is uniquely situated to play a significant role in bringing consistency and transparency to claims that products are environmentally preferable.

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