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bruce381
07-31-2012, 11:35 AM
California “Green Chemistry” Regs Proposed

On July 27, 2012, the California Department of Toxic Substances Control (DTSC) proposed its “Safer Consumer Products Regulations” for a 45-day public comment period. The proposed regulations, which have undergone several iterations, are the latest step in the state’s “Green Chemistry Initiative.” ILMA is closely following the development of the proposed regulations as a member of the Green Chemistry Coalition in California.

DTSC describes its proposed regulations as a “preemptive strategy that reduces the use of toxic substances in the design of products and industrial processes with the aim of creating safer and sustainable products that do not threaten human health or persist in the environment.” The core elements of the proposed regulations are: Chemicals of Concern (COC), Priority Products (PP), Alternative Assessments (AA), and Regulatory Responses.

Of critical importance to most companies doing business in California, including ILMA members, is DTSC's plan to create a COC List within 30 days after the effective date of the regulations. Under the proposed regulations, the COC List would include those substances that exhibit a hazard trait or an environmental or toxicological endpoint.

DTSC originally indicated that its list would include approximately 3,000 COCs. DTSC now estimates that the COC List will include approximately 1,200 COCs. The Agency says the difference is largely based on the removal of chemicals covered by other regulations (e.g., pesticides) and other chemicals determined not to be in consumer products.

Under the proposed regulations, there is a process by which DTSC can identify additional chemicals as COCs after considering the potential chemical adverse impacts, potential exposures, availability of reliable information and availability of safer alternatives. Individuals also can petition to have chemicals added or deleted from the COC List.

The proposed regulations require DTSC to evaluate and prioritize products that contain COCs and then to develop a list of PPs for which AAs must be conducted. To determine products of high priority, DTSC will evaluate the potential adverse health and environmental impacts posed by the COCs in each product based on factors listed in the proposed regulations. Of interest to ILMA members, the proposed regulations no longer distinguish between “assembled” and “formulated” products. Further, DTSC defines "consumer product" to include, in part, “component” and “homogeneous material” to provide it “flexibility to name any identifiable constituent or part or a homogeneous layer of material in the finished product or that makes up the finished product as a Priority Product.”

DTSC previously indicated — and the proposed regulations state — that the initial PPs list would contain two to five products. However, DTSC and the proposed regulations include a requirement that DTSC develop, no later than January 1, 2014, a Priority Product Work Plan that “identifies and describes the product categories that the Department will evaluate to identify products to be added to the Priority Products list during the next three (3) years.”

The proposed regulations will require “responsible entities,” including manufacturers, importers, and retailers who sell products in California, to notify DTSC within 60 days of a PP's listing that its product is a PP or satisfies an exemption in the proposed regulations. The notification responsibilities for responsible entities are tiered, such that primary responsibility will lie with the manufacturer (the person that makes the product or the person who controls the specifications and design of, or use of materials in, the products), the importer will have responsibility if the manufacturer fails to comply, and retailers will be required to comply only if the manufacturer and importer (if any) fail to comply and such information is posted on a "Failure to Comply" list on DTSC's website.

Under the scheme summarized above, responsible entities — typically manufacturers — must perform an AA for the listed COC and PP to determine how best to limit potential exposures or the level of potential adverse public health and environmental impacts posed by the COC in the PP. Under the proposed regulations, AAs must be conducted in two stages.

Under the proposed regulations, once a Final AA Report is submitted and DTSC determines it is compliant, the Agency will specify a proposed due date for implementation of the regulatory response. DTSC will require implementation of regulatory responses “designed to protect public health and the environment, and maximize the use of alternatives of least concern, where such alternatives are technically and economically feasible.” The definition of "technically and economically feasible alternative" has been revised in the proposed regulations. No regulatory response is required if DTSC determines for the selected alternative, after review of the Final AA Report, that no regulatory response is necessary to prevent or limit adverse public health or environmental impacts.

Although recognizing that its proposed regulations will have an economic impact on companies doing business in California, DTSC says it “does not expect the regulations to result in cost increases, given the wide variety of comparable safer products readily available at competitive prices.” Ongoing concerns for ILMA are that California’s Green Chemistry Program becomes the template for a nationwide program administered by the Environmental Protection Agency and individual state requirements tailored from the California regulations.

Definiton for the reg of "consumer products"

HEALTH AND SAFETY CODE
SECTION 25251-25257.1

25251. For purposes of this article, the following definitions
shall apply:
(e) "Consumer product" means a product or part of the product that
is used, brought, or leased for use by a person for any purposes.


?? lead ??

Librarian
07-31-2012, 1:00 PM
See also http://www.dtsc.ca.gov/pollutionprevention/greenchemistryinitiative/index.cfm

... and I can't begin to guess the answer to 'will lead be included?'

jwkincal
07-31-2012, 1:06 PM
Well, I'd make book on someone TRYING to include lead... whether it makes the final list is a different question, but you can bet your kid's college fund on somebody making this about ammo.

P.S. Do NOT really bet your kid's college fund on anything.

hnoppenberger
07-31-2012, 1:18 PM
I'd say you can count on it.

Wiz-of-Awd
07-31-2012, 1:24 PM
See also http://www.dtsc.ca.gov/pollutionprevention/greenchemistryinitiative/index.cfm

... and I can't begin to guess the answer to 'will lead be included?'

Well, I'd make book on someone TRYING to include lead... whether it makes the final list is a different question, but you can bet your kid's college fund on somebody making this about ammo.

P.S. Do NOT really bet your kid's college fund on anything.

I'd say you can count on it.

We already have a "no lead" situation for waterfowl hunting...
That was just a stepping stone.

I think for sure we will see at lest an attempt for the rest of ammunition.

A.W.D.

VW*Mike
07-31-2012, 6:17 PM
Another reason to go to Vegas....

Paper Boy
08-01-2012, 7:42 AM
If they go after lead wont that also affect batteries? Including car batteries?

GOEX FFF
08-01-2012, 8:00 AM
I find it funny since lead is a natural metallic element in soil, rocks and other substances readily found in the natural environment that's been here for 4.5 billion years.

sharxbyte
08-01-2012, 8:02 AM
idiots don't realize that lead is naturally occurring...

Edit: beat me too it.. xD

Wiz-of-Awd
08-01-2012, 8:07 AM
idiots don't realize that lead is naturally occurring...

Edit: beat me too it.. xD

nevermind

A.W.D.

cdtx2001
08-01-2012, 8:30 AM
:willy_nilly::willy_nilly::willy_nilly:

bsim
08-01-2012, 5:00 PM
I find it funny since lead is a natural metallic element in soil, rocks and other substances readily found in the natural environment that's been here for 4.5 billion years.All we're doing is retuning it "home". :)