Mike Rogge

Green Chemistry alternatives assessment language unveiled

By Mike Rogge

Capitol Update, Oct. 2, 2015 Share this on FacebookTweet thisEmail this to a friend

On September 24th, the Department of Toxics Substances Control (DTSC) released their long awaited Draft Stage 1 Alternatives Analysis Guide (AA) for their Safer Consumer Products program (Green Chemistry). The Stage 2 AA is scheduled to be released in the first quarter of 2016.

The first stage involves an initial screening of alternatives with a preliminary analysis to identify the legal, functional, and performance requirements of the Priority Product and Chemical of Concern.

First Stage AA

Considerations

Step 1: Identify Product

Requirements & Function

of Chemicals of Concern

•    Identify functional, performance, and legal requirements

•    Identify the role of the Chemical of Concern

•    Determine the necessity of the Chemical of Concern

•    Evaluate removing the Chemical of Concern

Step 2: Identify Alternatives

•    Identify and consider alternatives

•    Research and evaluate information that identifies possibly

viable alternatives

Step 3: Identify Factors Relevant

for Comparing Alternatives

•     Identify material contribution to one or more adverse impacts

and a material difference in contribution to such impacts

between the Priority Product and alternatives

Step 4: Initial Evaluation and

Screening of Alternative

Replacement Chemicals

•    Compare Priority Product and alternatives by considering

relevant factors

•    Identify viable alternatives

•    May eliminate alternatives posing greater adverse impacts

than Chemical of Concern

Step 5: Consider Additional

Information

•      May consider other factors such as economic impacts,

performance

Step 6: Preliminary AA Report

•    Include AA Work Plan for second stage

•    See Appendix 1

Second Stage AA

Considerations

Step 1: Identify Factors Relevant

for Comparing

Alternatives

•     Re-evaluate relevant factors identified in first stage

•    Consider required relevant factors:

•    Product function and performance; useful life

•    Economic Impacts:

o Public health and environmental cost

o Cost to government agencies and non-profit

organizations

o Internal cost

Step 2: Compare the Priority

Product & Alternatives

•    Compare Priority Product with alternatives with respect to

relevant factors and associated exposure pathways, and life

cycle segments

•     Reiterate analysis as needed

Step 3: Consider Additional

Information

•    May consider other pertinent information

Step 4: Alternative Selection

Decision

•    Select alternative

•    Support with comparative analysis

Step 5: Final AA Report

•    See Appendix 1

 

 

The second stage is an in-depth analysis of the relevant factors, life cycle, and economic impacts.

If DTSC selects a chemical/product/combination that you manufacturer, you will likely find yourself involved with having to produce an AA This is the time to provide your input as to what you believe is reasonable or unreasonable. To date, DTSC has only named three chemical/product combinations for review, but another three to five chemical/products are expected to be named at anytime and the number and frequency reviewed is expected to increase significantly over the coming year.

DTSC will hold two webinars:

October 7, 2015 - 9 a.m. to 10:30 a.m. (PST)  

October 21, 2015 - 9 a.m. to 10:30 a.m. (PST)

Register here

CMTA will be asking for an extension of the public comment period. It will take a considerable amount of time to properly analyze this document and the implications. 

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