Prioritizing Chemicals of Concern in California California‘s Safer Consumer Product Regulations . Joanna Malaczynski, Founder. NAHMMA 2014 Northwest Hazardous Materials Conference. Overview & Today’s Agenda California’s Safer Consumer Product Regulations. Overview of regulations
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Prioritizing Chemicals of Concern in California California‘s Safer Consumer Product Regulations
Joanna Malaczynski, Founder
2014 Northwest Hazardous Materials Conference
Rinse and Repeat
Second Draft regulatory list (2016)
(180+ Days after)
& Grace Period
E.g. – chemicals known to cause cancer
EC Annex IV**
E.g. – chemicals found in
* Total is 248 individual & grouped chemicals
Hypothetical: an ingredient used in protective plastic–based coatings can potentially be found in components across product types and industries
Foam insulation for lap-top
Metal zippers with rust-proof coating
Synthetic canvas with waterproof treatment
Synthetic strings with fray-proof coating
Draft Regulatory Product-Chemical Combo #1: Chemical:Methylene Chloride Products: Paint & Varnish Strippers, Surface CleanersFunction: Solvent
Primary hazards: Carcinogen, body-systems toxin, air & water pollutant
Who is at risk: Workers, do-it-yourselfers, pregnant women, fetuses & infants, those at risk of heart attack
Exposure pathways: Inhalation and dermal contact; air and water exposure near source. Transformed in body to carbon monoxide.
Safer alternatives: Paint strippers using benzyl alcohol, sanding
Source: DTSC Fact Sheet
PAINT & VARNISH
Draft Regulatory Product-Chemical Combo #2:Chemical: TDCPP (aka Chlorinated Tris)Products: Children’s Foam-Padded Sleeping Products Function: Flame retardant for polyurethane foam
Primary hazards: Carcinogen, hormone disruptor, bio-accumulative
Who is at risk: Children, daycare workers, fish, wildlife
Exposure pathways: Released into air and dust found in our everyday environments; ingested via inhalation; skin absorption
Safer alternatives: bedding without polyurethane foam (e.g. cotton, wool, polyester)
Primary Source: DTSC Fact Sheet
Draft Regulatory Product-Chemical Combo #3:Chemical: UnreactedDiisocyanates (incl. MDI, HDI, TDI)Products:Spray Polyurethane Foam Systems for building insulation, weatherizing, roofingFunction: Polymer Building Block
Primary Hazards: Leading cause of occupational asthma, sensitizer, irritant
Who is at risk: Workers, do-it-yourselfers, residents
Exposure pathways: Inhalation or skin contact from spray/vapor upon application and from dust
Safer alternatives: Alternative insulation, caulking products (for sealing).
Main Source: DTSC Fact Sheet
Compliance Requirements for FinalizedPriority Product-Chemical Combinations
Substitute The chemical
Conduct Alternatives Analysis
Select Preferred Strategy
Eliminate the product
Submit Documentation to DTSC
Eliminate the chemical (w/out substitution)
Materials/ Life Cycle
Markets are responding to regulatory and consumer pressure.
e.g. May 9, 2014 Newsfeed: “Hybrid Coating Technologies Inc. is pleased to announce that it is entering the $35B insulation market. Hybrid is in the process of developing spray foam insulation based on its non isocyanate platform technology.” --GlobeNewswire
Many other agencies offering guidance, data and support.
e.g. EPA releases Draft Report (June 2014), “Flame Retardants Used in Flexible Polyurethane Foam - An Alternatives Assessment Update:”
Alternatives analyses are becoming more common in the marketplace.
Companies are increasingly looking for opportunities to work individually or collaboratively across the distribution chain to avoid regrettable substitutions by comprehensively analyzing alternative strategies for greening their products.
Joanna Malaczynski, JD / MLA-EP
Special thanks to Karl Palmer, Pollution Prevention Performance Manager, DTSC
CA Safer Consumer Products Web Portal: