Prioritizing chemicals of concern in california california s safer consumer product regulations
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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

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 & Today’s AgendaCalifornia’s Safer Consumer Product Regulations

  • Overview of regulations

  • Selection of candidate chemicals (October 2013)

  • Where candidate chemicals are found

  • Draft regulatory list (March 2014)

  • Compliance requirements for first round (2015)

  • Concluding thoughts


Overview of california s safer product regulations

Overview of California’s Safer Product Regulations

  • Apply to those who put products into CA “stream of commerce;” manufacturers have primary responsibility.

  • Regulate product-chemical combinations.

  • First draft regulatory list will be finalized in 2015.

  • Require alternatives analysis to avoid regrettable substitutions.

Rinse and Repeat

Second Draft regulatory list (2016)

Draft regulatory

List Finalized

(2015)

Alternatives

Analyses Due

(180+ Days after)

First Draft

Regulatory List

(March 2014)

Public Comment

& Grace Period

(Now)

  • Statutory Authority - AB 1879 (2008) and SB 509 (2008); codified in 22 CCR 69501 et seq. (2013)


Regulatory lists used to select initial candidate chemicals

Regulatory Lists Used to Select Initial Candidate Chemicals

E.g. – chemicals known to cause cancer

Chemicals on

Regulatory

Hazards Lists

Example

List Sources

ATSDR

IARC**

CAN PBT**

CDC

EC Annex IV**

IRIS

CA OEHHA

CA EPA

WA PBTs

US EPA

NTP

Chemicals on

Regulatory

Exposure

Potential Lists

Initial

Candidate

Chemicals

List*

E.g. – chemicals found in

Bio-Monitoring studies

* Total is 248 individual & grouped chemicals

**International lists


Candidate chemicals are commonly used across product types and industries

Candidate Chemicals Are Commonly Used Across Product Types and Industries

Hypothetical: an ingredient used in protective plastic–based coatings can potentially be found in components across product types and industries

COUCHES

JACKETS

PLASTIC

COATINGS

DOLLS

PLASTIC PLATES

SHOES

LAMPS


Joanna malaczynski founder

A Given Product Can Have Multiple Components Each Product Component Can Have Separate Chemical Issues

Foam insulation for lap-top

Plastic Liner

Metal zippers with rust-proof coating

Synthetic canvas with waterproof treatment

Synthetic strings with fray-proof coating

Plastic clips

Image: FRUS


Prioritizing candidate chemicals for draft regulatory list based on exposure potential

Prioritizing Candidate Chemicals for Draft Regulatory List Based on Exposure Potential

  • Users, frequency of use, and type of use

  • Potential for exposure to the chemical from the product

  • Potential exposures to the chemical during the product’s life cycle

  • Volumes in products and commerce

Images: FRUS


Chemical exposure potential during the product life cycle

Chemical Exposure Potential During the Product Life Cycle

  • Manufacturing

  • Manufacturing Waste

  • Exposure to workers

  • Packaging

  • Exposure to Consumers

  • Exposure to workers

  • Storage &

  • Transportation

  • Risk of spills, combustion, etc.

  • Exposure to workers

  • Materials Extraction

  • Leeching into Air/soil/water

  • Exposure to workers

  • Use

  • Exposure to consumers, customers, workers

  • Disposal/Recycling

  • Leeching into Air/soil/water

  • Exposure to workers


Industries on regulatory radar overview of draft regulatory list 1

Industries on Regulatory Radar &Overview of Draft Regulatory List #1


Joanna malaczynski founder

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

STRIPPERS

TOXIC

SOLVENT

SURFACE CLEANERS


Joanna malaczynski founder

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

CHILDREN’S SLEEP

PRODUCTS

TOXIC FLAME

RETARDANT

POLYURETHANE

FOAM


Joanna malaczynski founder

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

SPRAY BUILDING

INSULATION

TOXIC

POLYMER

BUILDING

BLOCK

POLYURETHANE

FOAM


Joanna malaczynski founder

Compliance Requirements for FinalizedPriority Product-Chemical Combinations

Substitute The chemical

Conduct Alternatives Analysis

Select Preferred Strategy

Performance

Alternatives Analysis

Not Required:

Create Implementation

Work Plan

Hazards

Eliminate the product

Exposure potential

Submit Documentation to DTSC

Eliminate the chemical (w/out substitution)

Materials/ Life Cycle

Economics


Dtsc s carrots and sticks

DTSC’s Carrots and Sticks

  • Power to Influence the Market & Prohibit Sale

  • Power to Require R&D from Industry

  • Power to Request Information

    • New info may be basis for future

      regulatory action

  • Power to Restrict Product/Use

  • Power of Publication to Consumers


Joanna malaczynski founder

Parting Thoughts

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:”

http://www.epa.gov/dfe/pubs/projects/flameret/ffr-update-complete.pdf

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.


Questions

Questions?

Joanna Malaczynski, JD / MLA-EP

[email protected]

www.ecovaluate.com

Special thanks to Karl Palmer, Pollution Prevention Performance Manager, DTSC

CA Safer Consumer Products Web Portal:

http://www.dtsc.ca.gov/SCP/index.cfm


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