20 Jan 2017
California Issues Guide to Assist Manufacturers Identify Safer Alternatives for Hazardous Ingredients in Consumer Products
The California Department of Toxic Substances Control has released a draft alternatives analysis guide under the Safer Consumer Products programme that the agency hopes will assist manufacturers identify safer alternatives for hazardous ingredients in consumer products. According to DTSC, the guide represents an important step in the implementation of California’s pioneering Safer Consumer Products regulations, and many of the concepts in the guide provide solutions and ideas for resolving specific difficulties and choices encountered when conducting an alternatives analysis process.
The guide provides guidelines on each component of the alternatives analysis process, providing useful approaches, methods, resources, tools and examples of how to fulfil the regulatory requirements under the Safer Consumer Products regulations. General topics addressed by the guide include the alternatives analysis framework, product requirements and alternatives, impact assessments, screening of alternatives, exposure, life cycle impacts, economic impacts, informational needs in alternatives analysis, selection of alternatives, self-evaluation of alternatives analysis and resources.
The Safer Consumer Products regulations require responsible entities (manufacturers, importers, assemblers and retailers) to notify DTSC when their product is listed as a priority product, and DTSC will post that information on its Web site. Manufacturers or other responsible entities of products listed as priority products will be required to perform an alternatives analysis for the product and the chemicals of concern in that product to determine how best to limit exposures or the level of adverse public health and environmental impacts posed by the chemicals of concern. DTSC will also have to identify and require implementation of regulatory responses to protect public health and/or the environment and maximise the use of acceptable and feasible alternatives of least concern.
DTSC has the authority to require regulatory responses for a priority product (if the manufacturer decides to retain the priority product) or for an alternative product selected to replace the priority product. This may include ordering the removal or replacement of the chemical of concern in the product or the removal of the product from the California marketplace. DTSC is currently considering priority product designations for: (1) children’s foam-padded sleeping products containing tris(1,3-dichloro-2-propyl) phosphate (TDCPP) or tris(2-chloroethyl) phosphate (TCEP); (2) paint and varnish strippers and surface cleaners containing methylene chloride; and (3) spray polyurethane foam systems containing unreacted methylene diphenyl diicocyanates. Comments on a revised proposal to list as a priority product children’s foam-padded sleeping products containing TDCPP or TCEP were due by 12 January.