Californias SCP Californias SCP Implementation Update - - PowerPoint PPT Presentation
Californias SCP Californias SCP Implementation Update Implementation Update Bob Boughton Safer Consumer Products Branch Safer Consumer Products and Work Places Program California Department of Toxic Substances Control Safer Consumer
Bob Boughton Safer Consumer Products Branch
Safer Consumer Products and Work Places Program California Department of Toxic Substances Control Safer Consumer Products Summit September 18, 2013
http: / / www.ci.berkeley.ca.us/ ContentPrint.aspx?id= 11244
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DTSC
(Product‐Chemical Combinations)
Candidate Chemicals List Priority Products List Alternatives Selection Regulatory Responses
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DTSC
How I t W orks: The SCP Regulations
(Product‐Chemical Combinations)
Candidate Chemicals List Priority Products List Alternatives Selection Regulatory Responses
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species, impaired environments
product’s life cycle
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DTSC
How I t W orks: The SCP Regulations
(Product‐Chemical Combinations)
Candidate Chemicals List Priority Products List Alternatives Selection Regulatory Responses
Products…sold, offered for sale, supplied, distributed, or m anufactured in California.
who makes the product or who controls the manufacturing process or has the capacity to specify the chemicals in the product
who sell the product in California
containing Priority Product components
May opt-out by ceasing to order Priority Product
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Alternatives analysis is a scientific method for identifying, comparing and evaluating competing courses of action. In the case of chemical regulation, it is used to determine the relative safety and viability of potential substitutes for existing products or processes that use hazardous chemicals. Alternatives may include drop-in chemical substitutes, material substitutes, changes to manufacturing operations, and changes to component/product design. The methodology compares the alternatives to the regulated product and to one another across a variety of attributes, typically including public health impacts, environmental effects, technical performance and economic impacts on the manufacturer and the consumer. It can identify trade-offs between the alternatives and, if desired, generate an evaluation of the relative overall performance of the original product and its alternatives.
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I D Product Rqm ts
legal requirements
I D* Alternatives
Screening Alternative Chem icals
impacts
greater adverse impacts
Next Steps
AA report
AA Stage
* should ID chemical substitutions AND other alternatives.
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Step 1 – I D Relevant Com parison Factors
pathways & lifecycle phases
analysis
Step 2 – Com pare Priority Product & Alternatives
analysis
Step 3 – Alternatives Selection Decision
Report
justification for decision
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Rigorous AA evaluations scientifically assess the presence or release of harmful substances through production, use, and end-of- life phases, as well as account for impacts to a variety of media and endpoints. Identify burden shifting of an environmental impact from one stage in a product chain to another, from one hazard endpoint to another, from one impact category to another, between impacts and resource efficiency, between media or between countries or different times, etc. Making the data sources, assumptions made and decision-making methods transparent and well documented is fundamental to completion of a quality AA.
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The purpose of this document is to provide useful methods and tools to assist responsible entities in fulfilling the requirements of Alternatives Analysis. Overall, the intention is to equip users with the background they need to effectively integrate life cycle thinking and safer design into product development processes. Here, Life Cycle Thinking (LCT) takes into consideration all relevant environmental interactions associated with a product from a process chain perspective. This is in contrast to focusing only on site-level impacts (i.e., manufacturing facility environmental foot-print) or on single environmental impacts (such as carbon foot-print).
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DTSC
How I t W orks: The Safer Consumer Products Regulations
(Product‐Chemical Combinations)
Candidate Chemicals List Priority Products List Alternatives Selection Regulatory Responses
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California’s Safer Consumer Products regulation creates a predictable process for reducing toxic ingredients in consumer products. It requires manufacturers to ask, “Is this ingredient necessary? Is there a safer alternative? Is that alternative ingredient feasible?
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Bob Boughton Bob.boughton@dtsc.ca.gov ( 9 1 6 ) 3 2 3 -9 5 8 6
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