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Joanna Malaczynski, Founder

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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Joanna Malaczynski, Founder

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  1. Prioritizing Chemicals of Concern in California California‘s Safer Consumer Product Regulations Joanna Malaczynski, Founder NAHMMA 2014 Northwest Hazardous Materials Conference

  2. 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

  3. 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)

  4. 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

  5. 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

  6. 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

  7. 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

  8. 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

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

  10. 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

  11. 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

  12. 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

  13. 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

  14. 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

  15. 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.

  16. Questions? Joanna Malaczynski, JD / MLA-EP joanna@ecovaluate.com 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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