The concept of a toxic tax may be a politically attractive approach to regulation. It is not easy to administer well. Recall the difficulties with SB950 when CA had to address the issue of regulating a known human teratogen, ethanol, on the basis of hazard-only data. The politically unacceptable consequences of a ban are obvious. Similar issues surround Boron [borax], and equally perplexing administrative difficulties for "toxic" chemicals may surround gasoline, diesel fuel, household bleach, etc. My suggestion to CA is that a "toxic tax" should be collected in the form of exposure data. If a chemical meets a set of criteria deemed intrisically hazardous, then the manufacturers and all down-stream users must provide a defined dataset to include full chain-of-commmerce and end-use, cradle-to-grave, exposure analysis for humans and the environment. Sales volume in the state is initially capped until the data are received, and the volume cap declines with time until the exposure data are delivered. A risk assessment will subsequently determine the magnitude of the potential for harm. These are my own opinions and not necessarily those of my employer.
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The concept of a toxic tax may be a politically attractive approach to regulation. It is not easy to administer well. Recall the difficulties with SB950 when CA had to address the issue of regulating a known human teratogen, ethanol, on the basis of hazard-only data. The politically unacceptable consequences of a ban are obvious. Similar issues surround Boron [borax], and equally perplexing administrative difficulties for "toxic" chemicals may surround gasoline, diesel fuel, household bleach, etc. My suggestion to CA is that a "toxic tax" should be collected in the form of exposure data. If a chemical meets a set of criteria deemed intrisically hazardous, then the manufacturers and all down-stream users must provide a defined dataset to include full chain-of-commmerce and end-use, cradle-to-grave, exposure analysis for humans and the environment. Sales volume in the state is initially capped until the data are received, and the volume cap declines with time until the exposure data are delivered. A risk assessment will subsequently determine the magnitude of the potential for harm. These are my own opinions and not necessarily those of my employer.