CSPA strongly believes that in addition to toxicologically impacts, environmental impacts, and other physical chemical characteristics; commercial viability and effectiveness must be considered when evaluating a “safer alternative”.
However, CSPA opposes any mandatory assessment of alternative chemicals for use in consumer products. CSPA’s members have organizations staffed with experienced experts who effectively assess chemical hazard, know exposure and can effectively assess the risk of chemical usage in consumer products. Years of training and experience are required in order to become well versed in consumer product safety assessment. CSPA’s member companies employ toxicologists that are highly qualified to make decisions about the appropriate use of chemicals in products. These professionals are masters and PhD-level scientists within our companies. CSPA’s members know what chemicals are safe under foreseeable conditions of product use and misuse. CSPA members are committed to providing products that are thoroughly evaluated for human and environmental safety and go through rigorous safety-based assessments before they are brought to market. It is both unnecessary and duplicative to mandate safer alternatives assessments for all products.
Additionally, CSPA is concerned about the creation of a requirement for third-party certifications of products or ingredients; as third-party certifications can be conflicting, incomplete, and a costly market barrier to smaller companies. CSPA believes that the incentives and recognition for innovation and use of safer alternatives and data sharing on “safer alternatives” remains the most effective tool to achieving the goal of safer consumer products.
The Soap and Detergent Association (SDA) urges the State of California to include criteria for alternatives assessment that are consistent with the following principles: • The assessment is based on sound science, and uses a hazard- and exposure-based safety assessment. • The assessment is based on the full life cycle of a product thereby ensuring that burdens are not shifted from one phase of the life cycle to another. • The benefits (performance) of alternatives are evaluated at all stages of the life cycle and considered as part of the assessment. • The affordability of alternatives is considered as part of the assessment. • Accurate and meaningful information (i.e., reliable, relevant and adequate information; see Question #8 above) are used as part of the assessment. • Environmental claims are measured against existing official guidelines. • Reportable indicators are evaluated across all relevant areas. • The alternatives assessment process should be open and allow for continued innovation and flexibility in product development.
SDA urges the State of California to avoid approaches to alternatives assessment that: • Use pass/fail criteria based on limited endpoints (e.g. ready biodegradation, acute toxicity cut-off levels); • Use hazard-based criteria only; • Use targets addressing limited or narrow endpoints (e.g. amount of nonbiodegradable per use); • Discriminate against specific ingredients, products and product categories based other than on sound scientific principles; or • Use claims of environmental attributes that are not based on sound science, or are not compliant with Federal Trade Commission or U.S. EPA guidelines.
In assessing alternatives, the life-cycle effects (risks, costs, performance, and benefits) of the substitute should be compared with those of the original chemical for specific applications.
GMA opposes any mandatory assessment of alternative chemicals for use in consumer products. GMA’s members employ experts (e.g., toxicologists) with many years of experience. These experts are highly qualified to make decisions about the appropriate use of chemicals in products. They can effectively assess the risk of chemical usage in consumer products taking into account the hazard and exposure information. Consumer products are thoroughly evaluated for human health and environmental safety and are subjected to rigorous safety-based assessments before they are brought to market.
- Again with the “safer” “greener”! It’s either hazardous or it’s not, right?
Seriously, if safer and greener are truly the goals, then California should be very flexible and allow companies to select from many criteria, including novel ones, such as: recycled content, recyclability, reduced energy use in production or use, reduced material use, reduced waste generation or emissions in production or use, reduced use of hazardous components (if such a concept has any meaning), increased biodegradability (if pertinent to how the product is disposed), net life cycle benefits based on partnerships in the supply chain, etc. Changes should be material, e.g., exceeding 10% improvement, and have documented substantiation.
California would not benefit from a prescriptive checklist that inhibits innovation. The state should offer financial and technical assistance and reference tools, then let companies decide how they will meet the growing market demand for greener solutions.
Environmental Working Group advocates establishing a health standard, and requiring that chemicals meet this standard before they’re allowed on the market. This standard will become a driver for innovation, as it creates incentives for industries to create and use greener chemicals, or take more novel approaches to product design and manufacture. It would assure that all chemicals used in California meet basic safety criteria, making public health the central concern of our state’s chemical policy.
A model for this paradigm is the highly successful Montreal Protocol, which very simply banned ozone depleting chemicals, and fostered incredible innovations in chemistry, energy efficiency, refrigeration, and other chemical and engineering processes. The Montreal Protocol did not require assessments of available alternatives, a process that would likely have delayed implementation of the ban. Instead, industry was free to use any means at its disposal to meet the new requirements to protect public health.
In contrast to this health-based approach, an alternatives assessment approach would delay bans of harmful chemicals, and create an unwanted assessment bureaucracy that would spend much of its time evaluating which green alternatives are the most green. We advocate using our limited resources towards eliminating true bad actor chemicals from commerce, rather than producing painstaking comparisons of greener chemicals. By establishing a health standard and allowing companies to take many paths to meet this standard, we unleash the creative potential of California’s market economy to support green chemistry and healthy people.
The state should develop a set of mandatory data requirements that will apply to all chemicals. The essential principle is that for a chemical to remain on or be placed on the market manufacturers and commercial users of chemicals must provide publicly available safety information about that chemical. The information must be sufficient to permit a reasonable evaluation of the safety of the chemical for human health and the environment, including hazard, use, and exposure information. In addition, the state must have the authority to request additional information it believes would be helpful in evaluating the hazardous properties of a chemical, and it should rely on any reliable information about that chemical that become available from any source.
This information should then be used in determining whether a manufacturer can demonstrate its products are reasonably safe. Moreover, the same body of data should be used in selecting safer alternatives.
Additionally, it is vital that when the state conduct an alternatives assessment, it considers particular uses of the chemical and determines if there are other non-chemical means to achieve the end produced by that chemical or product. A good example of this is using Integrated Pest Management. This approach seeks to minimize hazard by employing prevention-based strategies and prioritizing non-chemical approaches to pest management. A similar approach could be used when conducting an alternatives analysis. It would require the state to ask a series of questions about a chemical’s uses, available chemical and non-chemical alternatives and strategies to minimize hazard.
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CSPA strongly believes that in addition to toxicologically impacts, environmental impacts, and other physical chemical characteristics; commercial viability and effectiveness must be considered when evaluating a “safer alternative”.
However, CSPA opposes any mandatory assessment of alternative chemicals for use in consumer products. CSPA’s members have organizations staffed with experienced experts who effectively assess chemical hazard, know exposure and can effectively assess the risk of chemical usage in consumer products. Years of training and experience are required in order to become well versed in consumer product safety assessment. CSPA’s member companies employ toxicologists that are highly qualified to make decisions about the appropriate use of chemicals in products. These professionals are masters and PhD-level scientists within our companies. CSPA’s members know what chemicals are safe under foreseeable conditions of product use and misuse. CSPA members are committed to providing products that are thoroughly evaluated for human and environmental safety and go through rigorous safety-based assessments before they are brought to market. It is both unnecessary and duplicative to mandate safer alternatives assessments for all products.
Additionally, CSPA is concerned about the creation of a requirement for third-party certifications of products or ingredients; as third-party certifications can be conflicting, incomplete, and a costly market barrier to smaller companies. CSPA believes that the incentives and recognition for innovation and use of safer alternatives and data sharing on “safer alternatives” remains the most effective tool to achieving the goal of safer consumer products.
The Soap and Detergent Association (SDA) urges the State of California to include criteria for alternatives assessment that are consistent with the following principles:
• The assessment is based on sound science, and uses a hazard- and exposure-based safety assessment.
• The assessment is based on the full life cycle of a product thereby ensuring that burdens are not shifted from one phase of the life cycle to another.
• The benefits (performance) of alternatives are evaluated at all stages of the life cycle and considered as part of the assessment.
• The affordability of alternatives is considered as part of the assessment.
• Accurate and meaningful information (i.e., reliable, relevant and adequate information; see Question #8 above) are used as part of the assessment.
• Environmental claims are measured against existing official guidelines.
• Reportable indicators are evaluated across all relevant areas.
• The alternatives assessment process should be open and allow for continued innovation and flexibility in product development.
SDA urges the State of California to avoid approaches to alternatives assessment that:
• Use pass/fail criteria based on limited endpoints (e.g. ready biodegradation, acute toxicity cut-off levels);
• Use hazard-based criteria only;
• Use targets addressing limited or narrow endpoints (e.g. amount of nonbiodegradable per use);
• Discriminate against specific ingredients, products and product categories based other than on sound scientific principles; or
• Use claims of environmental attributes that are not based on sound science, or are not compliant with Federal Trade Commission or U.S. EPA guidelines.
In assessing alternatives, the life-cycle effects (risks, costs, performance, and benefits) of the substitute should be compared with those of the original chemical for specific applications.
GMA opposes any mandatory assessment of alternative chemicals for use in consumer products. GMA’s members employ experts (e.g., toxicologists) with many years of experience. These experts are highly qualified to make decisions about the appropriate use of chemicals in products. They can effectively assess the risk of chemical usage in consumer products taking into account the hazard and exposure information. Consumer products are thoroughly evaluated for human health and environmental safety and are subjected to rigorous safety-based assessments before they are brought to market.
- Again with the “safer” “greener”! It’s either hazardous or it’s not, right?
Seriously, if safer and greener are truly the goals, then California should be very flexible and allow companies to select from many criteria, including novel ones, such as: recycled content, recyclability, reduced energy use in production or use, reduced material use, reduced waste generation or emissions in production or use, reduced use of hazardous components (if such a concept has any meaning), increased biodegradability (if pertinent to how the product is disposed), net life cycle benefits based on partnerships in the supply chain, etc. Changes should be material, e.g., exceeding 10% improvement, and have documented substantiation.
California would not benefit from a prescriptive checklist that inhibits innovation. The state should offer financial and technical assistance and reference tools, then let companies decide how they will meet the growing market demand for greener solutions.
Environmental Working Group advocates establishing a health standard, and requiring that chemicals meet this standard before they’re allowed on the market. This standard will become a driver for innovation, as it creates incentives for industries to create and use greener chemicals, or take more novel approaches to product design and manufacture. It would assure that all chemicals used in California meet basic safety criteria, making public health the central concern of our state’s chemical policy.
A model for this paradigm is the highly successful Montreal Protocol, which very simply banned ozone depleting chemicals, and fostered incredible innovations in chemistry, energy efficiency, refrigeration, and other chemical and engineering processes. The Montreal Protocol did not require assessments of available alternatives, a process that would likely have delayed implementation of the ban. Instead, industry was free to use any means at its disposal to meet the new requirements to protect public health.
In contrast to this health-based approach, an alternatives assessment approach would delay bans of harmful chemicals, and create an unwanted assessment bureaucracy that would spend much of its time evaluating which green alternatives are the most green. We advocate using our limited resources towards eliminating true bad actor chemicals from commerce, rather than producing painstaking comparisons of greener chemicals. By establishing a health standard and allowing companies to take many paths to meet this standard, we unleash the creative potential of California’s market economy to support green chemistry and healthy people.
The state should develop a set of mandatory data requirements that will apply to all chemicals. The essential principle is that for a chemical to remain on or be placed on the market manufacturers and commercial users of chemicals must provide publicly available safety information about that chemical. The information must be sufficient to permit a reasonable evaluation of the safety of the chemical for human health and the environment, including hazard, use, and exposure information. In addition, the state must have the authority to request additional information it believes would be helpful in evaluating the hazardous properties of a chemical, and it should rely on any reliable information about that chemical that become available from any source.
This information should then be used in determining whether a manufacturer can demonstrate its products are reasonably safe. Moreover, the same body of data should be used in selecting safer alternatives.
Additionally, it is vital that when the state conduct an alternatives assessment, it considers particular uses of the chemical and determines if there are other non-chemical means to achieve the end produced by that chemical or product. A good example of this is using Integrated Pest Management. This approach seeks to minimize hazard by employing prevention-based strategies and prioritizing non-chemical approaches to pest management. A similar approach could be used when conducting an alternatives analysis.
It would require the state to ask a series of questions about a chemical’s uses, available chemical and non-chemical alternatives and strategies to minimize hazard.