Product Prioritization

Transcription

1 California Green Chemistry Product Prioritization Bill Greggs Grocery Manufacturers Association

2 Green Chemistry Act Prioritization of Chemicals of Concern and Products (a)...the department shall adopt regulations to establish a process to identify and prioritize those chemicals or chemical ingredients in consumer products that may be considered as being a chemical of concern the regulations adopted pursuant to this section shall establish an identification and prioritization process that includes...: (1) the volume of the chemical in commerce in this state (2) the potential for exposure to the chemical in a consumer product (3) potential effects on sensitive subpopulations, including infants and children. (Health and Safety Code section (a))

3 Product Prioritization Green Chemistry Alliance Perspective Science based process: DTSC scientists Priorities based on quantitative comparison of hazard and exposure information Address highest risks first make a real difference in improving public health and the environment Transparent approach assumptions visible; potential for comment to improve decisions

4 Identification of Priority Products Begin with Priority Chemicals of Concern (CoC) Two Steps Identify CoC product uses Evaluate those uses

5 Step 1: Identify CoC Product Uses Identify consumer product categories that use CoC Primary sources public information on chemical use Product manufacturer websites (ingredients, MSDSs) EPA Inventory Update Rule (2011 Chemical Data Rule) HPV/REACh submissions Trade association publications SRI Chemical Economic Handbook Caution on secondary sources! Often hearsay

6 Step 2: Evaluate CoC Product Uses Factors to consider for each product use Potential for exposure and adverse impact Human Health Concentration in product Route(s) of reasonable and foreseeable exposure Product use resulting in exposure to sensitive subpopulations Design features that limit accessibility, potential for exposure Protective equipment or other mitigation measures Quantitative comparison of hazard and expected human exposure Potential for exposure and adverse impact Environment Probable release volume and exposure to the environment Quantitative comparison of hazard and expected environmental exposure

7 Relative Ranking Framework Proposed Chemicals of Concern Health Environmental Each Proposed Chemical of Concern Product Uses Product Uses Relative Contribution to Exposure from each Product Category Relative Contribution to Release from each Product Category Ranking Health Ranking Environmental Proposed Priority Products that use a Chemical of Concern Decision

8 Practicality / Credibility Tested Methodology Canadian Chemical Management Priority Setting Lessons learned : Efficient in time and cost Transparent Utilizes publicly available information Can be refined with better information No safety factors or subjective weighting needed Disciplined, objective ranking

9 Summary of Recommendation Proposed process complies with requirements of the Statute and APA Science based, quantitative approach Leverages publicly available data Initial rankings are quantitative, conservative Address both human health and environment Can focus on sensitive sub population requirement Practical, meaningful, transparent, objective A substantive first step to Safer Alternatives

10 Draft Regulations

11 Product Prioritization DTSC Draft Regulations Initial Reactions Evaluation factors List of adverse impacts List of potential for exposure sources Key selection criteria: meet one or more of: CoC poses significant potential for adverse impacts Product widely distributed and used by consumers Significant potential for exposure in quantities that can result in adverse impact Assembled products: inhalation or dermal contact Formulated product intended to be: applied to body; dispersed as aerosol/vapor or applied to hard surfaces with likely runoff or volatilization Meet all 3; Hazard and Exposure; Quantitative evaluation

12 Product Prioritization DTSC Draft Regulations Initial Reactions De minimis GCA Recommendation Address highest risks first Target meaningful levels in product that pose real threat 0.1% based on numerous U.S and global regulations DTSC Flexibility to adjust lower or higher Draft Regulation 0.01% carcinogen, reproductive/developmental, persistent, bioaccumulative, endocrine, immunotox, neurotox 0.1% for other hazards DTSC flexibility to adjust lower/higher

13 Product Prioritization DTSC Draft Regulations Initial Reactions Intentional ingredients GCA Recommendation Focus on functional ingredients that are intentionally added Address most significant threats Where product redesign can drive improvement Manufacturers have direct capability to evaluate/address. Draft Regulation No indication that Product Prioritization will have this focus Alternative Assessment requires analysis of any chemicals of concern in the product. No mention of de minimis

14 DTSC Draft Regulations DTSC Goal Practical Meaningful Legally Enforceable