California s Safer Consumer Products Regulations

Transcription

1 California s Safer Consumer Products Regulations 6 Classes Toxics Reduction Retreat IV May 2, 2016 Meredith Williams, Deputy Director Safer Products and Workplaces Department of Toxic Substances Control Cal/EPA

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3 Safer Consumer Products Framework List of lists approach Product-Chemical combinations that may cause harm Manufacturer evaluation of alternatives DTSC considers range of possible responses 3

4 ~2,000 chemicals Online searchable database 23 Authoritative Bodies Updated Quarterly Exclusions FIFRA pesticides Prescription drugs Radioactive Chemicals Natural toxins Breakdown products

5 Potential exposure to the Candidate Chemicals in the product AND Chemicals are considered in the product context Potential for exposures to contribute to or cause significant or widespread adverse impacts

6 What is a consumer product? Anything except Prescription drugs or devices Dental restorative materials Food Medical packaging A pesticide under FIFRA Commercial products included 6

7 First three Priority Products Children s Foam-Padded Sleeping Products containing TDCPP/TCEP Paint Strippers containing Methylene Chloride Spray Polyurethane Foam Systems with MDI 7

8 Answers key questions Key Concepts Manufacturer evaluation Narrative standard Public comment Is it necessary? Is there a safer alternative? Have regrettable substitutes been avoided? Consider the full product life cycle CBI protections Life Cycle Thinking Transparent Evaluation Class concept critical for evaluation of alternatives

9 Alternatives Analysis What are the trade offs? What information is available? What are the data gaps? What are the life cycle implications What will meet the performance criteria? Does this alternative have a downside? 9

10 No response Additional info to DTSC Additional info to consumers Additional safety measures Sales restrictions/prohibitions End-of-life product stewardship Research funding

11 Working faster Classes accelerate the decision making process Priority Product selection Hazard endpoint analysis Screening for safer alternatives Sentinel chemicals as indicators Classes can be based on structure or on function 11

12 US EPA chemical reviews 56 Categories Hazard groupings Recommended toxicity tests 12

13 Regulatory uses of classes EPA Flame Retardant clusters risk assessments Based on structural similarities Brominated Phthalates Cluster (TBB/TBPH)- DNA Brominated Bisphenol A Cluster (TBBPA)- PF Chlorinated Phosphate Esters Cluster (TCEP)- PF Cyclic Aliphatic Bromides Cluster (HBCD)- PF Biomonitoring CA Parabens Phthalates Pyrethroid pesticides PCBs Per- and polyfluoroalkyl substances PFASs (>2,000) 13

14 Priority Product Work Plan Categories Beauty, Personal Care and Hygiene Products Household/Office Furniture/ Furnishings Cleaning Products Building Products Paint Products, Adhesives, Sealants, Flooring Fishing and Angling Equipment Clothing Office Machinery Consumable Products 14

15 Chemical Groupings in the Priority Product Work Plan Both structural and functional groupings Class concept facilitates stakeholder discussions and outreach to experts Class/group Product Categories Flame Furniture/furnishings retardants Building products Clothing Antimicrobials Furniture/furnishings Clothing Cleaning Personal care products Building products PFAS Furniture/furnishings Building products Clothing Personal care products Azo and benzidine dyes Fragrances Furniture/furnishings Building products Clothing Cleaning 15 Personal care products

16 Big problems need big solutions 16

17 Ask me about Petition process Sensitive Subpopulations Comments on rulemaking 17

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19 Chemical groupings based on structure Benefits Shared structural features may be related to a hazard trait Allows DTSC to learn at a more general level early Anticipate regrettable substitutes Helps practitioners address data gaps - Read-across techniques - Trend analyses - QSAR models Challenges Extrapolating hazard traits has pitfalls All group members are not necessarily on CA Candidate Chemicals List 19

20 Functional approach helps focus on the Why??? Why antimicrobials? Why PFASs? Chemical availability? Customer demand? Product differentiation? Cost? Perception or reality? Dig into the specific basis for the requirement 20

21 Chemical groupings based on function Benefits Encourages investigation beyond structurally similar substitutes Potential to avoid regrettable substitutions Challenges Multi function chemicals Too broad brush 21

22 Thank you 22