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SPF coalition comments.




CBIA - SPF coalition comments







Yes, I support adding spray polyurethane foam systems containing unreacted methylene diphenyl
diisocyanates to the Priority Products list so that there can be stricter regulations around using this type of product.
These chemicals are known to be toxic to people and the environment.










Please refer to attachment.




ACC Request for CEQA NOE







Please see attachment.




GCMC Comment about citation







GCMC and Armstrong Roofing are petitioning DTSC to reconsider listing spray polyurethane foam with unreacted MDI as a Priority Product. The report states that SCP does not provide adequate documentation in support of listing SPF as required in the SCP regulations. The specific focus of the 2015 report is the use of SPF as a roofing material, which is described in detail, and questions about the types of products excluded from the definition of the Priority Product. There are also recommendati
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GCMC and Armstrong Roofing Commentary on Proposed Listing of SPF with unreacted MDI







Please refer to attached document requesting comment period extension.




Accella Request to Extend Comment Period







Please refer to attached document requesting extension of comment period.




General Coatings Request for Extension







Please refer to attached document requesting extension of comment period, which was submitted by Michelle Koenig on behalf of Steve Burns.




Huntsman Request for Extension







Please refer to attached document.




Covestro request for SPF comment period extension







Please refer to attached document.




Request to extend comment period







Please refer to attached document.




Request to extend comment period.







Please refer to attached document.




Request to extend comment period.







Please refer to attached document.




Request to extend comment period.







Please refer to attached document.




Request to extend comment period.







Please refer to attached document requesting extension of comment period.




Request to extend comment period







Please refer to attached document requesting comment period extension.




Request to extend comment period.







Please refer to attached document requesting extension of comment period.




Request to extend comment period







Please refer to attached document requesting extension of SPF rulemaking comment period.




Request to extend comment period







Please refer to attached document requesting extension to SPF rulemaking comment period.




Request to extend comment period







- 1) Chemicals in nail products – chemical presence, functional use, hazard traits, endpoints, and exposure information


Uploaded document.




DTSC-CaHNSC nail product comments







- Theme 1. Nonylphenol ethoxylates in cleaning and clothing products
- Theme 2. Triclosan product uses, removal, and substitution
- Theme 3. Aquatic hazards and the detection of NPE, triclosan methyl triclosan, and other transformation products that can impact the aquatic environment or resources
- Theme 4. Other Candidate Chemicals or Products that may impact the aquatic environment or resources


Please see attached comments.




AAFA Comments Regarding the Continued Use of Nonylphenol Ethoxylates in Clothing Products







- Theme 1. Nonylphenol ethoxylates in cleaning and clothing products
- Theme 2. Triclosan product uses, removal, and substitution
- Theme 3. Aquatic hazards and the detection of NPE, triclosan methyl triclosan, and other transformation products that can impact the aquatic environment or resources
- Theme 4. Other Candidate Chemicals or Products that may impact the aquatic environment or resources


Please see attached comments.




APERC Comments DTSC - Work Plan Implementation: Aquatic Impacts







- Theme 1. Nonylphenol ethoxylates in cleaning and clothing products
- Theme 2. Triclosan product uses, removal, and substitution
- Theme 3. Aquatic hazards and the detection of NPE, triclosan methyl triclosan, and other transformation products that can impact the aquatic environment or resources
- Theme 4. Other Candidate Chemicals or Products that may impact the aquatic environment or resources


February 28, 2017

Karl Palmer, Chief
Safer Consumer Products Branch
Department of Toxic Substances Control
P.O. Box 806, Sacramento, CA 95812

Re: Priority Products Work Plan Implementation: Potential Aquatic Impacts and Continued Uses of Nonylphenol Ethoxylates and Triclosan.

Dear Mr. Palmer:

These comments are submitted on behalf of the Environmental Working Group, a nonprofit public health research and advocacy organization based in Washington, D.C., with offices in San Francisco and
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EWG Comments Re. Aquatic Impacts, NPEs and Triclosan







- 1) Chemicals in nail products – chemical presence, functional use, hazard traits, endpoints, and exposure information
- 2) Product formulations and manufacturing information


The Washington State Department of Ecology (Ecology) is providing available nail products data. The information in this letter summarizes nail products data from the following Ecology databases:
• WA Children’s Safe Products Act (CSPA) Manufacturer Reporting Database https://fortress.wa.gov/ecy/cspareporting/
• WA Product Testing Database - https://fortress.wa.gov/ecy/ptdbpublicreporting/

Excel spreadsheets were sent separately. Each of the spreadsheets includes the downloaded data along
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WA Ecology Nail Products Letter







- Theme 1. Nonylphenol ethoxylates in cleaning and clothing products
- Theme 2. Triclosan product uses, removal, and substitution


Attached is a letter from the Washington State Department of Ecology (Ecology) related to the submittal of three spreadsheets to DTSC with data from the following databases:
• WA Children’s Safe Products Act (CSPA) Manufacturer Reporting Database: https://fortress.wa.gov/ecy/cspareporting/
• WA Product Testing Database: https://fortress.wa.gov/ecy/ptdbpublicreporting/
• WA Environmental Information Management Database: http://www.ecy.wa.gov/eim/

Ecology is pleased to provide copies of the
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2017-02-28 Ecology Letter Nonyphenol Ethoxylates and Triclosan

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