Comments Search




Enter search keyword

Filter Options

Comment Keyword Option






Date Range for Comments Submitted



Document Type





Documents with Attachments





Total Comments: 416 Sort By View per page







- 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
more




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
more




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
more




2017-02-28 Ecology Letter Nonyphenol Ethoxylates and Triclosan







- Theme 1. Nonylphenol ethoxylates in cleaning and clothing products


The California Retailers Association concurs with, supports and echoes the comments submitted by the Apparel and Footwear International RSL Management Group (AFIRM) re "Potential Aquatic Impacts and Continued Uses of Nonylphenol Ethoxylates (NPEs) and Tricolsan".

NPEs are already voluntarily being removed from the supply chain, and will be regulated in the European Union in 2021. There are functionally acceptable, technically feasible and economically feasible alternatives already in use. Thus,
more










- 1) Chemicals in nail products – chemical presence, functional use, hazard traits, endpoints, and exposure information
- Others: General principles for DTSC to consider


Please see attached comments from the Natural Resources Defense Council.




Comments from NRDC







- Theme 1. Nonylphenol ethoxylates in cleaning and clothing products


To California Department of Toxic Substances Control,

The Apparel and Footwear International RSL Management (AFIRM) Group welcomes this opportunity to provide DTSC with information on the use of nonlyphenol ethoxylates (NPEs) in clothing products as part of the Safer Consumer Products (SCP) prioritization process. NPEs have historically played a significant role in a wide variety of apparel and footwear manufacturing processes, and AFIRM seeks to demonstrate the substantial progress made to da
more




AFIRM CA DTSC NPE Comments







- 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 from Keith Maruya (SCCWRP) and Rebecca Sutton (SFEI).




Comments from SCCWRP and SFEI





Draft Alternatives Analysis Guide




- Chapter 1 – AA Framework
- Chapter 2 – Product Requirements and Alternatives
- Chapter 6 – Exposure
- Chapter 7 – Life Cycle Impacts


Please see our comments attached in the PDF document.




MEMA Commnets on Draft AA Guide





Draft Alternatives Analysis Guide




- Chapter 4 – Impact Assessments
- Appendix 4 – Methods and Databases for Chemical Hazard Assessment
- Appendix 6 – Exposure Tools
- Appendix 7-2 – LCA Tools


Is Medscape also an acceptable research tool? It has news articles as well as links to journal articles. Are all the EPA research tools available to the public?








Draft Alternatives Analysis Guide




- Others: General comments


The Draft Alternatives Analysis Guide is a comprehensive resource for use in developing an alternatives analysis under the Safer Consumer Products Act.

We commend the Department on a thorough compilation of tools and methodologies available. However, we feel that examples, illustrating what compliance with requirements might look like, would be useful to companies working to comply.

BizNGO has developed three model alternatives assessments using the framework outlined in the California Safer
more








Draft Alternatives Analysis Guide




- Introduction
- Chapter 2 – Product Requirements and Alternatives
- Chapter 3 – Relevant Factors
- Appendix 11 – Information Quality Evaluation in Other Frameworks


General Comments
1. The VI supports the comments of the American Chemistry Council (ACC) submitted in their separate response to the subject request for comment.
2. The VI strongly supports following the principles established in The National Academies 2014 Framework on selection of chemical alternatives.
Specific Comments
3. The example on page 24 with respect to polyvinyl chloride food wrap should be removed. It incorrectly states:
“For example, when looking for alternatives to phthalates
more




Vinyl Institute





Draft Alternatives Analysis Guide




- Introduction
- Chapter 1 – AA Framework
- Chapter 2 – Product Requirements and Alternatives
- Chapter 3 – Relevant Factors
- Chapter 4 – Impact Assessments
- Chapter 5 – Screening of Alternatives
- Chapter 6 – Exposure
- Chapter 7 – Life Cycle Impacts
- Chapter 8 – Economic Impacts
- Chapter 9 – Informational Needs in AA
- Chapter 10 – Selection of Alternatives
- Chapter 11 – Self-Evaluation of AA
- Appendix 1 – Required Information for AA Reports
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternatives Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 – Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Methods and Databases for Chemical Hazard Assessment
- Appendix 6 – Exposure Tools


Please see attached comments from the Natural Resources Defense Council.




Comments from NRDC on Draft Alternatives Analysis Guide





Draft Alternatives Analysis Guide




- Appendix 4 – Methods and Databases for Chemical Hazard Assessment


p. 194 Appendix 4 –Methods and Databases for Chemical Hazard Assessment
B. Databases for Collecting Chemical Hazard Information

• Healthy Building Network. Chemical Hazard Data Commons. A tool is still under development and designed to compile resources on hazard information of chemicals and alternatives.

Comment: I’m not clear on how this listing of databases is distinguished from Appendix 2. It is possible that the same or a modified version of the description of the Data Commons provided fo
more








Draft Alternatives Analysis Guide




- Appendix 2 – Data Sources for Identification of Alternatives


p. 168 Appendix 2 – Data Sources for Identification of Alternatives
Current language:
“• Chemical Hazard Data Commons (http://healthybuilding.net/content/data-commons) This free web-based service, provided by Healthy Building Network, is not available to the public yet, but is being tested by a beta test group as of this writing. It is a tool to help find information about chemical substances, and provides links to other databases such as PubChem, ChemIDplus, eChemPortal, HSDB, Pharos, and the
more








Draft Alternatives Analysis Guide




- Chapter 4 – Impact Assessments


Current language:
“...Currently, most list translators have only been developed to apply to narrow categories of chemicals or products, such as cleaning products, and are typically designed to be used by practitioners with limited experience or knowledge of chemical hazards. As with the lists themselves, list translators are straightforward to use, but they can be constrained by their narrow focus and limited number of attributes. A responsible entity that uses a list translator tool will need
more








Draft Alternatives Analysis Guide




- Chapter 1 – AA Framework
- Chapter 2 – Product Requirements and Alternatives
- Chapter 3 – Relevant Factors


Please see attached comments by the Rubber Manufacturers Association.




RMA Comments on Alternatives Analysis Guide





Draft Alternatives Analysis Guide




- Introduction
- Chapter 1 – AA Framework
- Chapter 2 – Product Requirements and Alternatives
- Chapter 3 – Relevant Factors
- Chapter 4 – Impact Assessments
- Chapter 5 – Screening of Alternatives
- Chapter 6 – Exposure
- Chapter 7 – Life Cycle Impacts
- Chapter 8 – Economic Impacts
- Chapter 9 – Informational Needs in AA
- Chapter 10 – Selection of Alternatives
- Chapter 11 – Self-Evaluation of AA
- Appendix 1 – Required Information for AA Reports
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternatives Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 – Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Methods and Databases for Chemical Hazard Assessment
- Appendix 6 – Exposure Tools
- Appendix 7-1 – SCP Factors and Typically Used Life Cycle Impact Categories
- Appendix 7-2 – LCA Tools
- Appendix 11 – Information Quality Evaluation in Other Frameworks


The comments of the American Chemistry Council on DTSC's Draft Alternatives Analysis Guide are attached.




ACC Comments on Draft AA Guide





Draft Alternatives Analysis Guide




- Introduction
- Chapter 1 – AA Framework
- Chapter 2 – Product Requirements and Alternatives
- Chapter 3 – Relevant Factors
- Chapter 4 – Impact Assessments
- Chapter 5 – Screening of Alternatives
- Chapter 6 – Exposure
- Chapter 7 – Life Cycle Impacts
- Chapter 8 – Economic Impacts
- Chapter 9 – Informational Needs in AA
- Chapter 10 – Selection of Alternatives
- Chapter 11 – Self-Evaluation of AA
- Appendix 1 – Required Information for AA Reports
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternatives Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 – Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Methods and Databases for Chemical Hazard Assessment
- Appendix 6 – Exposure Tools
- Appendix 7-1 – SCP Factors and Typically Used Life Cycle Impact Categories
- Appendix 7-2 – LCA Tools
- Appendix 11 – Information Quality Evaluation in Other Frameworks


The Consumer Specialty Products Association (CSPA) appreciates the opportunity to provide comments on the Draft Alternatives Analysis Guidance Document. CSPA members are committed to manufacturing and marketing safe products that are protective of human health and the environment while providing essential benefits to consumers. CSPA submitted extensive comments on the Draft Stage 1 AA Guidance and many of the concerns raised in that evaluation remain. We appreciate the intent of the Departme
more




CSPA Comments AA Guidance





Draft Alternatives Analysis Guide




- Introduction
- Chapter 1 – AA Framework
- Chapter 2 – Product Requirements and Alternatives
- Chapter 3 – Relevant Factors
- Chapter 4 – Impact Assessments
- Chapter 5 – Screening of Alternatives
- Chapter 6 – Exposure
- Chapter 7 – Life Cycle Impacts
- Chapter 8 – Economic Impacts
- Chapter 9 – Informational Needs in AA
- Chapter 10 – Selection of Alternatives
- Chapter 11 – Self-Evaluation of AA
- Appendix 1 – Required Information for AA Reports
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternatives Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 – Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Methods and Databases for Chemical Hazard Assessment
- Appendix 6 – Exposure Tools
- Appendix 7-1 – SCP Factors and Typically Used Life Cycle Impact Categories
- Appendix 7-2 – LCA Tools
- Appendix 11 – Information Quality Evaluation in Other Frameworks


Comments from The Dow Chemical Company




Comments from The Dow Chemical Company





Draft Alternatives Analysis Guide




- Introduction
- Chapter 1 – AA Framework
- Chapter 2 – Product Requirements and Alternatives
- Chapter 3 – Relevant Factors
- Chapter 4 – Impact Assessments
- Chapter 5 – Screening of Alternatives
- Chapter 6 – Exposure
- Chapter 7 – Life Cycle Impacts
- Chapter 8 – Economic Impacts
- Chapter 9 – Informational Needs in AA
- Chapter 10 – Selection of Alternatives
- Chapter 11 – Self-Evaluation of AA


Please see attached.




Auto Alliance Comments on DTSC Draft AA Guide-Stage II 2017-02-03





Draft Alternatives Analysis Guide




- Introduction
- Chapter 1 – AA Framework
- Chapter 2 – Product Requirements and Alternatives
- Chapter 3 – Relevant Factors
- Chapter 4 – Impact Assessments
- Chapter 5 – Screening of Alternatives
- Chapter 6 – Exposure
- Chapter 7 – Life Cycle Impacts
- Chapter 8 – Economic Impacts
- Chapter 9 – Informational Needs in AA
- Chapter 10 – Selection of Alternatives
- Chapter 11 – Self-Evaluation of AA


Please see uploaded document.




Comments on AA Guide





Draft Alternatives Analysis Guide




- Chapter 3 – Relevant Factors
- Chapter 7 – Life Cycle Impacts
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 7-1 – SCP Factors and Typically Used Life Cycle Impact Categories
- Appendix 7-2 – LCA Tools


I will upload two documents: one is a relatively brief set of more general comments; the other is a marked-up version of the AA Guide, which includes a number of specific comments and suggested edits.




2017-02_IC2 Comments on California Draft AA Guide
Draft-Alternatives-Analysis-Guide_IC2-comments

12345678910...

Home