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2014-17 Draft Priority Product Work Plan









Comments for Package: 2014-17 Draft Priority Product Work Plan


Total Comments: 347 Sort By View per page





2014-17 Draft Priority Product Work Plan




- Others: general


1. Engage chemical manufacturers and trade organizations early.
2. Refine product prioritization to address meaningful risks to California.
3. Provide clarity to stakeholders across all affected industries by being more transparent about the selection process.
4. Delist potential candidate products and chemicals in the draft Work Plan that are regulated by existing federal and state regulations.
5. The Work Plan likewise requires “a note to readers.”
6. All evaluations must rely on the best avai
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coalition ltr to Director





2014-17 Draft Priority Product Work Plan




- Household, Office Furniture & Furnishings


These comments have been developed on behalf of the US home furnishings industry (the industry coalition) by the American Home Furnishings Alliance (AHFA), the California Furniture Manufacturers Association (CFMA), the Upholstered Furniture Action Council (UFAC), the National Council of Textile Organizations (NCTO), the North American Home Furnishings Association (NAHFA), and the Polyurethane Foam Association (PFA).

See attached.




Joint Industry Comments submitted by AHFA





2014-17 Draft Priority Product Work Plan




- Fishing and Angling Equipment


I am asking that your department drop your intentions to build a regulatory plan to ban lead, copper and zinc in terminal fishing tackle in California.
I) The two people I have spoken to have NO knowledge of what terminal tackle is or how it is used - you don't understand fishing.
2) You have NO scientific research to back your action" some numbers that came from Canada and some other places", this makes your group sound ignorant. Will you have the time and money to do meaningful scientific rese
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Braida,Edith_comment_letter





2014-17 Draft Priority Product Work Plan




- Office Machinery (Consumable Products)


Thank you for the opportunity to review and comment on the California Department of Toxic Substances Control’s (Department or DTSC) Safer Consumer Products (SCP) DRAFT Priority Product Work Plan published in September 2014.

Hewlett-Packard (HP) would like to offer the following feedback on the draft:

1) We would like to have visibility to the supporting information and/or research that informed the Department’s decisions to include the various product categories and potential candidate chemica
more




HP comment letter





2014-17 Draft Priority Product Work Plan




- Others: All categories


The Electronics TakeBack Coalition urges DTSC to add the category of electronic products to its product categories. Please see the attached letter for full comments.




Letter from Electronics TakeBack Coalition





2014-17 Draft Priority Product Work Plan




- Others: Automotive Interiors


October 21, 2014

Miriam B. Ingenito, Acting Director
California Department of Toxic Substances Control
1001 I Street
Sacramento, CA 95812-0806

Dear Ms. Ingenito,

We support the product categories identified by DTSC in the “Safer Consumer Products DRAFT Priority Product Work Plan”. However, we believe the product category list should be expanded in order to be able to capture some of the largest volume products on the market that contribute substantially to the exposure of the general populat
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Research Director





2014-17 Draft Priority Product Work Plan




- Building Products
- Household, Office Furniture & Furnishings


On behalf of the 10 organizations signed on to the attached letter, thank you for the opportunity to comment on the Department of Toxic Substance Control’s Draft Priority Product Work Plan for the Safer Consumer Products Program. We have no financial interest in any of the products or chemicals which may be the subject of these comments.

Californians for Toxic-Free Fire Safety is a diverse coalition of groups dedicated to improving public health and safety by advocating for non-toxic alternati
more




work plan comments final





2014-17 Draft Priority Product Work Plan




- Building Products


The comments of the Resilient Floor Covering Institute of the DTSC Draft Three-Year Work Plan are attached. We look forward to meeting with you to discuss our comments.




RFCI Comments on Draft Work Plan
Appendix A to RFCI Comments on Draft Work Plan





2014-17 Draft Priority Product Work Plan




- Beauty, Personal Care and Hygiene Products
- Building Products
- Cleaning Products
- Clothing
- Household, Office Furniture & Furnishings
- Fishing and Angling Equipment
- Office Machinery (Consumable Products)


Thank you for giving OCSD the opportunity to comment on the Safer Consumer Products Draft Priority Product Three Year Work Plan. Attached is a letter with OCSD's specific comments.




OCSD's Comments on September 2014 SCP Draft Priority Product Work Plan





2014-17 Draft Priority Product Work Plan




- Fishing and Angling Equipment


I support fishing in California. Delist fishing gear from your draft work plan. EPA did not think fishing gear was an issue, so why is California wasting money and resources to come to the same scientifically based conclusion.

It does not appear that the DTSC has conducted any research to justifying new regulations! What publically available information was used in selecting fishing gear?

The Work Plan claims lead poisoning associated with the ingestion of lead fishing weights is well docu
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2014-17 Draft Priority Product Work Plan




- Beauty, Personal Care and Hygiene Products
- Building Products
- Cleaning Products
- Household, Office Furniture & Furnishings
- Fishing and Angling Equipment
- Others: General comments


Please see attachment.




Toxics Use Reduction Institute comments





2014-17 Draft Priority Product Work Plan




- Beauty, Personal Care and Hygiene Products
- Building Products
- Cleaning Products
- Clothing
- Household, Office Furniture & Furnishings
- Office Machinery (Consumable Products)


We appreciate this opportunity to submit comments on behalf of the Natural Resources Defense Council (NRDC), a non-profit organization with over 1.3 million members and activists, 250,000 of whom are Californians. NRDC has no financial interest in any of the chemicals or products that may be the subject of these comments.

We commend the Department on the draft work plan, which is comprehensive, clear and will serve as a good basis for naming Priority Products which impact millions of Californi
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NRDC comments 3 year work plan





2014-17 Draft Priority Product Work Plan




- Beauty, Personal Care and Hygiene Products
- Building Products
- Cleaning Products
- Clothing
- Household, Office Furniture & Furnishings
- Fishing and Angling Equipment
- Office Machinery (Consumable Products)


Attached for your review and consideration are comments prepared by the Green Chemistry Alliance (GCA) regarding the Department of Toxics Substances Control’s (DTSC) Safer Consumer Products (SCP) 3-Year Work Plan.

We look forward to continued dialogue on these issues. Thank you!




GCA DTSC SCP 3-Year Work Plan Comments





2014-17 Draft Priority Product Work Plan




- Beauty, Personal Care and Hygiene Products
- Cleaning Products


To: Meredith Williams, Deputy Director, Safer Products and Workplaces Program, DTSC
From: California Healthy Nail Salon Collaborative
Re Safer Consumer Products Regulations, draft 3-year work plan
Date: October 21, 2014

We are writing to comment on the September 2014 Safer Consumer Products DRAFT Priority Product Work Plan released by the Department of Toxic Substances Control (DTSC).

Workers in the salon industry.

In California alone, there are 289,320 cosmetologists who are licensed to
more




Draft Work Plan comment ltr-CaHNSC





2014-17 Draft Priority Product Work Plan




- Fishing and Angling Equipment


there is no proof








2014-17 Draft Priority Product Work Plan




- Others: 3 Year Work Plan


Comments by the Rubber Manufacturers Association.




Comments by the Rubber Manufacturers Association





2014-17 Draft Priority Product Work Plan




- Clothing


On behalf of the American Apparel & Footwear Association (AAFA), please find attached comments to the California Department of Toxic Substances Control (DTSC) on the Safer Consumer Products (SCP) Draft Priority Product Work Plan.




AAFA Comments to DTSC on the SCP Draft Priority Product Work Plan





2014-17 Draft Priority Product Work Plan




- Building Products
- Clothing
- Household, Office Furniture & Furnishings
- Others: Electrical and electronic products, Transportation, Miscellaneous,


The seven product categories and related subcategories identified by DTSC in the “Safer Consumer Products DRAFT Priority Product Work Plan” are a good starting pointing for the draft Work Plan. We support the listing of these categories and subcategories. However, given that DTSC can “only identify a product as a Priority Product if it falls into one of the categories identified in the Work Plan” and that the life of this Work Plan is three years, it is important that DTSC be inclusive of other
more




Chemical Alternatives Assessment: Enabling Substitution to Safer Chemicals





2014-17 Draft Priority Product Work Plan




- Beauty, Personal Care and Hygiene Products
- Cleaning Products
- Others: Prioritization


Please see the attached letter from the International Fragrance Association North America. Thank you for the opportunity to comment.




IFRA NA Comments





2014-17 Draft Priority Product Work Plan




- Fishing and Angling Equipment


Thank you for the opportunity to comment on this draft plan. On behalf of KeepAmericaFishing, please see the 659 individual letters enclosed.




Individual letters from KeepAmericaFishing members





2014-17 Draft Priority Product Work Plan




- Fishing and Angling Equipment



o DTSC has not conducted California research justifying new regulations!








2014-17 Draft Priority Product Work Plan




- Fishing and Angling Equipment


Raising the costs of fishing equipment is pointless, you already
Raised the fishing licenses prices. It costs me up to $40 plus gas
To fish. It costs between $5 & $9 in some places just for a permit,
On top of that, a required license. Raising fishing equipment prices, don't you think prices are high enough already. Cant use lead weights, bad for fishing. Boats are far more worse than the equipment we use. So I say no to your price raises








2014-17 Draft Priority Product Work Plan




- Building Products
- Clothing
- Household, Office Furniture & Furnishings


The comments of the North American Flame Retardant Alliance of the American Chemistry Council on the SCP 3-year Work Plan are attached.




NAFRA comments on SCP 3-Year Work Plan





2014-17 Draft Priority Product Work Plan




- Office Machinery (Consumable Products)


Please see the attached document of ITI comments on the Draft Work Plan.




ITI comments on Draft Work Plan





2014-17 Draft Priority Product Work Plan




- Fishing and Angling Equipment


I oppose a ban on lead fishing products.




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