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Draft Stage 1 Alternatives Analysis Guide














Comments for Package: Draft Stage 1 Alternatives Analysis Guide


Total Comments: 26 Sort By View per page





Draft Stage 1 Alternatives Analysis Guide




- Chapter 5 – Screening Alternatives
- Others: Draft Priority Product Work Plan


“Safer” alternatives is the primary objective of the SCP program, but the term is ill defined at this time, except if the alternative is no longer classified as a chemical of concern (which is not defined anywhere and should be added to the glossary; another suggestion is to add “priority product” to the glossary). To some extent, safer is seen to be subjective with respect to endpoint impacts (Chapter 5 in Draft Stage 1 AA Guide), which is understandable. However, in the Draft Priority Product
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Draft Stage 1 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 Alternatives


See Attached Document




Sportfishing Industry Comments to DTSC on Draft Stage 1 AA Guide





Draft Stage 1 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 Alternatives
- Appendix 1 – Required Information for AA Report
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternative Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 –Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Tools and Methods for Chemical Hazard Assessment


I’d like to commend staff for producing a guidance document that uses clear, concise, and easy-to-read language with many real-world examples and very little jargon. This is an excellent way to reach a very broad audience.

One improvement that could be incorporated into existing chapters is a more explicit discussion of what an AA practitioner does when an alternative under consideration requires broader product reformulation. An existing example, that of flooring product alternatives (pages 40
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Draft Stage 1 Alternatives Analysis Guide




- Others: Entire document


We submit these comments on the DTSC Draft Stage 1 Alternatives Analysis on behalf of Californians for a Healthy and Green Economy (CHANGE). CHANGE is a statewide coalition of environmental and environmental justice groups, health organizations, labor advocates, community-based groups, parent organizations, and others who are concerned with the impacts of toxic chemicals on human health and the environment. Because this draft only includes the first five of eleven proposed chapters and there a
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CHANGE AA comments





Draft Stage 1 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 Alternatives
- Appendix 1 – Required Information for AA Report
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternative Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 –Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Tools and Methods for Chemical Hazard Assessment


Please refer to attached file submitted November 16, 2016: Comments_Stage1_AA_Guide_DTSC_Dow_20151116.pdf




Dow Comments on Draft Stage 1 AA Guide





Draft Stage 1 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 Alternatives
- Appendix 1 – Required Information for AA Report
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternative Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 –Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Tools and Methods for Chemical Hazard Assessment


Thank you for the opportunity to provide comments on the Draft Stage 1 Alternatives Analysis Guide.




Comments by the Rubber Manufacturers Association





Draft Stage 1 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 Alternatives
- Appendix 1 – Required Information for AA Report
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternative Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 –Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Tools and Methods for Chemical Hazard Assessment


The Consumer Specialty Products Association (CSPA) appreciates the opportunity to provide comments on the Draft Stage 1 Alternatives Analysis Guidance Document. CSPA and our member companies have participated throughout the years-long regulatory development process through submission of written comments and participation in public hearings and workshops/seminars. CSPA urges that DTSC carefully consider and adopt the recommendations of the National Academy of Sciences “A Framework to Guide Sel
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CSPA Comments on Safer Consumer Products Program Draft Stage 1 Alternatives Analysis Guidance Docume





Draft Stage 1 Alternatives Analysis Guide




- Introduction
- Chapter 1 – AA Framework
- Chapter 2 – Product Requirements and Alternatives
- Chapter 3 – Relevant Factors
- Appendix 3-3 –Potential Information Sources for Identification of Relevant Factors


Thank you for the opportunity to comment on DTSC’s Draft Stage 1 Alternatives Analysis Guide. Overall, we found the Guidance document to be a helpful resource, especially to those new to alternatives analysis. Especially useful are the text boxes that summarize points and call out questions responsible parties should ask themselves, as well as the many references and resources for further research.

Our comments on specific sections follow:

Glossary
p. 4 Include definition for “green chemistry.
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Draft Stage 1 Alternatives Analysis Guide




- Others: See Attached Comment Letter


Attached for your review and consideration are comments from the Green Chemistry Alliance (GCA) regarding the Safer Consumer Products Program's draft Stage 1 AA Guidance document.

Please contact John Ulrich or me with any questions, concerns or for more information. Thank you!




Green Chemistry Alliance Comment Letter - Draft Stage 1 AA Guidance Document





Draft Stage 1 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 Alternatives
- Appendix 1 – Required Information for AA Report
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternative Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 –Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Tools and Methods for Chemical Hazard Assessment


Please see the attached comments.




ACA Comments on DTSC Stage 1 AA Guide





Draft Stage 1 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 Alternatives
- Appendix 1 – Required Information for AA Report
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternative Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 –Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Tools and Methods for Chemical Hazard Assessment


Thank you for the opportunity to comment. Our comments are attached.





Comments of the American Chemistry Council on Safer Consumer Products Program Draft Stage 1 AA Guide





Draft Stage 1 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 Alternatives


We wish to congratulate the DTSC for considering a class-based approach in its chemical and product research and alternatives assessment, grouping chemicals into structural or functional classes. Despite the challenges and limitations discussed during the Green Ribbon Science Panel meeting on November 13, 2015, we have consistently found that regulating potentially harmful chemicals as classes is a highly effective strategy for reducing the incidence of “regrettable substitutions.”

Structural
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Draft Stage 1 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 Alternatives


Dear Director Lee:
We are writing on behalf of the members of the Halogenated Solvents Industry Alliance (HSIA) to provide input on DTSC’s recently released draft Stage 1 Alternative Analysis Guide for the California Safer Consumer Products (SCP) program. We appreciate the opportunity to provide the following comments and look forward to the Agency’s response.




Stage 1 Guide Comments





Draft Stage 1 Alternatives Analysis Guide




- Others: Please see attached document for full comments.


Please see attached document for full comments.




Alliance of Automobile Manufacturers DTSC Stage 1 Guide Comments FINAL





Draft Stage 1 Alternatives Analysis Guide




- Chapter 2 – Product Requirements and Alternatives
- Chapter 3 – Relevant Factors
- Chapter 4 – Impact Assessments


The Comments on the Draft Stage 1 Alternatives Analysis (AA) Guide of Unifrax I LLC, a manufacturer of Refractory Ceramic Fibers, are attached. As discussed in the comments, the final Stage 1 AA Guide should: (1) emphasize the legal requirement to consider product benefits, particularly energy benefits; (2) require at least a preliminary screening analysis of the feasibility of potential substitutes; (3) clarify that voluntary industry programs can be used as a substitute for AA or significant p
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Unifrax AA Comments





Draft Stage 1 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 Alternatives
- Appendix 1 – Required Information for AA Report
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternative Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 –Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Tools and Methods for Chemical Hazard Assessment


Please see the attached comments from IFRA North America regarding the Draft Stage 1 Alternatives Analysis Guide.




IFRA North America Comments Draft Stage 1 AA Guide





Draft Stage 1 Alternatives Analysis Guide




- Introduction
- Chapter 3 – Relevant Factors


Please find the attached comments from the Motor & Equipment Manufacturers Association.




Motor & Equipment Manufacturers Association Comments to DTSC on the Alternative Analysis Guide





Draft Stage 1 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 Alternatives
- Appendix 1 – Required Information for AA Report


The Department of Toxic Substances Control (DTSC) Human and Ecological Risk Office (HERO) has reviewed the Draft Stage 1 Alternatives Analysis Guide (the Guide). The scope of our review focuses primarily on aspects related to toxicology and hazard analysis, but we have also commented on information delivery.

Please see our attached comments.




DTSC HERO comments on Draft Stage 1 AA Guide





Draft Stage 1 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 Alternatives
- Appendix 1 – Required Information for AA Report
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternative Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 –Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Tools and Methods for Chemical Hazard Assessment


Please see attached document for full comments.

November 16, 2015

Submitted online via CalSAFER

COMMENTS FROM THE NATURAL RESOURCES DEFENSE COUNCIL ON THE DEPARTMENT OF TOXIC SUBSTANCES CONTROL DRAFT STAGE 1 ALTERNATIVES ANALYSIS GUIDANCE

We appreciate this opportunity to submit comments on behalf of the Natural Resources Defense Council (NRDC), a non-profit organization with over 2.4 million members and activists, 380,000 of whom are Californians. NRDC has no financial interest in any of t
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NRDC comments on Stage 1 AA guide





Draft Stage 1 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 Alternatives
- Appendix 1 – Required Information for AA Report
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternative Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 –Potential Information Sources for Identification of Relevant Factors
- Appendix 4 – Tools and Methods for Chemical Hazard Assessment


The California Sportfishing League represents the interests of California’s anglers and the larger sportfishing industry. The Department of Toxic Substances Control has published a Draft Stage 1 Alternatives Analysis Guide, purportedly to assist responsible entities in performing an alternatives analysis for priority products. The League and its members are particularly concerned about the Guide in light of the Department’s inclusion of “Fishing Weights and Gear” as a product category from whi
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California Sportfishing League comment letter on draft stage 1 AA
California Sportfishing League comment letter Attachment A





Draft Stage 1 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 Alternatives


November 16, 2015

SUBMITTED VIA CALSAFER.DTSC.CA.GOV

California Department of Toxic Substances Control
1001 I Street
P.O. Box 806
Sacramento, California 95812-0806

RE: Comments on DTSC’s Alternative Analysis Guidance

Dear Sir or Madam:

The Association of Global Automakers, Inc. (Global Automakers) appreciates the opportunity to provide the following comments and recommendations to the California Department of Toxic Substances (DTSC) regarding its “Draft Stage 1 Alternatives Analysis Guide
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Global Automakers Comments to DTSC on Draft Stage 1 AA Guide





Draft Stage 1 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 Alternatives
- Appendix 1 – Required Information for AA Report
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-2 – Checklists for Identification of Relevant Factors


Congratulations on a fine new draft of the AA Guidance Document. It is well organized and well written. It flows logically and is easy to follow. Generally, I think the tone is nicely balanced—partly directive and partly encouraging. There are many examples and illustrations (there could be more) and these offer practical concreteness to the text. Definitions are handled well in the text and in boxes. Indeed, the boxes are very helpful throughout.

I understand that this is only the first
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Draft Stage 1 Alternatives Analysis Guide




- Introduction
- Chapter 1 – AA Framework


One flaw of the proposed AA system is not about gathering complete product requirements, all the relevant factors, dealing with data gaps, lack of credible sources or even fully screening any possible alternatives, but in developing an acceptable methodology for weighting factors and providing a decision making tree to avoid regretable substitution or improper conclusion - too many equal factors leads to DTSC analysis paralysis. One must rank and then choose what's more important. And to consume
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Draft Stage 1 Alternatives Analysis Guide




- Chapter 2 – Product Requirements and Alternatives
- Chapter 3 – Relevant Factors
- Chapter 4 – Impact Assessments
- Others: Definitions


Add Green Chemistry Definition: The design, development, and implementation of chemical products and processes that reduce or eliminate the use and generation of hazardous substances.

Justification: The term green chemisty is used in several locations in the document.

Chapter 2, Page 26: Third paragraph, discussion on ‘consumer acceptance’.
Although the Department acknowledges the importance of consumer acceptance, the Department will consider how a responsible entity justifies that a viab
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Draft Stage 1 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 Alternatives
- Appendix 1 – Required Information for AA Report
- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-1 – List of Factors for Consideration in the Alternative Analysis
- Appendix 3-2 – Checklists for Identification of Relevant Factors
- Appendix 3-3 –Potential Information Sources for Identification of Relevant Factors


Attached please find comments from the American Cleaning Institute on the Draft Stage 1 Alternatives Analysis Guide.




ACI Comments on Draft Stage 1 AA Guide

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