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Comments for Package: Draft Alternatives Analysis Guide


Total Comments: 20 Sort By View per page





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





Draft Alternatives Analysis Guide




- Others: General comment.


The document is very comprehensive. Probably only people with a background in risk analysis could or would use the document (or be forced to). Recommend that you scrap the entire document and allow entities to determine which of the risk analyses they wish to use. If you are aiming at the fish and game community and the equipment provided to consumers, you will need to look at the cost impact to California. Reducing the number of people fishing and hunting, as a result of suppliers raising c
more








Draft Alternatives Analysis Guide




- Chapter 3 – Relevant Factors


The number of fisherman has been dropping for many years now, restricting equipment will further drive many away from the sport. Please look at states like Alaska which have no restriction on lead weights yet flourishing waters and many more fisherman in them! Thank you.








Draft Alternatives Analysis Guide




- Others: entire process


This is a bureaucratic nightmare. Simplicity would make for a more workable and understandable let alone believable program. It takes several disciplines of science, a lawyer, and a lot more historic data to support and interpret this process realistically.
It would be a political tool and create more division between ideologies not too mention industry (economic factions).
It is too bad government can not find a way to help everyone not just regulate.
Another example of government serving itse
more








Draft Alternatives Analysis Guide




- Chapter 2 – Product Requirements and Alternatives
- Chapter 3 – Relevant Factors
- Chapter 4 – Impact Assessments
- Chapter 6 – Exposure
- Chapter 8 – Economic Impacts
- Chapter 10 – Selection of Alternatives
- Appendix 4 – Methods and Databases for Chemical Hazard Assessment


More science is to determine the affects of lead and its environmental impacts within our ecosystems. To date there have been no definitive studies that support restrictions on the use of lead in fishing tackle.




ASA Position





Draft Alternatives Analysis Guide




- Appendix 2 – Data Sources for Identification of Alternatives
- Appendix 3-2 – Checklists for Identification of Relevant Factors


Please see uploaded document




pinfa comments to CalSAFER alternatives guide for 3-2-17


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