Product Stewardship & Chemicals Management

Nice blog by Michael Kirschner summarizes steps to take to deal with all the challenges  that are threatening products containing chemicals “of concern.”  He advises manufacturers to take the following steps:

1. Collect full material disclosure from your suppliers. Simple declarations and certificates are useless. If your suppliers insist on continuing to provide this level of information in light of the changing marketplace, make sure you understand why they’re doing it and whether you can move to a different supplier that will give you what you need.
2. From this information, produce a list of the chemicals that are used in your product.
3. Prioritize the chemicals in terms of toxicity, potential for exposure, amount, and potential for future regulation.
4. Understand why those chemicals are used.
5. Understand what it would take to replace these chemicals in your product.
6. Assess any marketing or competitive value this could have for your company.
7. Make a plan for what to replace, how, and why. [I would argue you should also consider whether it is worth it to try to defend the use of the chemical.  He seems to be in the "just bail" club.]
8. Get it funded and move ahead.

Knowing what is in your products, designing them to be safe  in the first place and continuous management are core to product stewardship.  Challenges abound in setting up ongoing supply chain communication systems, confidentiality,  information awareness and management systems and the ever-changing set of societal expectations that throw your priorities out of whack.  

     You need explicit and fairly sophisticated systems (including people) to keep up with it all unless you just sell one or two simple component products. Will the exponential growth in public chemophobia and complicated regulatory schemes (e.g., REACH) result in product manufacture being done by only the really big companies that have the resources to cope?  The best a little guy can do is try to find or hook up with big guys in his supply chain and hope they will help him.

EHS Strategies, Inc. can help you get your product stewardship program in shape.

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REACH Dossiers: 92% Lacking

ECHA’s report of 2011 compliance checks showed 134/146 had issues.  Oops. Primarily

- substance identity

- not sufficiently substantiating use of “read across” to avoid testing

- poor Chemicals Safety Reports

Hey – it’s a new program and everyone is learning.  (And they’ve only looked at 146 out of 25,248 dossiers on 4,278 chemicals.)

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REACH for 90 Chemicals – CoRAP

ECHA has now published the list of 90 chemicals that will undergo Evaluation for potential further restrictions under the REACH Community rolling action plan or CoRAP program based on PBT and toxicity concerns seen in the dossiers submitted to date.  The “responsible” Member State will have 12 months to review its chemicals (split into batches over 3 years) and may ask for further information of registrants:

 This request might go beyond the standard information requirements of REACH (Annexes VII to X) and it may pertain to the intrinsic properties of the substance or its exposure. For example, registrants may need to provide studies on mode of action or monitoring of concentration levels in organisms or the environment.

Recommendations will be made to the other member states and ECHA will finally decide after public comment.  They may decide that current risk management is adequate.  Or not.

Some pretty basic chemicals on the list: formaldehyde, methanol, silver, titanium dioxide.  Also the usual suspects: phthalates, chlorinated paraffins, BPA, triclosan, etc.  Check out the chemicals and the concern areas here.

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REACH: 8 More for Authorization

Eight more chemicals require application for authorization to continue use or they’ll be banned under REACH in 2015 (Annex XIV): diisobutyl phthalate (DIBP), diarsenic trioxide, diarsenic pentaoxide, lead chromate, lead sulfochromate yellow (C.I. Pigment Yellow 34), lead chromate molybdate sulphate red (C.I. Pigment Red 104), tris (2-chloroethyl) phosphate (TCEP) and 2,4-dinitrotoluene (2,4-DNT)

 

That makes 14 chemicals so far.

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California Green Chemistry Initiative

Nice summary of the state of the California Green Chemistry Initiative:

The Recorder: CA Green Chemistry Law Has Lawyers, Industry on Alert

Hard to believe California can manage this mess without years of litigation.  This isn’t just putting as label on that customers will ignore like Prop 65 (although it has caused a lot of substitution activity and its share of NGO lawsuits against companies).  It will mean a load of company work looking for the “right” alternatives based on moving target analyses and potential mischief for government blacklisting of companies and their products.  Not to mention that California is broke and doesn’t have the wherewithal to pay bureaucrats to do the reviews required.  A source of exorbitant fees to pay down state debt?

Maybe the state will move slowly on just a couple chemicals of concern and a couple of products to test it out and create a worthwhile process that helps push companies to do better product design.  I just hope it doesn’t become a very expensive, pointless game.

 

If you are interested in how to move forward with product stewardship, that includes meeting or avoiding regulatory challenges like Cal Green Chemistry, contact EHS Strategies, Inc.

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TSCA CDR: Webinar on CDX e-Reporting

On February 8, 2012 from 1:30 to 3:30 EST EPA will conduct a webinar on CDX Registration for the CDR Rule. Discussions will include registration for the 2012 CDR, and how to access eCDRweb, the electronic reporting tool needed to complete the CDR Form U. There will be time for questions. Register for the webinar.

If you already do TRI on CDX, this shouldn’t be a big deal.

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