Life Cycle Thinking Blog Moves

Life Cycle Thinking blog is moving.

I will continue to provide commentary about TSCA, REACH, product stewardship, sustainability, environmental marketing claims and more as part of the redesigned EHS Strategies, Inc. website.

Georjean Adams

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Cadmium “Studies” Must Be Reported

EPA has withdrawn this final rule as of Dec 14, 2012 - too controversial!

ATTENTION ARTICLE MAKERS!

EPA today released a final rule  that requires reporting of “health and safety studies” under TSCA section 8(d) for cadmium and its compounds in consumer products.  This is a little broader than the lead rule that focused on children’s products (40 CFR 716.21(a)(8)).

Article Import and Manufacture: The rule applies to manufacturers and importers of cadmium, cadmium compounds or cadmium-containing ARTICLES  that have been, or are reasonably likely to be, incorporated into consumer products if any cadmium has been measured to be present.

“consumer product means any product that is sold or made available to consumers for their use in or around a permanent or temporary household or residence, in or around a school, or in or around recreational areas.”

Reportable “studies” appear to have been expanded beyond traditional toxicity and exposure studies to include:

- measurement of cadmium content in a consumer product

- discussion of the function of the cadmium and formulation

- migration from the product studies

The preamble implies the above are reportable as stand-alone data.  That’s not the way TSCA 8(d) reads: such data would only e reportable if it were developed as part of an exposure assessment or toxicity study.

As with the standard 8(d) model rule (40 CFR 716), this rule applies to anyone who manufactured or imported cadmium-containing consumer  products in the last 10 years and anyone proposing to do so in the future.

Timing:  The rule is effective 30 days after Federal Register publication unless someone complains, in which case EPA traditionally withdraws the “direct final” rule and publishes a proposed rule for comment.  Expect there to be comment.  Once final, you have 60 days to send in unpublished studies in your possession and 30 days to notify EPA of future studies.

This stems from EPA’s work with CPSC to reduce cadmium exposure.

Contact EHS Strategies, Inc. for assistance.

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TSCA CFR Bookmarks Updated

Updated TSCA e-CFR (electronic Code of Federal Regulations) links can be found on EHS Strategies, Inc.’s webpage TSCA Quick Links.  The Government Printing Office seems determined to move around the urls for TSCA.

Even EPA can’t keep up with the changes on their websites!  EPA’s page on section 8(d) health and safety studies reporting links 40 CFR 716 to

PART 407—CANNED AND PRESERVED FRUITS AND VEGETABLES PROCESSING POINT SOURCE CATEGORY

(which happens to be TSCA exempt)

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REACH: 20 More SVHC

ECHA has added 20 more chemicals to the Substances of High Concern (SVHC) list: more lead, chromate and arsenic compounds, phenolphthalein, dichloromethylenedianiline, BCME, EDC, anisidine, technical MDA, refractory ceramics and more.
The full list of SVHC is here

For these newly listed chemicals European importers and manufacturers must inform their downstream industrial users and respond to customer inquiries about the presence of these SVHC.  In addition, the batch listed in June  2011 are now subject to notification to ECHA for articles with >0.1% of those chemicals (along with all the other chemicals previously listed) unless the use in the articles were registered under REACH in November 2010.  More information is available from ECHA here.

EHS Strategies, Inc. can help you understand and deal with these requirements.

 

 

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REACH: Act NOW for 2013 Registration

ECHA is encouraging companies to get going NOW for the May 31, 2013 REACH registration deadline for >100 metric ton volume chemicals.  See the press release here.  You might want to check out some of the videos from the REACH workshop held September 23.   Preparation for registration is a long effort to collect and assess data, especially when there is negotiation between parties doing joint registration.

If you need to register as a manufacturer or importer, find (or form) your SIEF (Substance Information Exchange Forum).

If you are a downstream user, get your use information up to your suppliers so they can make sure to cover your uses in their dossier and exposure assessments.  Make sure you know that your purchased chemicals are already registered or will be by your suppliers and that you receive extended safety data sheets from them.

 

Need REACH help? Contact EHS Strategies, Inc.

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Changing Corporate Culture: Employee Engagement

Very useful guide on how to go about engaging your employees into sustainability and watch the culture change: Toward Engagement 2.0
While these case studies are from companies who “get” sustainability, there are some good suggestions for how to develop sustainability-think for all employees and yield real value for any company at any stage. Lots of resources, too.

I like their approach of encouraging you to tailor programs to what works best for your organization.  Their steps in bold with my spin on what it means.

Permit: Start with a sustainability vision and demonstrate senior management believes it.

Educate & Engage:  Communicate messages to your employees in ways that are meaningful for your organization and types of employees.

Act: Empower and recognize employees to do sustainable things.

Embed: Infiltrate sustainability into your current culture, rather than take the 2×4 approach.

Evaluate: You only know if you are improving if you measure the right things and adapt as necessary.

Every employee needs to do what they do sustainably.  Do they know what that means for your organization and do you help them to succeed?

Contact EHS Strategies, Inc. for help.

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Product Stewardship: Design with LC Thinking

Interesting presentation by Bresseler company in how they do quick versions of life cycle analysis in an iterative process in doing product design:  http://www.bresslergroup.com/webinar/cut-the-crap/video.php

I don’t know the company, but I like their way of thinking.

This is not unlike the product stewardship processes I’ve long supported.  See my paper on

Product Development with Life Cycle Thinking

While you are designing processes to serve customer needs, keep you eyes wide for more sustainable solutions and keep checking as you go, including after the product is out there and new information and technologies point toward even better solutions.

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Postponing the Ozone Standard Revision

Obama postponed the revision to the ozone standard today.  It’s the right move for now.

Everyone wants clean air.  The questions are how much it costs and who pays?  We have a convoluted accretion of decades-long regulatory mechanisms that have very high costs to companies in pollution control and compliance (that require resource reallocation away from income-generating production) and high costs to state governments (i.e., state taxpayers) to implement ozone control programs.  Postponement while we work our way through this recession is realistic.

What we really need is to redesign how we achieve pollution reduction most efficiently and move toward products and processes that are made and used sustainably.  EPA reviewing a list of 35 individual regulations will not address the fundamental structural problems we have with our media-based patchwork of laws and regulations.  If only we could start over and create a better system based on sustainability principles and work out a rational transition process to get there….

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EPA TSCA Chemical Prioritization

EPA is holding a webinar on how they are going to prioritize chemicals under TSCA Sept 7, 2011, 1:30 – 3:30 pm EST. Register here.   Apparently they heard the message that their picks of chemicals of concern for “action plans” were pretty random.  Will this be a recast of ChAMP?

Get background and blog on the topic with EPA here until Sept 14.  This seems more a focus on data sources than the actual assessment and prioritization process itself, however.  The devil is always in the detail and weighting of factors and just how large a collection of chemicals EPA intends to tackle and how.

Once upon a time, I helped develop a model with the then Chemical Manufacturers Association on how EPA could prioritize chemicals based on a separatory funnel filled with red, yellow and green chemical-application entities (represented by jelly beans in an actual sep funnel).

(c)1996, Chemical Maufacturers Association Product Risk Management Strategy Overview

We argued that EPA should focus on the highest likely risks (worst first) – the red chemical-application/use combinations (red dots).  The factors EPA lists in the background paper are “red,” although it’s not clear they are talking risk as in exposure + toxicity, rather than stand alone criteria: children’s products, PBT, developmental effects, carcinogens.  But key to the concept of the sep funnel was that EPA should titrate (tackle) red dots (high potential risk chemical-applications) only at the rate it could manage through its regulatory processes.  As it screened and addressed chemical risks, it could  titrate out some more chemical-use applications.  Of course, the Jackson EPA is into issuing blacklists of chemicals and publishing industry reported data (the new CDR with difficult CBI claims) to enable NGOs to exert pressure on companies to eliminate chemical use, so EPA can avoid writing regs.

We even went so far as to draft the reporting elements of a “red dot reporting rule” – focused on toxic  chemicals that would likely be highest risks according to exposure filters.  At that time (mid-90′s), we were trying to avoid threatened massive IUR reporting. Fifteen years later, we get the Chemical Data Reporting Rule – without the filters, so we’ll have a lot of yellow and green chemical dots being reported on – with EPA still not sure how it’s going to prioritize chemicals.  Sigh….

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ACS Sustainability Website

The American Chemistry Society has launched it’s new website on sustainability: www.acs.org/sustainability.

Yours truly led development of the site as a portal for those interested in chemistry and sustainability and, in particular, to learn what the American Chemical Society and its members are doing and can do to understand and create chemical solutions sustainably.

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