TSCA CDR: Attention Solvent Recyclers

EPA is determined to get reports from solvent recyclers under the TSCA Chemical Data Reporting rule (formerly IUR).  From their “Q&A Document on Recycling and the TSCA Chemical Substance Inventory“:

Question C. 8 We have facilities that recycle spent solvents. The spent solvents are received as a hazardous waste and are often complex mixtures of different types of solvents. These materials are re-distilled to remove water and other contaminants and to separate the various solvents, and are re-sold as solvents. Is the recycling of the solvents a “manufacturing” activity?

A: In this case, the spent solvents are considered to be byproducts of use. However, according to 40 CFR 720.30(g), the manufacture of a byproduct is exempt from reporting when the byproduct is solely used to extract a component chemical substance from the byproduct. The extracted component chemical substances, the various purified solvents this case, are reportable chemical substances.

Contact EHS Strategies, Inc. for help.

 

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REACH SVHC in Article Controversy Still

The issue of whether the Substances of Very High Concern (SVHC) in articles is triggered at >0.1% weight of chemical to weight of the entire article placed on the market or to any component of that article remains controversial according to discussions at the September 23, 2011 REACH workshop.  ECHA guidance is still holding with the entire article weight in the denominator, but acknowledges that some member countries are saying they will enforce the RoHS approach on each component part.  ECHA and The European Commission are looking at how to resolve this issue.

Odds are good that this one is going to the European Court of Justice.

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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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