Archive for the ‘Product Stewardship’ Category

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


Read Full Post »

EPA released its “Universe of Chemicals” of 10,000 chemicals that might be targeted for screening tests to determine whether they are endocrine disruptors over the next 5 years (it could have been 87,000).  From the report:

“It is important to emphasize that the identification of this universe of chemicals for potential EDSP screening should neither be interpreted as a list of chemicals that will automatically be screened, nor as a list of chemicals with potential to interfere with endocrine systems of humans or other species.”

The report also lays out validation principles that will be used on the screening tools (heavy on computational modeling):

1. a defined endpoint;
2. an unambiguous algorithm;
3. a defined domain of applicability;
4. appropriate measures of goodness-of-fit, robustness and predictivity;
5. a mechanistic interpretation.

and declares external peer review will take place in January 2013.

Pretty ambitious.

Read Full Post »

California’s Appellate Court ruled that California’s Office of Environmental Health Hazard Assessment (OEHHA) went too far in basing Prop 65 listing as a “known” carcinogen on the basis of an IARC 2B (possibly carcinogenic to humans) classification for styrene and vinyl acetate.  Since Prop 65 represents a blacklist in not only California but also many other states and purchasers who use it for their toxics lists, this is a Big Deal.  Obviously for styrene and vinyl acetate (which are building blocks for major polymers) but also for other Prop 65 candidates and blacklisters.

See great summary article by Bergeson & Campbell here

Read Full Post »

ECOS – Environmental Council of the States (an organization of state environmental agency leaders) adopted a definition of “product stewardship” as:

“…the act of minimizing health, safety, environmental, and social impacts, and maximizing economic benefits of a product and its packaging throughout all lifecycle stages. The producer of the product has the greatest ability to minimize adverse impacts, but other stakeholders, such as suppliers, retailers, and consumers, also play a role. Stewardship can be either voluntary or required by law”

This in conjunction with their real interest of Extended Producer Responsibility (EPR – aka you-made-it-you-eat-it):

“…a mandatory type of product stewardship that includes, at a minimum, the requirement that the producer’s responsibility for its product extends to post-consumer management of that product and its packaging. There are two related features of EPR policy: (1) shifting financial and management responsibility, with government oversight, upstream to the producer and away from the public sector; and (2) providing incentives to producers to incorporate environmental considerations in the design of their products and packaging”

ECOS almost got product responsibility right.  Except that it isn’t “an act,”  it’s acting on an ongoing basis using life cycle thinking.  It isn’t something that other stakeholders “play a role” in – it’s a shared responsibility of everyone involved with a product – everyone who can affect the life cycle (including the public sector).  At least they acknowledged that there are benefits associated with products – but they aren’t only economic benefits, unless they mean to cover quality of life and the pursuit of happiness under the term.  Mandatory product stewardship is also a nonstarter for me.  Product stewardship is an ethic.  While society can set regulations and punish violators, “mandating” how one should think doesn’t work.

EPR – another blog for another day.  EPR may or may not make sense as a tool of product stewardship in limited cases, but thank you, ECOS, it is not the same as.  I’m not convinced that “incenting” product stewardship this way is desirable or effective.  See an interesting report on EPR here showing it may not be such a cost-effective solution after all.  Mostly, I have issues with the fantasy that the consumer doesn’t pay for EPR take-back programs (customers pay for everything a company does) and that government knows what its doing in setting up false markets. Previous moaning here.

Read Full Post »

EPA finally finished it’s peer review of results from the infamous Ramazzini Institute labs that test sick animals after pressure from industry that the lab’s practices were inappropriate.  It will no longer rely on findings from this lab when it does IRIS reports.  Immediately affected are dropping cancer findings for methanol, MTBE and ETBE.  http://www.epa.gov/iris/ramazzini.htm

It took awhile, but scientific peer review is necessary and proper.

Read Full Post »

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.

Read Full Post »

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.

Read Full Post »

Older Posts »