Posts Tagged ‘EHS Strategies Inc.’

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EPA has withdrawn this final rule as of Dec 14, 2012 – too controversial!


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  Once final, you have 60 days to send in unpublished studies in your possession and 30 days to notify EPA of future studies.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


(which happens to be TSCA exempt)

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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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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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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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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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