IPC Comments on California’s Impractical Green Chemistry Proposal
BANNOCKBURN, Ill., USA, November 5, 2009 — IPC’s Environment, Health and Safety (EHS) Steering Committee submitted comments yesterday to California’s Department of Toxic Substances Control (DTSC) on their proposal for a green chemistry regulation. The EHS committee comments urged the DTSC to adhere to a science-based, lifecycle approach to evaluating chemicals.
The DTSC proposal includes a list of hundreds of chemicals of concern that cannot be in any products sold in California. “IPC had high hopes for DTSC’s green chemistry policy, but was extremely disappointed with the recent proposal because it identifies hundreds of prohibited chemicals without regard for the inevitable disruption to the marketplace,” explained Fern Abrams, IPC director of government relations and environmental policy.
Abrams said the DTSC’s proposal takes the “everything but the kitchen sink” approach to a chemicals regulation. The IPC comments caution the DTSC that having this enormous list of banned substances without conducting a thorough, comprehensive alternatives assessment for each chemical will inevitably lead to inadvertent negative results.
“A prime example of a negative consequence is if brominated flame retardants are removed from circuit boards, the number of fire deaths associated with electronics catching fire could be more prevalent, as Europe experienced, ” says Lee Wilmot, director of environmental health and safety (EHS) at TTM Technologies, and chairman of IPC’s EHS Steering Committee.
IPC encouraged DTSC to initially limit the scope of the regulation to the nine product categories identified in the first section of the straw proposal in order to be able to implement a more targeted, manageable regulation. In its comments, IPC notes that regulating all products sold in the state of California at once will severely disrupt the marketplace. If all products are regulated at once, some manufacturers may choose to stop selling a product in California all together and others may be forced to redesign their products, leading to inevitable price increases.
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