Life Cycle Thinking Blog

As expected, the direct final rule requiring reporting “health and safety studies” under TSCA 8(d) for anything with cadmium in it was too controversial.

Pointed comments by outgoing CEFIC (European Chemical Industry Council) president Squinzi on REACH here. One highlight on the 2 billion euro cost since 2007…

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.”

EPA has withdrawn this final rule as of Dec 14, 2012 – too controversial!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

Reminder that FTC has issued new guides for environmental marketing claims: http://www.ftc.gov/os/2012/10/greenguides.pdf

There are more examples and terms explained, but it still comes down to two basic principles:

1. Be technically accurate

2. Do not mislead

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.

EPA is on a tear issuing Significant New Use Rules (SNURs) under TSCA. Mostly for new chemicals that hit triggers under PMN reviews. Make sure you are reading notifications from suppliers – often on MSDS – that may affect how you can use the chemical (e.g., workplace protections and disposal restrictions) and trigger export notifications to EPA under section 12.

Interesting article on LEED certification: http://www.usatoday.com/story/news/nation/2012/10/24/green-building-leed-certification/1650517/

It’s not so easy to come up with a green standard – lots of competing goals and caveats to encourage enough buy-in to get organizations to use the standard. Unfortunately, many government organizations make assumptions about LEED without looking at the shortcomings because it’s simple to glom onto. Like every other system out there, lots of people will game it. How do you set up enough post-certification validation checks without dragging the whole system down? LEED has caused movement in the right direction overall, but maybe not much.

Good quick review of available tools to do Life Cycle Assessments: http://www.linkcycle.com/comparison-of-best-life-cycle-assessment-software/ and here

I like the way Linkcycle thinks – focusing on the most strategic and biggest influencers on lifecycle impacts, rather than doing monster assessments. They even offer a free quick review tool.

Helpful webinar slides and audio have been posted on ECHA’s site regarding the CoRAP evaluation process on chemicals registered under REACH.

Presentations emphasize the tight time frame for the evaluations and the need to coordinate with fellow registrants so you have a central contact point (likely the lead registrant) to deal with issues around new testing and data submissions that may be raised by the evaluating member state. ECHA speakers reminded people that the listing on CoRAP does not mean there will be any change in current regulation of the chemical. Of course, time will tell.