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Here are my comments to FTC on their latest Green Guides:
Re: Proposed, Revised Green Guides, 16 CFR Part 260, Project No. P954501
The latest version of the Green Guides adds useful clarification for the primary standards environmental marketing claims that should adhere to:
Claims need to be technically accurate and supported by scientific data.
Claims should not be misleading to the consumer insofar as they imply environmental benefit that is not and/or cannot be substantiated. -
EPA has just posted its draft Alternatives Assessment Methodology on how it will compare the hazards of alternate chemicals in deciding whether or not to designate a product as “Designed for the Environment.” DfE is geared to identifying alternatives that work and are available and are greener than the current chemicals that are being used. The methodology guide offers how to classify hazards as very high-high-moderate-low and has many useful resources for those of you trying to decide which alternatives are “safer.” EPA will be using alternatives analysis when looking at safer alternatives for the Chemical Action Plan priority chemicals.
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California listened to some of the public comments on their proposed Safer Consumer Product Alternatives regulation (see earlier blog) and simplified it some. Details can be found here, with 15 days to get in comments.
Jumping through the hoops of Chemicals and Products Under Consideration and preparing a Tier I Alternatives Assessment are gone. Now it will just be proposed and final Chemicals of Concern and Priority Products. Notification that a Chemical of Concern is in a consumer product also will have less confidential business information. But there will still be a boatload of work to do Alternatives Assessments on Priority Products.
