Life Cycle Thinking Blog - Product Stewardship

The new Responsible Care Product Safety Code enhances value chain communication in ways that chemical customers should be using now.

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.”

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.

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”

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

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:

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?

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.

Kind of ironic:
Industry has submitted a petition to EPA to hold off on getting data on List 2 for the Endocrine Disruptor Screening Program (EDSP) until the Agency reviews and issues final guidance on how they are going to deal with the results they get on the first list of chemicals – especially if the agency is going to change the rules of the game in the middle of testing. Allegedly, one issue of controversy is around Good Laboratory Practices (GLP) – a careful set of documentation, review and recordkeeping requirements to ensure data quality every step of the way for any given written protocol. By following GLP, it should be possible to verify the protocol was followed and any deviations noted so that the test could be replicated (or challenged) by others. Failure to follow GLP leaves open the possibility of biased short-cuts or modifications (or ignoring uncomfortable data points) that make the results unreliable.