State Regulatory Support:
California's Green Chemistry Initiative

California’s Green Chemistry Initiative is a new and unique approach to regulating consumer product formulations containing hazardous chemicals. It is a comprehensive program designed to substantially reduce the impact of “toxic chemicals” on both people and the environment.

The Green Chemistry program will:

1. Identify the world of “toxic chemicals”
2. Develop a list of “chemicals of concern” (using very broad criteria)
3. Develop a list of "products of concern" that either contain these chemicals or use them in
their production and/or disposal
4. Require manufacturers to review all possible alternatives to using these chemicals
5. Implement the elimination of these products and the use of these chemicals from
the California marketplace.

When implementing green chemistry, the human health and environmental effects of products are considered.

The Green Chemistry Initiative is a three step process:

1. Prioritization
2. Alternative Assessment
3. Regulatory Elimination

Prioritization involves the identification of priority products by:

▲ Determining whether or not product contains a priority chemical

▲ Determining the level of priority by evaluating set factors, including:

– The volume of the product already in commerce

– The potential for public exposure to the chemical

– The types and the extent of consumer use of the product

– Whether or not the waste is hazardous

▲ Determining prioritization of a “Product under Consideration” through factors such as:

– The relative degree of threat from the product

– Whether or not the available information is reliable

– Availability of an alternative assessment

▲ Placing the product on a priority list if it meets the necessary conditions.

The second step consists of conducting an Alternative Assessment:

▲ Can the product be reformulated, redesigned or replaced?

▲ Manufacturers will be responsible for submitting an Alternative Assessment Report

▲ The Alternative Assessment Report will undergo a review using a Risk Based Approach

▲ The first step of the Risk Based Approach is the Chemical Hazard Assessment

▲ Product containing chemicals with hazard traits will undergo Exposure Potential
Assessments for all types of potential exposures to persons and the environment

▲ Finally, a Multimedia Life Cycle Evaluation is generated with criteria such as:

– Product function or performance

– Materials and resource consumption

– Air emissions

– Energy efficiency

– Public health/Environmental impacts

– Waste and end-of-life disposal.

The third and final stage is the Regulatory Elimination. Examples of potential responses include product elimination, warning statement or changes in directions for use, end-of life management (forced recycling), and product use restrictions (or none of the above if NO concerns are identified in the Alternative Assessment).

TSG works with companies to ensure that they are prepared for the implementation of this new program, and can minimize its impact on specific product lines by providing guidance and staying ahead of these evolving policies.
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