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Chemical Industry Council of California

Green Chemistry Alliance Opposes DTSC Rules Proposal

Contends Rules Too Seriously Flawed - Recommends They be Withdrawn - Posted 11/05/10



On November 1st, the industry coalition know as the Green Chemistry Alliance (GCA) gave oral testimony and submitted 169 pages of legal and technical comments and exhibits opposing the DTSC's proposed Safer Consumer Product Alternatives (SCPA) regulations.  GCA, which until now has been proactively supportive of DTSC's efforts to promulgate final rules for implementation of the Green Chemistry legislation (AB 1879 and SB 509; 2008) has expressed that it is "incredibly dismayed" at the manner in which DTSC has so sharply deviated from the track they were on when the draft regulation was released in June 2010.  GCA contends that, "These [newly] proposed regulations if adopted will have very serious and detrimental impacts on the regulated community and the state's economy."   Read complete GCA comments.


In concluding its comments, GCA writes:


"The Green Chemistry Alliance has appreciated the opportunity we have had to constructively work with DTSC and the other stakeholders over the past two years in an attempt to craft a set of workable regulations.  We are therefore perplexed and greatly disappointed that at this late date in the process DTSC would choose to veer so dramatically from the path they had been following.  These regulations as proposed have entirely lost focus and will not work.  The proposed rules lack clarity and authority and seek to impose unnecessary regulatory burdens on all of California's business and industry.   Until such time as major issues identified above are addressed, the Green Chemistry Alliance can no longer support the adoption of these regulations.  GCA recommends DTSC withdraw the regulations and develop a more workable program for carrying out the Green Chemistry law.  We urge DTSC to seek out the advice of the Green Ribbon Science Panel and other stakeholders who are interested in refocusing the regulations on addressing the areas of greatest risk reduction in a scientifically sound and efficient manner.  The Green Chemistry Alliance stands ready to constructively participate in such an effort."



Earlier, GCA submitted comments and testified before the CalEPA Environmental Policy Council (EPA) to make the point that the all encompassing nature of the rules and their lack of clarity regarding how DTSC might implement the rules leave every industry vulnerable to the whims of future regulators.  Given the uncertainty of the rules GCA testified the EPC could not, as required by AB 1879, "conclusively determine" that the regulations "will not have any significant adverse impact" on public health or the environment.  The EPC, comprised of the Secretary of CalEPA and the six heads of the Boards, Offices and Departments of CalEPA (Water, Air, Recycle, OEHHA, DPR, DTSC) nevertheless summarily dismissed industry's comments and proceeded to make such a ruling thereby assuring a legal challenge if the rules proceed to final promulgation in their current form.  See GCA comments to EPC.


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