CICC Offers Initial Comments on DTSC's “Green Chemistry Initiative”
Sacramento, CA - CICC submitted comments to Cal/EPA Secretary, Linda Adams, regarding its initial reaction to the recently announced Green Chemistry Initiative. CICC complemented Secretary Adams and Maureen Gorsen, Director of the Department of Toxic Substances Control (DTSC), for their efforts to broadly communicate the goals and plans of the Initiative, and to identify a transparent and inclusive stakeholder process. According to CICC, ". . . these up-front efforts will serve the process well as it moves forward."
CICC reiterated comments it made during an earlier presentation at theGreen Chemistry Symposium in October 2006. "The concepts of 'green chemistry' are not at odds with the direction of today's modern chemical industry," said CICC. However, CICC cautioned that narrow and prescriptive regulatory definitions of 'green chemistry' and 'green engineering' would have a deleterious and stifling effect on development in California.
According to CICC, "Green chemistry policies should be based upon scientific methodologies that are both objective and reproducible. Alternative technologies and seemingly less hazardous materials do not always prove to be a panacea in the final analysis. A science-based assessment that evaluates human health and environmental considerations, performance, cost and feasibility must include an examination of traditional and alternative technologies, materials and processes. Finally, positive incentives must be a part of the Green Chemistry Initiative if it is to ultimately accomplish its goals."
On the matter of product substitution and alternative green molecules, CICC wrote, "Not all traditional chemicals can or ever will be replaced with 'green' alternatives, but all chemicals can, through a process of continuous improvement and pollution prevention, be manufactured, distributed, and used in a more sustainable manner." CICC believes the voluntary DTSC/CICC Pollution Prevention Challenge Program, and other projects like it, will further this objective.
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