ACI Stresses Science When Evaluating Products

The California Department of Toxic Substances Control (DTSC) should consider information and sources responsibly as it looks to amend the Safer Consumer Products (SCP) program framework regulations, according to comments submitted by the American Cleaning Institute (ACI), the trade association for the cleaning product supply chain.

In the comments, ACI:
 - Advises DTSC to ensure there is a comprehensive analysis of alternatives
 - Highlights that the proposed reliability criteria that would replace an Alternatives Analysis are insufficient
 - Points out that the proposed amendments as described are skewed against products

ACI writes, “In its Technical Document, DTSC proposes to amend the SCP framework regulations such that it has the authority to skip the Alternatives Analysis stage in the process, thereby proceeding directly from listing a Priority Product to proposing a regulatory response. In this approach, DTSC would instead ‘rely on publicly available studies or evaluations of alternatives’ to inform its decisions. The amendments would also create a new ‘petition pathway’ whereby interested parties can present DTSC with information on a product-chemical combination and suggest a regulatory response.”

ACI said it appreciates DTSC’s desire to improve its SCP process; however, in practice, there are several concerns with the proposed amendments, which could enable hype or fear to dominate over thorough scientific considerations.

“With its regulatory authority over essential products that have critical roles in protecting health and hygiene, it is important for DTSC to consider information and sources responsibly,” writes Dr. Dan Selechnik, ACI Director, Environmental Health & Safety. The proposed amendments risk undermining a fully science-based process; therefore, maintaining the Alternatives Analysis stage within the SCP framework is necessary.

Click here to read the full comments.