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Greener on the Other Side?: STPP comments on AB1879 Draft Regulation

We respectfully submit the following comments to the Safer Consumer Product Alternatives Draft Regulations released by Department of Toxic Substances Control (DTSC) on November 15, 2010. As you know, STPP strongly supports the overall goals of SB 509 (Simitian, 2008) and AB 1879 (Feuer) to identify chemicals of concern in consumer products and promote the development and diffusion of safer substitutes whenever feasible. STPP’s December 22, 2009 White Paper “Integrating Safer Alternatives into Chemical Policy: Developing a Regulatory Framework for AB 1879” outlined an approach we believed would lead to efficient and effective implementation of the legislation. We appreciate that a number of the recommendations suggested in the White Paper and in our later comments on various versions of draft regulations were addressed by DTSC. The comments below highlight a number of remaining problems with the current draft regulation which, if left to stand, would create significant barriers undermining the core goals of the legislation. For each problem, we provide practical solutions intended to resolve the underlying issue. Taken together, we believe that the recommended changes will result in a regulatory program that will efficiently and effectively drive the innovation and diffusion of safer alternatives.

STPP Comments (complete document)