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SUPPLY-CHAIN-WIDE PRODUCT DATA MANAGEMENT

July 28, 2010

EPA Advances Material Disclosure by Publishing Latest Industrial and Toxics Release Data

EPA announced today that Toxics Release Inventory data will be made available the same month it is collected.

In keeping with its drive toward material disclosure regulation and management, the U.S. Environmental Protection Agency (EPA) announced today (July 27, 2010) it has published the latest data on industrial releases and transfers of toxic chemicals in the United States between Jan. 1 and Dec. 31, 2009. EPA is making the Toxics Release Inventory (TRI) data available within weeks of the reporting deadline.

For more on material disclosure in at the chemical and substance level, see this issue of Chem.Info magazine, but it was in the print version so you have to view it in the online-magazine format here - on page 8. There, the in-depth article lists the Top 20 Best Practices for managing material disclosure and declaration.

Data Unlocked

The information made available today by EPA includes environmental release and transfer data on nearly 650 chemicals and chemical categories reported to EPA by more than 21,000 industrial and other facilities. Examples of industries that report to TRI include general manufacturing, metal mining, electric utilities, and commercial hazardous waste treatment facilities. Deadline for reporting data is July 1st of each year.

EPA and disclosure exposure

“It is vital that every community has access to information that impacts their health and environment,” said EPA Administrator Lisa P. Jackson in a statement today (July 28, 2010). “The data we’re releasing provides critical insights about pollution and polluters in the places where people live, work, play and learn. Making that knowledge available is the first step in empowering communities to protect the environment in their areas.”

The preliminary data-set allows communities to find out about releases and transfers of chemicals at the local level. EPA says it will continue to process paper submissions, late submissions, and to resolve issues with the electronic submissions.

For more information on the data: http://www.epa.gov/tri

July 26, 2010
EPA Issues GHG Reporting Requirements for Coal Mines, Wastewater, Landfills, and Magnesium Production Facilities: On June 29, 2010, the U.S. Environmental Protection Agency (EPA) announced it is finalizing requirements under its national mandatory greenhouse gas (GHG) reporting program for underground coal mines, industrial wastewater treatment systems, industrial waste landfills and magnesium production facilities.

The data from these sectors will provide a better understanding of GHG emissions and will help EPA and businesses develop effective policies and programs to reduce them.

Methane is 20 times as potent as carbon dioxide
Methane is the primary GHG emitted from coal mines, industrial wastewater treatment systems and industrial landfills; it's more than 20 times as potent as carbon dioxide in warming the atmosphere. Carbon dioxide of course is the most infamous GHG: colorless, odorless, incombustible -- CO2, formed during respiration, combustion, and organic decomposition is used in food refrigeration, carbonated beverages, inert atmospheres, fire extinguishers, and aerosols.

The main fluorinated GHG emitted from magnesium production is sulfur hexafluoride, which has an even greater warming potential than methane, and can stay in the atmosphere for thousands of years.

These source categories will begin collecting emissions data on January 1, 2011, with the first annual reports submitted to EPA on March 31, 2012.

Requesting public comment on which GHG info to make public
In a separate proposed rule, EPA is requesting public comment on which industry related GHG information would be made publicly available and which would be considered confidential. (see previous post on U.S. GHG Reporting System) Under the Clean Air Act, all emission data are public. Some non-emission data, however, may be considered confidential, because it relates to specific information which, if made public, could harm a business’s competitiveness. Data considered confidential under this proposal include: certain information reported by fossil fuel and industrial gas suppliers related to production quantities and raw materials.

EPA says it is committed to providing the public with as much information as possible while following the law.

The GHG reporting program requires that suppliers of fossil fuels (or industrial GHGs) and large direct emitters of greenhouse gases to report to EPA. Collecting such data will encourage businesses to track emissions and identify cost effective ways to reduce emissions.

EPA hopes to provide data to the public after the first annual GHG reports are submitted: March 2011. That may seem like a long way off -- but it really isn't.

More information on the final rule to add reporting requirements for four source categories: http://www.epa.gov/climatechange/emissions/remaining-source-categories.html

More information on the proposal on data confidentiality: http://www.epa.gov/climatechange/emissions/CBI.html

July 20, 2010
A Growing Population Needs Clean Water: As the population grows, the nation's clean water supply needs to be managed knowledgeably and carefully. Withering wetlands, vital to replenishing drinking water, are under constant pressure to maintain not only our need for water but the environment's as well. The idea is to keep chemicals out of the watershed and and the supply of water itself at a sustainable level. Environmental Leader recently published an overview of U.S. Wetlands and Water Policy. Environmental Leader deserves kudos for its excellent product-stewardship-oriented web site for Green.

In related news, the EPA will be holding its 7th annual drinking water workshop August 8th -10th in Cincinnati, OH. Details here.

Also: EPA is seeking small business input on proposed stormwater rule, inviting small businesses and municipalities to nominate representatives who will provide input on a proposed stormwater rule. Selected participants would provide input to a Small Business Advocacy Review panel.

More information about participating in the panel, go to: http://www.epa.gov/sbrefa/stormwater.htm
For more information about the rulemaking, go to: http://www.epa.gov/npdes/stormwater/rulemaking

The proposed stormwater rule would strengthen the national stormwater program under the Clean Water Act (CWA) and focus on stormwater discharges from developed sites, such as subdivisions, roadways, industrial facilities, and commercial buildings or shopping centers.

For further information on the EPA's drinking water strategies:
A New Approach to Protecting Drinking Water and Public Health

July 16, 2010
Obama's Head of EPA Testifies on BP Oil Spill in Gulf: EPA will continue to provide full support to the United States Coast Guard (USCG) and the UC, and will continue to take a proactive and robust role in dispersant use as well as monitoring, identifying, and responding to potential public health and environmental concerns, including waste management and beach cleanup. -- Lisa P. Jackson, Administrator, U.S. Environmental Protection Agency in Thursday's Legislative Hearing on Use of Dispersants in BP Oil Spill. The same day, BP managed to stop oil from gushing into the Gulf for the first time since April.

Jackson began her testimony on Thursday (July 15, 2010) this way: "I also want to express my condolences to the families of those who lost their lives and those injured in the explosion and sinking of the Deepwater Horizon." Very appropriate beginning.

Jackson went on to discuss what EPA’s Oil Spill Program is. "The program focuses on activities to prevent, prepare for and respond to oil spills from a wide variety of facilities that handle, store, or use various types of oil."

EPA regulates approximately 620,000 of these facilities, including oil production, bulk oil storage, and oil refinery facilities that store or use oil in above-ground and certain below-ground storage tanks. Additionally, EPA is the principal federal response agency for oil spills in the inland zone, including inland waters.

EPA’s Role in Spill Response

EPA is one of many agencies providing support to the USCG-led federal response. EPA’s monitoring and sampling activities provide the USCG, states, and local government with information about the potential impacts of the oil spill and response on human health of residents and aquatic life along the shoreline. Jackson said, "EPA is collecting samples along the shoreline and beyond for chemicals related to oil and dispersants in the air, water and sediment, supporting and advising USCG efforts to clean the reclaimed oil and waste from the shoreline, and closely monitoring the effects of dispersants in the subsurface environment."

Use of Chemical Dispersants

Dispersants contain chemicals mixtures, that, when applied directly to the spilled oil, can break down the oil into smaller drops that can sink below the water’s surface. Jackson explained, "Dispersed oil forms a 'plume' or 'cloud' of oil droplets below the water surface, and mixes vertically and horizontally into the water column, and is ideally rapidly diluted.

"The application of dispersant is part of a broader environmental triage approach to minimize the known threat to the environment to the greatest extent possible," Jackson pointed out. But there are trade-offs. As we've said before in this blog -- see "Five Most Commonly Asked Questions About the Gulf Oil Spill" -- a chemical dispersant solution is the lesser of evils.

"We know dispersants are generally less toxic than the oils they break down," Jackson said. "We know that surface use of dispersants decreases the environmental risks to shorelines and organisms at the surface and when used this way, dispersants break down over several days to weeks."

Results indicate -- so far -- that subsea use of the dispersant is effective at reducing the amount of oil reaching the surface.

On May 26, 2010, EPA together with USCG directed BP to significantly decrease the overall volume of dispersant used and to cease use of dispersant on the surface of the water altogether, unless conditions on the ground limited the use of other mechanical means. Since that directive, the total volume of dispersants used has fallen by almost 70% from peak levels.

Yesterday, Thursday, July 15, 2010, for the first time since April 20, 2010, BP managed to completely stop oil from gushing into the Gulf.

July 13, 2010

A Boston IPC Symposium on Electronics & the Environment

Electronics and the Environment is the subject of an IPC Symposium on July 20–21, 2010. Participants will meet in Boston, Mass.

IPC Symposium Subjects are: REACH, RoHS, TSCA, Material Disclosure, and Green Chemistry.

"Get Up to Speed on How Ever-Changing Environmental Regulations Will Affect You." That's from the Event announcement email.

In June, the European Chemicals Agency (ECHA) announced the addition of eight additional substances to the REACH Substances of Very High Concern (SVHC) list while the European Union Parliament's Environmental Committee voted on proposed changes to the RoHS Directive. Also in June, California published a draft Green Chemistry regulation which would require alternative assessments for chemicals of concern contained in consumer products sold in the state.

And that's only the tip of the iceberg.

With the plethora of international chemical and product regulations evolving across the globe, it's easy to be overwhelmed. This July 20–21, IPC's Symposium -- called It's Not Easy Being Green -- will help everyone get up to speed on the latest regulatory developments from around the globe. Subjects include:

chemical regulations in Asia
changes to the EU REACH Regulation
changes to the EU RoHS Directive
implementation of a Globally Harmonized System for Labeling Chemicals
the Canadian Chemicals Management Plan
California's Green Chemistry Initiative

The symposium will also tackle the halogen-free trend and the need to know what is in your products. Materials declaration will be the subject of a lively debate on full disclosure, plus there will be an overview of the new IPC-1752A materials declaration standard and an optional workshop on materials declaration following the conference. A workshop on REACH Compliance will also be offered for those wanting a full overview of this complex regulation.

July 12, 2010
REACH Compliance Deadline is November 2010: The deadline for REACH registration is 30 November 2010 for the registration of high volume and potentially toxic substances. In order to be in compliance, companies or their representatives must register by that date.

There are notable benefits for registering before the drop-deadline, as itemized by a recent report from ECHA, the European Chemicals Agency. Risk-mitigation is the largest benefit. (For an overview of REACH regulation, see previous post on the Top Ten FAQs about REACH.)

Companies are accelerating their efforts to gather the necessary data, reports ICIS.com. Software solutions for REACH compliance can help some companies streamline operations and mitigate risk associated with chemical management in a product supply network. Still, even if using software, it is important to have an understanding of the big picture.

The November cut-off, the first of three Reach registration deadlines, covers dossiers for chemicals produced or imported in annual volumes of 1,000 tonnes or more. It also covers registration of substances which are carcinogenic, mutagenic or toxic to reproduction and chemicals used in quantities above 100 tonnes per year that pose long term risks to aquatic organisms, as stated by the RSC.

Benefits of submitting before October 1st are:

Resubmission

Companies that submit dossiers early (before 1 October) will get their Completeness Check result within 3 weeks and will have the time to resubmit. Should they fail the second time, they can even start the process again provided they are in a position to make a new submission before 1 December.

Later submissions will have only one chance to get through the entire registration process successfully.

As incentive for timely registration, ECHA is offering manufacturers, importers or only representatives a special service from ECHA’s Helpdesk. ECHA is ready to address Lead Registrants’ requests on a priority basis. When appropriate, assistance will be provided over the phone.

Registration: a Behind the Scenes Look

For dossiers arriving after 30 September, there will be a "floating" period -- about six months of uncertainty -- regarding the status of REACH registration. What will happen is: ECHA examines the dossier on arrival, and, if the dossier is not complete, ECHA writes to the registrant before 1 March 2011. Companies will then get a reasonable deadline (typically a further four months) to provide the information requested by ECHA. If that information is not provided satisfactorily, then the registration has failed, and there is no second chance. Failed means: the company does not receive a registration number and the substance cannot legally be manufactured or imported in the European Union – worse, any manufacturing or import since the registration deadline will have been illegal.

Submitting before the end of September will prevent companies being in an uncertain situation. Uncertain situations are risky business in today's changing regulatory landscape; it's important to have compliance details settled so a business can move forward. Please contact us for more information.

July 9, 2010
Sustainable Materials Management Push by New EU Presidency: The Belgian EU Presidency wants to clean up industrial processes in Europe by promoting a "cradle-to-cradle" approach to resource management in the manufacturing sector, according to latest reports. Materials management for sustainability is nothing new - but the fact that it's drawing high-level attention and backing from the co-creators of the landmark chemical-management law known as REACH regulation (see What is REACH?) gives new life to the sustainable materials approach.

History: Herman Miller is generally credited with introducing the phrase "cradle-to-cradle" into the public mindset -- the phrase indicates, of course, the importance of designing products for greener beginnings and for recycling or re-use after the product's life span. Here is a nice article about their sustainable design practices from Treehugger. Herman Miller partners with many companies to enhance CSR and materials management initiatives -- they continue to be industry leaders in this regard and many others (fantastic products, profits, public perception, endurance, etc).

EurActiv, an excellent source for European environmental news, reports that environmental ministers will debate a study by the Belgian EU Presidency on "sustainable materials management" (SMM) while meeting in Ghent this July 12-13, 2010. Bear in mind that this current EU Presidency only lasts 6 months (rotating basis). That said, the EU has been the leader in green chemistry, renewable energy, and recycling policy so far; we can assume that any reasonable cradle-to-cradle initiative -- once in motion -- is unlikely to be overturned, quelled, or squashed by subsequent rotations of governance.

How does a manufacturing processing and materials policy affect manufacturing in the U.S.? Immensely. First of all, manufactures or distributors who produce, source from, or sell to the EU (which is pretty much all businesses!) will need to comply with new sustainable materials management regulation. Second, the U.S. tends to follow Europe in environmental regulation for industry, so what the EU does is inevitably on its way elsewhere, including here in America. REACH is one example, see also WEEE and RoHS directives. And material disclosure directives and material disclosure solutions loom large in the U.S. with EPA honing related current and pending TSCA legislation.

Please stay tuned for more critical environmental regulatory news for business. We comb the regulations as a matter of course -- please make use of our work! Bookmark us, subscribe to our feed, and / or check in with us twice a week. As researchers and bloggers, we're pleased to be the industry reference library for Regulatory Updates, background, facts and new solutions.

July 6, 2010

Pollution Controls - EPA updates Clean Air Act

WASHINGTON D.C. – Gina McCarthy, the U.S. Environmental Protection Agency’s (EPA) assistant administrator for air and radiation, held a press conference call today, July 6 at 12:30 p.m. Eastern Time to discuss a significant Clean Air Act proposal to protect public health and the environment.

Today's conference call was titled, “EPA's Clean Air Act Announcement.” The gist of the call was the long-awaited rewrite of the Clean Air Interstate Rule for keener pollution controls. Emissions monitoring is typically done either by tracking the output at the smokestack itself or by tracking the raw materials in the plant and/or manufacturing process.

Clean Air Act: what's in your output?

Today's EPA call was for credentialed members only, mostly media. But the material hopes to have far-reaching affect.

Preventing 14,000 to 36,000 premature deaths per year
The updated regulation, known as the Clean Air Interstate Rule, requires 31 states from Massachusetts to Texas to reduce emissions that cause smog and soot and can travel long distances via wind. The agency predicted the rule would prevent about 14,000 to 36,000 premature deaths a year, says the News Tribune.

The new plan will tighten restrictions on pollution from coal-burning power plants in the eastern half of the U.S., a key step to cut emissions that cause smog. The EPA said the new rules would cut sulfur dioxide emissions by 71 percent from 2005 levels by 2014 and nitrogen oxide emissions by 52 percent.

Background of the Clean Air Act
Journalists Mark Peters and Tennille Tracy at The Wall Street Journal reported this morning, before the call:

"The program [Clean Air Act] announced in 2005 by the EPA under President George W. Bush was aimed at making the largest reduction in air pollution in more than a decade. It used existing environmental markets to reduce emissions of sulfur dioxide and nitrogen oxides mostly from coal-fired power plants in 28 eastern states.

"The plan prompted a flurry of activity in U.S. emissions markets and increased investments by utilities in pollution controls. But a federal appeals court in July 2008 rejected the rule, saying it was fatally flawed, and sent it back to the EPA to rewrite," said the WSJ.

July 1, 2010

RoHS exceptions: toxic materials in electronics - notable exemptions

RoHS is far reaching and surprisingly penetrating. We have written an overview of RoHS in this blog previously, including the Top 5 Questions about RoHS as well as General RoHS Information.

Got RoHS? You may not need to...

The electronics industry already has standards and legislation and tools for compliance in place. Manufacturers, of course, must understand and manage the requirements of the RoHS Directive to ensure that their products, and their components, comply. Yes, RoHS is enforced. As ubiquitous as RoHS is becoming, there are exceptions to the rule. Sometimes - and here's where it gets complicated - there are exemptions for use of *mercury, lead, cadmium (see SVHC list here) in the manufacture of electronics and electronic devices. Below is a list worth browsing. It might be too much detail for most but do scan it to get a feel. Then, you may want to keep it handy for reference.

RoHS Exemptions as of March 2010

Mercury in compact fluorescent lamps not exceeding 5 mg per lamp
Mercury in straight fluorescent lamps for general purposes not exceeding: — halophosphate 10 mg
Mercury in straight fluorescent lamps for general purposes not exceeding: — triphosphate with normal lifetime 5 mg
Mercury in straight fluorescent lamps for general purposes not exceeding: — triphosphate with long lifetime 8 mg
Mercury in straight fluorescent lamps for special purposes
Mercury in other lamps not specifically mentioned in this Annex
Lead in glass of cathode ray tubes, electronic components and fluorescent tubes
Lead as an alloying element in steel containing up to 0,35 % lead by weight, aluminum containing up to 0,4 % lead by weight and as a copper alloy containing up to 4 % lead by weight
Lead in high melting temperature type solders (i.e. lead-based alloys containing 85 % by weight or more lead)
Lead in solders for servers, storage and storage array systems, network infrastructure equipment for switching, signaling, transmission as well as network management for telecommunications
lead in electronic ceramic parts (e.g. piezoelectronic devices)
Cadmium and its compounds in electrical contacts and cadmium plating except for applications banned under Directive 91/338/EEC (1) amending Directive 76/769/EEC (2) relating to restrictions on the marketing and use of certain dangerous substances and preparations
Hexavalent chromium as an anti-corrosion of the carbon steel cooling system in absorption refrigerators
DecaBDE in polymeric applications. Exemption ended 30 June 2008
Lead in lead-bronze bearing shells and bushes
Lead used in compliant pin connector systems
Lead as a coating material for the thermal conduction module c-ring
Lead and cadmium in optical and filter glass
Lead in solders consisting of more than two elements for the connection between the pins and the package of microprocessors with a lead content of more than 80 % and less than 85 % by weight
Lead in solders to complete a viable electrical connection between semiconductor die and carrier within integrated circuit Flip Chip packages
Lead in linear incandescent lamps with silicate coated tubes
Lead halide as radiant agent in High Intensity Discharge (HID) lamps used for professional reprography applications
Lead as activator in the fluorescent powder (1 % lead by weight or less) of discharge lamps when used as sun tanning lamps containing phosphors such as BSP (BaSi2O5:Pb) as well as when used as specialty lamps for diazoprinting reprography, lithography, insect traps, photochemical and curing processes containing phosphors such as SMS ((Sr,Ba)2MgSi2O7:Pb)
Lead with PbBiSn-Hg and PbInSn-Hg in specific compositions as main amalgam and with PbSn-Hg as auxiliary amalgam in very compact Energy Saving Lamps (ESL)
Lead oxide in glass used for bonding front and rear substrates of flat fluorescent lamps used for Liquid Crystal Displays (LCD)
Lead and cadmium in printing inks for the application of enamels on borosilicate glass
Lead as impurity in RIG (rare earth iron garnet) Faraday rotators used for fibre optic communication systems until 31 Dec-09
Lead in finishes of fine pitch components other than connectors with a pitch of 0.65 mm or less with NiFe lead frames and lead in finishes of fine pitch components other than connectors with a pitch of 0.65 mm or less with copper lead frames
Lead in solders for the soldering to machined through hole discoidal and planar array ceramic multilayer capacitors
Lead oxide in plasma display panels (PDP) and surface conduction electron emitter displays (SED) used in structural elements; notably in the front and rear glass dielectric layer, the bus electrode, the black stripe, the address electrode, the barrier ribs, the seal frit and frit ring as well as in print pastes
Lead oxide in the glass envelope of Black Light Blue (BLB) lamps
Lead alloys as solder for transducers used in high-powered (designated to operate for several hours at acoustic power levels of 125 dB SPL and above) loudspeakers
Hexavalent chromium in corrosion preventive coatings of unpainted metal sheetings and fasteners used for corrosion protection and Electromagnetic Interference Shielding in equipment falling under category three of Directive 2002/96/EC (IT and telecommunications equipment). Exemption granted until 1 July 2007.
Lead bound in crystal glass as defined in Annex I (Categories 1, 2, 3 and 4) of Council Directive 69/493/EEC (1)
Cadmium alloys as electrical/mechanical solder joints to electrical conductors located directly on the voice coil in transducers used in high-powered loudspeakers with sound pressure levels of 100 dB (A) and more
Lead in soldering materials in mercury free flat fluorescent lamps (which e.g. are used for liquid crystal displays, design or industrial lighting)
Lead oxide in seal frit used for making window assemblies for Argon and Krypton laser tubes
Lead in solders for the soldering of thin copper wires of 100 μm diameter and less in power transformers
Lead in cermet-based trimmer potentiometer elements
Cadmium in photoresistors for optocouplers applied in professional audio equipment until 31 December 2009
Mercury used as a cathode sputtering inhibitor in DC plasma displays with a content up to 30 mg per display until 1 July 2010
Lead in the plating layer of high voltage diodes on the basis of a zinc borate glass body
Cadmium and cadmium oxide in thick film pastes used on aluminum bonded beryllium oxide
Cadmium in colour-converting II-VI LEDs (< 10 μg Cd per mm 2 of light-emitting area) for use in solid state illumination or display systems until 1 July 2014

Again - as of March 2010.

For more information on RoHS: http://www.rohs.gov.uk/Docs/Links/RoHS%20directive.pdf
For more information on WEEE: http://www.rohs.gov.uk/Docs/Links/WEEE%20directive.pdf

* The second three of six substances of very restricted use under RoHS are:

June 29, 2010
EPA and lead paint regulation: EPA and Lead Paint
EPA will delay enforcing lead-paint regulation, according to a great write-up by Stephen Power at the Wall Street Journal last week. In a memorandum to EPA regional offices on Friday, Cynthia Giles, the EPA's assistant administrator for enforcement, said the agency will not take enforcement action against renovation and repair firms for violations of the rule's certification requirement until October 2010.

June 28, 2010
Should the U.S. give Canada the oil-drilling business?: Today, BP spending on the Gulf oil spill has hit $100 million per day (source: James Heron, Wall Street Journal). AP reports the total oil spill price-tag so far: $2.65 billion.

An article in the July Oilweek Magazine simultaneously suggests that Canada might be best suited to take over oil and gas exploration.

Should Canada take over oil and natural gas exploration?

The article says that Worker Safety is the thing that Canadian oil exploration has that other countries have not yet mastered. And that the investment pays off when you start looking at the price-tag that less-than-spectacular Safety Procedures can bring.

"The EH&S stool has three legs," McKenzie-Brown writes: "customs and social attitudes; regulatory and industrial codes; technical skills and operating environments. If the legs aren´t the same length, the stool wobbles. Since the three legs of the Canadian stool are level and strong, there are good reasons to encourage the industry to reach out to new operating environments."

"People [doing safety turnarounds at gas plants] now have fall-arrest equipment. They don´t do anything without fire protection and breathing air equipment. A friend of mine tells me that at the plant he works at, the safety bill used to be $20,000. Now it´s like $300,000 to $400,000. Every time someone goes into a vessel, someone has to be there to watch. They may need to have specialized safety equipment or even specially trained personnel to watch that person in the vessel." His point is that this investment pays off in a relatively safe and accident-less history of oil and gas incidents.

With oil leaking in the Gulf of Mexico, Canada is well-positioned to deal with the heightened risks—and reap the bountiful rewards—of frontier exploration, says Peter McKenzie-Brown. He argues that Canada has Environmental, Health & Safety -- or EH&S -- so embedded in its policies and the fabric of its business culture that Canada is in prime position to pick up the slack in oil drilling that the U.S. may be unable to handle.

It comes down to EH&S - McKenzie-Brown says that Safety is the third leg of a stool that U.S. oil companies have shortened beyond repair. Source: "It’s a matter of safety," Oilweek Magazine. Read more: http://www.oilweek.com/articles.asp?ID=745#ixzz0sA9ufQxV

June 22, 2010

EPA and Chemical Safety Inspections: Employees Asked to Participate

EPA seeks employee participation in chemical safety inspections.

Breaking News: The U.S. Environmental Protection Agency (EPA) has released interim guidance that aspires to provide greater transparency in the agency’s chemical safety inspections process. Under the interim guidance, EPA inspectors will offer employees and employee representatives the opportunity to participate in chemical safety inspections.

EPA will also request that state and local agencies adopt similar procedures under the risk management program.

The Risk Management Plan Rule (RMP Rule) requires companies of all sizes that use certain flammable and toxic substances to develop a Risk Management Program. The program includes a(n):

Hazard assessment that details the potential effects of an accidental release, an accident history of the last five years, and an evaluation of worst-case and alternative accidental releases
Prevention program that includes safety precautions and maintenance, monitoring, and employee training measures
Emergency response program that spells out emergency health care, employee training measures and procedures for informing the public and response agencies (e.g the fire department) should an accident occur

The Risk Management Program overall is about reducing chemical risk at the local level. Chemical information -- what is housed where and what the properties and hazards are -- helps local fire, police, and emergency response personnel (who must prepare for and respond to chemical accidents). This level of chemical information is very useful in general to citizens in understanding the chemical hazards in communities.

Under the Clean Air Act, the Chemical Accident Prevention Provisions require facilities that produce, handle, process, distribute, or store certain chemicals to develop a Risk Management Program, prepare a risk management plan, and submit the plan to EPA. EPA expects to issue final guidance on participation of employees and employee representative in RMP inspections later this year.

If you have questions or concerns, contact us for tricks and solutions. Start here - Information Week article on how electronic systems tend to be best for managing hazardous materials. See also article on material disclosure best practices - but mind you, that link takes you to e-Magazine version of Chem.Info Magazine and you have to turn to Page 8. Still - there are 20 Best Practices listed and its worth reading. To get in touch with EPA, the contact for this subject is Dale Kemery (try kemery dot dale at epa dot gov). Good luck; please write a note if you find anything you think others could benefit from knowing.

Towards increased transparency of chemicals

EPA believes that involvement of employees and employee representatives in inspections is more effective in terms of inspection results and better protects workers and the adjacent communities. EPA anticipates that making the RMPs available to the public stimulates communication between industry and the public to improve accident prevention and emergency response practices at the local level.

It seems to so far -- as you can see, we jumped to blog about it as soon as the announcement posted! It's definitely buzz-worthy news. Stay alert; stay tuned.

June 21, 2010
Is Your Salary Fair? New Salary Figures for Purchasing / Supply Mgmt: The Institute for Supply Management (ISM) has just released the results of its survey of Supply Management professionals. ISM is the world's largest supply management organization. Supply management refers to managing supplied goods and services, as well as managing procurement processes, contracts, supplier relations, and supplier metrics. An extensive career center and more general info available at http://www.ism.ws/.

ISM says that salaries in Supply Management start at $50,000 (USD) at entry-level and go up to $250,000 (USD). Remember that these are averages, some will be higher, others not as high. For reference: according to the U.S. Dept of Labor, in May of 2008 the median annual wages of Purchasing Managers were $89,160. The middle 50 percent earned between $67,370 and $115,830. The lowest 10 percent earned less than $51,490, and the highest 10 percent earned more than $142,550.

Other info on Supply Management: an Elsevier report on the subject, for reference; and Supply Purchasing is a website that sometimes has good articles.

Survey says...

The numbers:

$240,408 Chief Purchasing/Supply Management/Sourcing
$226,562 Vice President, Purchasing/Supply Management/Sourcing
$132,398 Director, Purchasing/Supply Management/Sourcing
$94,384 Manager, Purchasing/Supply Management/Sourcing
$71,348 Experienced Supply Management Professional
$50,506 Entry-Level Supply Management Professional

ISM salary survey figures for 2009 are in U.S. dollars. (Image courtesy Photos8.)

This is ISM's fifth comprehensive salary survey. Amazingly, almost 1000 ISM members and non-members participated in the survey.

The metrics were gathered as follows: ISM surveyed supply management professionals in the United States during January and February 2010. Random samples of customers were pulled from an ISM database that included both members and nonmembers. An e-mail message requesting participation was then sent to these customers. In all, a total of 973 responses were received, representing a response rate of 7.3 percent.

There's more detail in the full report - and must say, with the high response rate it's an interesting and unique compilation of data. The full report is available for $199 at the ISM web site. We'll keep posting relevant industry data; feel free to inquire if you have questions on materials procurement.

June 17, 2010

Top 10 Questions & Answers about GHS

The new GHS classification and communication pieces are the foundation of larger programs that ensure the safe use of chemicals. We need a world with a sensible approach to chemical management in products, materials, storage, and waste. GHS is the bedrock for this. The first two steps in any program to ensure the safe use of chemicals are 1)to identify intrinsic hazard(s) such as classification, and then 2)to communicate that information. GHS aims to address both steps in a globally standardized way. In common language, GHS just means a universal, structured classification and labeling system for chemicals.

GHS: sensible metrics for hazardous chemicals

In this article, we've compiled the top 10 most commonly asked questions about GHS for hazardous chemicals.

1. What is GHS?

GHS is the Globally Harmonized System of Classification and Labeling of Chemicals. Technically, it's called "The GHS," but people often shorthand to just "GHS." In short, the idea is a uniform safety data sheet that simplifies classifying and identifying chemical hazards across borders, from one country to another.

2. What are the benefits of the GHS?

The GHS provides a consistent global framework for classifying and identifying chemical hazards. Different countries will be able to fine-tune the regulation to their specific initiatives by increasing requirements on toxicological thresholds or exposure. A recent article in Industry Week magazine on GHS said it this way: "The goal of the GHS is to provide a consistent global framework for classifying and identifying chemical hazards." The production and use of chemicals is fundamental to all economies. The global chemical business is more than a $1.7 trillion per year enterprise. In the U.S., chemicals are more than a $450 billion business and exports are greater than $80 billion per year.

Chemicals directly or indirectly affect our daily lives. The widespread use of chemicals has resulted in the development of sector-specific regulations (transport, production, workplace, agriculture, trade, and consumer products). Having readily available information on the hazardous properties of chemicals, and recommended control measures, allows safe management of production, transport, use and disposal of chemicals.

Thus, human health and the environment are protected. The GHS will streamline and make a universal standard. Simple. (Right?...)

3. Are all chemicals covered by the GHS?

The GHS covers all hazardous chemicals. There are no complete exemptions from the scope of the GHS for a particular type of chemical or product. The term "chemical" is used broadly to include substances, products, mixtures, preparations, or any other terms that may be used by existing systems. The goal of the GHS is to identify the intrinsic hazards of chemical substances and mixtures and to convey hazard information about these hazards.

4. How will the GHS impact countries without existing regulations?

Developing and maintaining a classification and labeling system is not a simple task. The GHS can be used as a tool for developing national regulations. It is expected that countries that do not have systems will adopt GHS as their basic scheme. The GHS provides the building blocks from which countries can construct chemical safety programs.

5. What are the GHS label elements?

Some GHS label elements have been standardized (identical with no variation) and are directly related to the endpoints and hazard level. Other label elements are harmonized with common definitions and/or principles.

The standardized label elements included in the GHS are:

Symbols (hazard pictograms): Convey health, physical and environmental hazard information, assigned to a GHS hazard class and category.
Signal Words: "Danger" or "Warning" are used to emphasize hazards and indicate the relative level of severity of the hazard, assigned to a GHS hazard class and category.
Hazard Statements: Standard phrases assigned to a hazard class and category that describe the nature of the hazard.

6. What is the GHS Safety Data Sheet (SDS)?

The (Material) Safety Data Sheet (SDS) provides comprehensive information for use in workplace chemical management in a 16 section format. Employers and workers use the SDS as sources of information about hazards and to obtain advice on safety precautions. The SDS is product related and, usually, is not able to provide information that is specific for any given workplace where the product may be used. However, the SDS information enables the employer to develop an active program of worker protection measures, including training, which is specific to the individual workplace and to consider any measures that may be necessary to protect the environment. Information in a SDS also provides a source of information for other target audiences such as those involved with the transport of dangerous goods, emergency responders, poison centers, those involved with the professional use of pesticides and consumers

7. What is the difference between the GHS SDS and existing MSDSs/SDSs?

SDSs are in use globally. So it is useful to have an understanding of the similarities and differences in the existing MSDS/SDS content and format and the GHS SDS content and format. A table comparing MSDS/SDS content/format is provided in Appendix A of one of the OSHA guidance documents.

8. What are some ways I can prepare for GHS?

There are several things you can to do prepare for a GHS implementation. These include: 1)weeding out redundant and outdated documents, 2)setting up process to ensure outreach to suppliers occurs on an ongoing basis, and 3)assembling raw materials in a spreadsheet or database application.

9. What will the cost be?

OSHA estimates that in safety data sheet review, standardized data sheets would save 2.5 to 4 hours per review. OSHA further estimates the average salary of the person reviewing the SDS to be $47/hour. If your department reviews an average of three SDSs per day, that's a $141 savings each day, and $36,660 each year. You would have to do the math for your organization, but in SDS review alone GHS conversion provides immediate ROI. (source: IndustryWeek, article sourced above.)

Also, special to this blog, OSHA provided a table of net GHS costs to benefits. The net monetized benefits are estimated to be $754 million annually -- which according to these numbers are an 8-to-1 ROI.

10. Does the GHS address training?

The GHS states, in Chapter 1.4, Section1.4.9, the importance of training. The goal of training is that all target audiences know how to recognize and interpret label and/or SDS information, and to take appropriate action in response to chemical hazards. Training requirements should be appropriate for and commensurate with the nature of the work or exposure.

Key target audiences include workers, emergency responders and also those responsible for developing labels and SDSs. To varying degrees, the training needs of additional target audiences have to be addressed. These should include training for persons involved in transport and strategies required for educating consumers in interpreting label information on products that they use.

-- Adam Baer
Guest blogger Adam Baer authors (M)SDSs and manages (M)SDS data and related compliance information on a daily basis. He graduated from the University of Maine with a B.A. in Journalism. Contact him at abaer@actio.net.

June 14, 2010
Top 10 Q&A about electronics and RoHS environmental compliance: RoHS is a directive based in the United Kingdom that has shaken up the global electronics industry. In short, RoHS insists that substances of very high concern -- like cadmium, lead, and mercury -- not be used in the manufacture of electronics and electronic devices. RoHS was fully implemented by the European Union (EU) in 2006.

Overall, the list of chemical and product regulations affecting the electronics industry continues to grow in 2010. For some companies, compliance is for Corporate Social Responsibility, or "CSR," also known as "good PR." These regulations also effect consumers, that is, anyone looking to dispose of or recycle a device such as an iPhone or a pair of headphones or a vault full of high-tech servers and other hardware. Software tools for RoHS compliance include BOMtracker from Actio and similar, fledgling products from PTC.

The fact is: complying with product regulations and materials disclosure is because of tightening industry standards, government regulations, regional laws, and directives. Major examples of these include: regulations such as REACH (see REACH Top Ten Q&A about REACH here), TSCA mandates under the new EPA, electronics industry directives such as RoHS and WEEE, and new IPC standards. These are changing how products are made and how materials data is tracked. We've discussed RoHS previously in this blog. Here we're looking at the top 10 questions we encounter about RoHS and the electronics industry.

RoHS is a directive, not a regulation. A regulation is a law that is immediate and universal across all participating entities in the EU. A directive is a legislative act which requires member states to achieve a particular result without dictating the means of achieving that result. This means it's a law but there can be differences in how the law is carried out. Directives typically leave member states with a certain amount of leeway as to the exact rules to be adopted. Both immediately apply to anyone who wants to sell in the EU, import from the EU, or manufacture in the EU.

1. What does RoHS stand for?

RoHS stands for "Restrictions of Hazardous Substances." This is a refreshingly simple acronym in compliance regulations these days (!) so we should pause here to enjoy it.

Now: RoHS restricts the use of six hazardous materials (cadmium, lead, mercury, plus the three usual suspects) in manufacturing various types of electronic and electrical equipment. Specifically: RoHS bans placing on the EU market: new electrical and electronic equipment containing more than agreed-upon levels of lead, cadmium, mercury, hexavalent chromium, polybrominated biphenyl (PBB) and polybrominated diphenyl ether (PBDE) flame retardants.

2. How do you pronounce RoHS?

In real life, RoHS is pronounced in as many ways as you can think of. But the favored pronunciation in the U.S. tends to be either "ross" or "rose." Stick with rose. (No pun intended.)

3. Is RoHS connected to WEEE, the electronics-recycling directive?

Yes. RoHS is closely linked with the Waste Electrical and Electronic Equipment Directive (WEEE) which articulates collection, recycling and recovery targets for electrical goods. WEEE is part of the EU legislative initiative to solve the problem of huge amounts of toxic e-waste.

4. Are solar panels and wind turbines within the scope of RoHS?

On June 2, 2010, windmills and solar panels were deemed "excluded" from a RoHS recast. Here's the thinking behind that decision: RoHS is primarily aimed at curbing the use of toxic chemicals in consumer goods, e.g., household electric and electronic goods. The European Parliament's environment committee amended a proposal on the recast Directive on the Restriction of Hazardous Substances in electrical and electronic equipment (RoHS).

The hope of the recast was to widen the RoHS directive's scope from household appliances to all electrical and electronic devices, unless specifically excluded. But the prospect of a more open scope had made renewable energy producers anxious. Understandably, they were concerned about being subjected to legislation that the fossil fuel industry would not have to comply with, putting them at a competitive disadvantage. For more information on the specifics, we recommend www.euractiv.com.

Currently, solar-powered equipment is still considered to be within the scope of RoHS. It falls under one of the general categories. (The solar component within the equipment is considered exempt.) But, for example, a solar-powered calculator would be in scope of RoHS. Expect updates around this subject, though.

5. Should companies place a mark or seal on a product to show it complies with RoHS Regulations?

There is no obligation or standard marking to show RoHS compliance, but consider showing your compliance anyway to make everything easier for import/export and going-to-market. For compliance with the WEEE Directive, however, a ‘crossed out wheeled bin’ symbol must be used. Get extra help on that here: http://www.weeeregistration.com/ As far as a RoHS-approved "Certificate": there is a requirement in the UK that an EEE product ‘producer’ has documentation to demonstrate compliance. Therefore there is no expiry time or other prescribed approaches to the format of certificates.

Please read Annex D of this document.

6. Does packaging used for a product need to comply with RoHS regulations?

No. But yes. :) Any packaging that is discarded after purchase of the product is not considered to be part of the EEE and therefore does not fall within the scope of the RoHS regulations. However, compliance of a case or packaging that forms part of, or may stay with, the product and may be disposed of with the product may need to comply; this must be judged on a case by case basis. Think of a sticker commonly left on the bottom of a laptop, for instance. Or a special piece of packaging attractive to children that a child wants to keep.

Industry intelligence will advise that packaging suppliers and users be sensible: know what's in your packaging. Declare -- or be ready to declare -- anything that remotely smacks of cadmium, lead, mercury or the other three primary suspects in the RoHS case. Remember, suppliers can pass you cadmium in paint -- packaging companies and customers must be on top of their ingredients.

7. What are the rules regarding repairing a product placed on the market prior to 1st July 2006?

The RoHS Directive does not apply to spare parts for the repair, or reuse, of electrical and electronic equipment placed on the market before 1st July 2006. This is so that old equipment can be maintained with spare parts and to promote the reuse of old electrical and electronic equipment.

It is permissible to place on the market spare parts - containing the hazardous substances - for the repair of old equipment (if the latter was put on the market before 1st July 2006). But it is not permissible to repair new equipment (put on the market after 1st July 2006) with spare parts containing hazardous substances. The marketing of spare parts containing banned substances for the repair of new equipment would prolong the existence of hazardous substances in the waste stream and hamper efforts to increase recycling.

8. Are LEDs within the scope of RoHS?

No, but the product containing an LED is within the scope.

LEDs sold individually are considered to be components rather than an electrical product and therefore are not within the scope of RoHS. However, when being used as part of electrical equipment, LEDs do fall within scope and therefore should be compliant. For instance, an LED lamp is covered by the Directive. Starts to make sense, doesn't it.

If not, you may need to contact an expert -- or review the gory details yourself (see #10 below) but it isn't always pleasant reading and has a similar hue to the U.S. OSHA Federal Registers.

9. Can a company continue to manufacture items it was manufacturing before 1 July 2006 without modification?

No. Any item of electrical or electronic equipment covered by the RoHS scope that is placed on the EU market from 1 July 2006 will have to comply, regardless of whether it is one of a line of products that existed before that date. No grandfather clause, sorry.

10. Where can I find all the (more) gory details?

There is more information to be found on Wikipedia of course, and here and here:
RoHS Directive: http://www.rohs.gov.uk/Docs/Links/RoHS%20directive.pdf
WEEE Directive: http://www.rohs.gov.uk/Docs/Links/WEEE%20directive.pdf

(all images courtesy of photos8.com)

June 10, 2010

Top Ten Questions and Answers about REACH Regulation Compliance

In over a decade of intense involvement with the chemical and substance-level environmental compliance and with over 25 years of chemical engineering savvy on our advisory board, we've seen a lot of questions asked and answered about different regulations. We thought we'd compile the Q&A Top Ten on Europe's REACH regulation.

1. What is REACH?

REACH stands for the Regulation for Registration, Evaluation, Authorization and Restriction of Chemicals. The REACH Regulation really became firm on June 1, 2007 and is still rising to its crest. The idea behind REACH is to streamline and improve the former legislative framework for chemicals of the European Union (EU). (We are on the verge of similar legislation in the United States so it's critical that we all pay keen attention to REACH.)

REACH Regulation spawned an agency for the occasion: the European Chemicals Agency (ECHA). ECHA has a central coordination role in the REACH process. Headquartered in Helsinki, Finland, ECHA's mission is "to manage the registration, evaluation, authorization and restriction processes for chemical substances to ensure consistency across the countries in which REACH applies."

There's lots of information about REACH on the ECHA web site. And while they do try admirably to communicate a lot of complicated information, it is sometimes confusing. So don't get frustrated. Keep digging around the site if you like: here is a good start. Note: sometimes its best to retain a third-party with expertise and knowledge on chemical and substance regulations. To minimize the headaches.

A web page such as http://www.reachtracker.com is also a good place to start for compliance info. Here's why: if you know what bullet-points leading solutions-providers are offering in REACH software tools, then you'll know what is typically needed for compliance. From there, how you get to compliance is up to you.

2. Who can I contact with questions on REACH?

For assistance and information on REACH, try:

National helpdesks established in each country of the European Economic Area (EEA). They provide services in their local language(s) and know the national conditions (e.g. national legislation, organisation of enforcement authorities, etc.). The list of contact details of the national REACH helpdesks is available.
Experts in blanket solutions can help. Blanket solutions are usually technology solutions that work for mid-to-large sized manufacturing companies. They are for-profit companies who are invested in making REACH work for companies whose wares and supply network demand a more robust, defensible solution. This article, Lowering REACH Compliance Pains at Stanley Works, profiles such third-parties. A company with a lot of experience in international environmental regulations can help. Actio Corporation is one such company.
There are also trade associations, sector groups, chambers of commerce and other organizations set up for REACH; these are often more familiar with sector-specific terminology, e.g. plastics, minerals, mineral oils, paints.
ECHA provides assistance particularly to those companies that are registering substances who have questions on REACH provisions and on technology ECHA provides for REACH.

3. Does REACH apply to substances (solo, in mixtures, or in articles) manufactured or imported in volumes below 1 tonne per year?

Yes, is the short answer. Sometimes. There are several obligations under REACH. Registration requirements only apply to substances that are manufactured or imported in quantities of 1 tonne or more per year per registrant. However, if a substance is manufactured or imported at less than 1 tonne per-year-per-registrant, other obligations under REACH may still apply. These obligations, which may apply irrespectively of the volume, include obligations concerning: a) use of the substance, b) restrictions, c) authorizations and d) communication in the supply chain. A typical example is the provision of safety data sheets.

4. Do substances at nano-scale fall under the scope of REACH?

Yes, they do. Nanotechnology is evolving, of course. The health and environment properties of all substances must be assessed according to the provisions of the REACH Regulation. Potential registrants should first consider whether they have obligations under REACH irrespective of the particle size of the substances. Then, further investigation of the detailed provisions of REACH may indicate that different provisions apply according to the hazard properties associated with the particle size of the substances.

The evolving science of nanotechnology may necessitate further requirements in the future to reflect the particular properties of nano-particles.

5. Who has to register substances?

Registration must take place when a person who is the member of the EEA:
(1) manufactures a substance within the EEA in quantities of 1 tonne or more per year
(2) is responsible for import into the EEA of quantities of 1 tonne or more per year or
(3) has been appointed as an only representative according to Article 8 of the REACH Regulation
The national law of each country provides the specific provisions concerning natural or legal personality and when such a natural or legal person is established in its territory. Check with the associated helpdesk if confused and if trying to manage the project yourself.

6. Do I have to register alloys?

This is an interesting question to because of the answer. It has to do with mixtures or chemical cocktails. REACH documentation refers to alloys as "special mixtures". This means an alloy is to be treated the same as other mixtures under REACH. Specifically, the alloy is not subject to registration, but the alloying elements (e.g. metals), irrespectively of the alloy production process, are subject to registration.

A note, however: components which are not important for the properties of the alloy should be considered as impurities (i.e. they are part of a substance in the mixture) and therefore need not be registered separately. This is a loophole that can require expert insight.

Skip to the next paragraph unless really interested in alloys: The REACH documentation cautions that inter-metallic compounds are often wrongly regarded as alloys. Such substances are listed in EINECS (e.g. "aluminium, compound with iron (1:1)", "iron, compound with titanium (2:1)", etc.). These cannot be regarded as mixtures. Therefore these intermetallic compounds have to be registered as substances. This means that e.g. separate (pre-)registrations of the substances Al and Fe do not cover the substances "aluminium, compound with iron (1:1)" or "aluminium, compound with iron (1:3)". For each intermetallic compound with a different metal ratio a separate (pre-)registration is required. As substances, not alloys.

7. Can downstream users continue to use a substance, if it has not been (pre-)registered?

Downstream users can use substances regardless of whether they have been (pre-)registered or not. In this regard, "use" means any processing, formulation, consumption, storage, keeping, treatment, filling into containers, transfer from one container to another, mixing, production of an article or any other utilisation. Placing on the market is however not regarded as a "use". You may want to contact a helpdesk for explanation of the need for substances to be (pre-)registered in order to be placed on the market.

Please note that for the use of substances (whether (pre-)registered or not) certain requirements related to restrictions, authorization and risk management may apply. Guidance on how to comply with these requirements is provided in the Guidance for downstream users

8. Are any substances already subject to authorization?

No, not yet. Back on June 1, 2009, ECHA submitted its first recommendation of priority substances (from the candidate list) to be included in Annex XIV of the REACH Regulation. This first recommendation contains seven substances.

9. Where do I find the SVHC candidate list for authorization?

The candidate list of substances of very high concern (SVHC) for authorisation is available on ECHA's website - find it if you can and good luck! We provided it below for reference. Note: the first 15 substances were included in the candidate list on 28 October 2008. Additional substances will regularly be included in the candidate list after being identified as SVHC.

10. What substances exactly are currently on the list of SVHCs?

Here is a good overview of SVHCs on Wikipedia.

To review the current list of SVHCs, please click here: current list of SVHCs. List is current and accurate. For more information, please contact us. Or should we say: reach out to us? Couldn't resist.

Cheers.

June 8, 2010
Toxic cadmium served in a 'Shrek' glass is a supply chain communication problem: In recent news, McDonald's recalls over 12 million "Shrek" movie glasses because of toxic cadmium in the paint. Each glass would have sold for $2. This is a supply chain communication problem. There are solutions on the market for supply chain communication regarding toxic substances -- this blog discusses them in detail often, for example, here and here. Toxic substances such as cadmium, lead, and mercury are known as substances of very high concern or SVHCs. Best practices for companies seeking to avoid recalls because of SVHCs are here, in this article online called Material Disclosure Best Practices.

Can Product Stewardship Help?

Thousands met in Denver last month to confer on subjects of Industrial Hygiene and Chemicals in Manufacturing. And last March, Maine passed the first Product Stewardship framework law in the U.S. Product stewardship laws typically intend to shift the fiscal and physical burden of dealing with hard-to-recycle products away from local communities and toward producers and their suppliers. These laws also tend to shift the burden toward consumers and others who benefit from products sold and used. So how do you recycle a paint can? Stay tuned - it's not easy now and it won't get easier. The measure might inspire consumers towards greener -- and easier to dispose of -- products.

Maine Governor John E. Baldacci signed the "Provide Leadership Regarding the Responsible Recycling of Consumer Products" Act on March 11. Under this law, producers are required to file and implement product stewardship plans, detailing the collection, transportation, reuse and recycling or disposal of their end-of-life products. A state agency has been given authority to determine which product categories will fall under the new law. The following products have been highlighted for legislation on product-specific producer responsibility:

* Paint
* Lighting
* Household Battery
* Carpet

Pending California law will require a carpet producer or carpet stewardship organization to submit a plan, and a report on the plan annually thereafter, to the Department of Resources Recycling and Recovery (Calrecycle) California.gov

Other Green Industry News Of Interest

Report: Ohio positioned for green jobs Dayton Daily News
Nylon Carpet Recycler Revs Up in Delaware Plastic News
Utah scientists invent chemical to stop anthrax ABC News
With Solar Valley project, China embarks on bold green technology mission? Washington Post

June 3, 2010

Top 5 Questions About Web-based (M)SDS Management

With environmental issues and safety concerns on the rise, companies now face a dual challenge of mitigating risk to employees while reducing the high costs and complexities of Environmental, Health & Safety (EHS) compliance management. A Material Safety Data Sheet, called an "MSDS" or sometimes just "SDS," contains critical safety information. When considering a switch to computerized, web-based, on-demand (M)SDS management, many companies want to know the benefits. Five commonly asked questions are:

1. How/where are my MSDS stored?

(M)SDS and related data are stored as content in a secure data warehouse. MSDSs are not stored as .pdf documents – instead, uniform sections of the document are broken up and stored in a relational database. This method has been proven, trusted and implemented since 1999. Tip: check web-based MSDS management companies for the SAS-70 seal - this ensures the provider's system and their processes have been certified by a third-party auditor. The seal should be right on the web site.

The SAS-70 seal

2. How will my employees access the (M)SDS?

Easy: all that's needed is internet access. By strict username and password protocols, all employees have access to a centralized (M)SDS library. The extensive, up-to-date library provides permission-based access 24 hours a day, seven days a week.

3. Will this make my EH&S regulation reporting easier?

Yes. State-of-the-art search and analysis capabilities ensure your auditable and defensible EHS compliance reporting.

4. What about my multi-format (M)SDS?

No problem. You’ll get support with a variety of (M)SDS formats such as: GHS (Global Harmonized System), GHS Japan and Australia, ANSI, and WHMIS.

5. Will we be going paperless?

Although OSHA permits “paperless compliance,” a hardcopy of the (M)SDS must be readily accessible to all employees and emergency response personnel if needed. Because of this, back-ups in case of emergency are recommended. However, you’ll find that employees rarely need them or want the extra baggage when they can just access the material online.

Additional information can be found at this Outsourcing MSDS Management (Show Me the Money!) page.

Guest blogger Adam Baer:

Guest blogger Adam Baer authors MSDSs and manages MSDS data on a daily basis. He graduated from the University of Maine with a B.A. in Journalism. Contact him via khurley@actio.net.

June 1, 2010

EPA says chemical-ingredients no longer confidential (as of August 25, 2010)

Starting August 25th, Environmental Protection Agency (EPA) will likely reject all confidentiality claims for chemical identity in health and safety studies.

This is tremendous news for anyone interested in chemical information disclosure. Please feel free to contact us for more information.

Blog-Advisor Kal Kawar, PE, CIH

The Big Picture
EPA announced last week that companies making confidentiality claims should expect a letter from EPA denying such claims. EPA expects to begin reviews of confidentiality claims — both newly submitted and existing claims — in accordance with this guidance on August 25, 2010.

This newsflash is of particular interest for those who manufacture (defined by statute to include import) and/or process chemical substances and mixtures subject to TSCA (15 U.S.C. 2601 et seq.) Also, companies identified by the North American Industrial Classification System (NAICS) codes 325 and 32411 are likely to be affected. However, EPA has not attempted to describe all the specific entities that may be interested in this action.

EPA will begin a general practice of reviewing confidentiality claims for chemical identities in health and safety studies, and in data from health and safety studies, submitted under the Toxic Substances Control Act (TSCA).

Supply Chain Engagement?
Professional Chemical Engineer and Certified Industrial Hygienist Kal Kawar says, “Supplier engagement can be further elevated by having functional groups other than Environmental Health and Safety or EHS involved.”

How it can actually work: “Purchasing, supply chain, and product stewardship must work together. With the right software, the inter-departmental work-flow can be automated and monitored from any computer or mobile device with a browser and the right network security clearance.”

Regulatory Loopholes?
TSCA does not extend confidential treatment to health and safety studies, or data from health and safety studies, which, if made public, would not disclose processes used in the manufacturing or processing of a chemical substance or mixture; or, in the case of a mixture, the release of data disclosing the portion of the mixture comprised by any of the chemical substances in the mixture. Where a chemical identity does not explicitly contain process information or reveal portions of a mixture, EPA expects to find that the information would clearly not be entitled to confidential treatment.

This builds on similar efforts regarding confidentiality of chemical identities listed on the public version of the TSCA Chemical Substances Inventory (TSCA Inventory) and submitted in notifications pursuant to TSCA section8(e), discussed in the Federal Register of January 21, 2010.

Comments?
Though EPA is not required to solicit comment for this action, comments received before this date will inform these reviews. ADDRESSES: Submit your comments, identified by docket identification (ID)number EPA–HQ–OPPT–2010–0446, by one of the following methods:

Federal eRulemaking Portal: http://www.regulations.gov. Follow the on-line instructions for submitting comments. Do not submit information that you consider to be CBI or otherwise protected through regulations.gov or email. The regulations.gov website is an ‘‘anonymous access’’ system. This means EPA will not know your identity or contact information unless you provide it in the body of your comment. Direct your comments to docket ID number EPA–HQ–OPPT–2010–0446. EPA’s policy is that all comments received will be included in the docket without change and may be made available on-line at http://www.regulations.gov. The complete story on how to submit comments is here, in the Federal Register.

More Info?
Many companies are already implementing tools to manage chemical and material disclosure / regulatory information – see the Actio product here, for instance, and try a Google search on “Material Disclosure.” This will get you started finding related tools to manage materials information at the substance – or granular – level. For product information, contact Chris Nowak, Director Client Services, Actio, 30 International Drive, Portsmouth, NH 03801; telephone number: (866) 522-8102; email address: cnowak@actio.net.

For technical information, contact: Scott M. Sherlock, Environmental Assistance Division, Office of Pollution Prevention and Toxics, Environmental Protection Agency, 1200 Pennsylvania Ave., NW., Washington, DC 20460–0001; telephone number: (202) 564–8257; e-mail address:sherlock.scott@epa.gov.

For general information contact: The TSCA-Hotline, ABVI-Goodwill, 422South Clinton Ave., Rochester, NY14620; telephone number: (202) 554–1404; e-mail address: TSCAHotline@epa.gov.

Background

What is “Confidential Business Information” (CBI)? According to the EPA web site, as it stands now, submitters may claim confidentiality for proprietary information within a Toxic Substances Control Act (TSCA) submission -- but should submit a detailed written explanation to substantiate all confidential business information (CBI) claims. Also, submitters must submit a sanitized or "cleaned-up" (think crossed out sections of CIA docs) copy of the submission (with confidential information deleted) for placement in the TSCA Public Docket.

On January 21, 2010, as part of EPA Administrator Lisa P. Jackson’s commitment to strengthen and reform chemical management, EPA announced a new policy to increase the public’s access to information on chemicals. Starting in January, EPA put forth its intention to reject a certain type of confidentiality claim, known as Confidential Business Information (CBI), on the identity of chemicals. Read the backstory. (The ACC responded here.)

Summary
Starting August 25th, EPA will review all confidentiality claims for chemical identity in health and safety studies. EPA announces to companies making confidentiality claims that they should expect to get a letter from EPA denying such claims.

Richard Denison, a Scientist at EDF.org, wrote a sufficient piece about this if you get a chance. For more information, inquire here with the materials management experts at Actio Corp.

May 27, 2010

Europe's REACH system shuts down May 26

EU REACH regulation news alert:

The current REACH-IT system will be shut down as of 17.00 (EET) 26 May for system maintenance and upgrades.

REACH-IT is a system that allows companies to sign up online and to submit dossiers and other required information on chemical substances to ECHA for REACH compliance. Shut-down time will allow data to be backed up, migrated to the new system, and tested. The new system will go live on Monday 31 May 2010. For further information, go here.

The European Chemicals Agency (ECHA) is an agency of the European Union which manages the technical, scientific and administrative aspects of the famous chemical regulation called REACH. REACH is the Registration, Evaluation, Authorisation and Restriction of Chemicals.

ECHA plans to launch a new version of REACH-IT on Monday, May 31.

OTHER ECHA NEWS

Last week's REACH summit in Helsinki
Last week we posted about the meetings in Helsinki. Followup: the presentations and video recording of ECHA’s Fourth Stakeholders’ Day on 19 May 2010 are available here. Additionally, presentations from Helsinki Chemicals Forum on 20-21 May 2010 can be found here.

Free webinars
A series of webinar recordings has been published. Webinars provide key information to the members of joint submissions on how to prepare registration dossiers in IUCLID 5.2 and to submit to ECHA via REACH-IT technology. Webinars can be found here.

Animal Testing call to action
ECHA calls for information to avoid unnecessary animal testing. Please submit information you have that may help avoid excessive animal testing. All efforts are appreciated -- so thanks in advance to all who participate.

REACH Regulation aims to oversee chemicals after production; this image shows a chemical production plant.

May 24, 2010
Dioxins, triclosan, and chemical management: Skeletal formulas and substituent numbering schemes of dioxin isomers

Dioxin is a general term that describes a group of hundreds of chemicals in the environment, manufactured both by humans and by nature. Dioxins are formed during combustion or burning. Sources of dioxins include commercial or municipal waste incineration; the burning of fuels like wood, coal, or oil; and natural processes such as forest fires.

"Dioxins" more specifically indicates a group of chemical compounds that share certain chemical structures and biological characteristics. Several hundred of these compounds exist and are members of three closely related families: the chlorinated dibenzo-p-dioxins (CDDs), chlorinated dibenzofurans (CDFs) and certain polychlorinated biphenyls (PCBs). The Maine EPA site is a good reference. PCBs are manufactured products no longer produced in the United States.

Know your chemicals

Knowing your chemicals goes a long way towards risk mitigation. Typically in this blog we speak to manufacturers about chemicals and risk mitigation. Now, obviously, it's a deep consumer concern as well.

Manufacturers keep track of their chemicals, substance-volumes and chemical mixtures using technology like this software package from Actio Corp:

Manufacturers are now installing tools to manage chemical and substance production and waste streams (see above). How responsible should consumers expect manufacturers to be? Should every citizen exercise the right to bear a chemical-testing device in their home, to defend home and family? That's not a bad idea -- but is not a complete, or even feasible, solution. Being informed is a strong start for everyone. And while there's a saying, "a little knowledge can be worse than no knowledge at all," think hysteria and misinformation, the public discussion must begin somewhere.

Dioxins in general

The term "dioxin" is commonly used to refer to a family of toxic chemicals that share a similar chemical structure and induce harm through a similar mechanism. Dioxins have been characterized by EPA as likely human carcinogens. They are anticipated to increase the risk of cancer at background levels of exposure. Details can be found on the EPA dioxin page. Nice article recently by Chemical Online.

Dioxins - generally - are formed as a result of combustion processes such as commercial or municipal waste incineration and from burning fuels (like wood, coal or oil). Almost every living creature has been exposed to dioxins (see also G9). Studies have shown that exposure to dioxins at high enough levels may cause a number of adverse health effects.

Health effects?

The most common health effect in people exposed to large amounts of dioxin is skin disease (details here). Other possible effects include excessive body hair and mild liver damage. There is some concern that exposure to low levels of dioxins over long periods (or high level exposures at sensitive times) might result in reproductive or developmental effects. The state of Maine EPA site says, "At extremely low levels, dioxin can alter the way cells grow and develop. Scientists agree that one form of dioxin causes cancer in humans; some chemical forms of dioxin are considered likely to cause cancer."

Notably, the FDA does not recommend personal dioxin testing. Tests for measuring dioxin levels in humans are not routinely available, the FDA says, and laboratories that offer dioxin testing generally do not have the required certification for medical testing. Also: the amount of dioxin in a person’s body is not helpful for predicting or screening disease.

On the FDA Dioxin page, section G12, there is the following question-and-answer:
Q: How can I reduce my personal dioxin levels?
A: eat healthier (!)

Eat less animal fat - because of the high concentrations of dioxins said to be therein - and eat more vegetables and whole grain products.

Well, haven't we heard that before: eat your vegetables and trim the fat. Okay, already! Science and Mom have finally met in the middle.

Dioxins, triclosan, and the Mississippi River

The University of Minnesota study, released this week, examined sediment samples from Lake Pepin, which allowed researchers to analyze the accumulation of pollutants over time. Story is nicely authored by Jon Swedien. The University Water Resources Center published a report.

"Nasty"

Researchers found over the past 50 years dioxins - described by U of M Civil Engineering Professor William Arnold as a "generally nasty (class of) chemicals" - had in all cases decreased, with the exception of those derived from triclosan, an ingredient found in some hand and dish soaps and deodorants.

"These four dioxins only come from triclosan. They didn't exist in Lake Pepin before triclosan was introduced," said Arnold, who supervised the study, in a university press release. Dioxins that end up in the Mississippi by the way of triclosan, an antibacterial agent first added to soaps in 1987, has risen between 200 to 300 percent in recent decades, according to the study.

Just exactly how toxic these four dioxins are or the specific impacts they might have on the environment is not well understood, Arnold said, but because of the nature of the chemicals there is reason to be concerned.

Help on the way...

Over the past decade, EPA and industry have worked together to dramatically reduce dioxin emissions. It is important to note that dioxin levels in the United States environment have been declining for the last 30 years due to reductions in man-made sources.

Notably: dioxins break down very slowly. They are extremely persistent compounds. A large part of the current exposures to dioxins in the United States is due to release of man-made dioxins that occurred decades ago. And, because some instances of dioxins are manufactured by nature, even if all human-generated dioxins were eliminated, low levels of naturally produced dioxins would remain. EPA - with other Gov't departments - is currently looking for ways to further reduce dioxin levels entering the environment and to reduce human exposure. *

Notice: EPA draft dioxin reanalysis report avail for 90-day public review and comment period

as stated in the Dioxin Science Plan and announced in an May 21, 2010 Federal Register Notice. During the review period, EPA has will also announce by Federal Register a public teleconference on or about June 24, 2010, and a public panel meeting on July 13-15, 2010.
The deadline for comments is August19, 2010. More info here.

The Federal Register notes on public comment process are here: http://www.gpo.gov/fdsys/pkg/FR-2010-05-21/html/2010-12280.htm

At the request of Administrator Jackson, EPA is in the process of re-assessing the science on the effects of dioxin, a toxic chemical that is emitted by multiple sources, on the public’s health.

Please submit comments in the approved comment submission format. Comments on the EPA draft dioxin report may be submitted and reviewed using the link. From the site, select Environmental Protection Agency and the keyword EPA-HQ-ORD-2010-0395 (for the docket ID) to comment on this report.

Dioxin report background

In 2003 EPA and other federal agencies developed a set of questions and answers related to dioxins. They have updated them about every year and a half. These materials have again been updated to include more recent information. These questions and answers provide general information on dioxins such as what they are, where they can be found, and major sources of dioxins. They also discuss possible effects of dioxin exposure in humans, include advice about consumption of food that might contain dioxins, and explain the review process for the dioxin reassessment.

* Lurid detail footnote, either fyi or tmi: Not all dioxin compounds have the same risk. Different dioxin compounds have different toxicities and dioxins are most often found in mixtures rather than as single compounds in the environment. The most toxic forms of dioxin are 2,3,7,8-TCDD and 1,2,3,7,8-Pentachloredibenzodioxin. A method has been established for comparing the toxicity of different types of dioxins to the toxicity of 2,3,7,8-TCDD and 1,2,3,7,8-PeCDD and adding together the toxicity of mixtures of dioxins. This method is called the "Toxicity Equivalence" or TEQ.

May 19, 2010

Europe REACH experts put heads together in Helsinki

A big deal in the chemical and environmental landscape: Europe REACH annual Chemicals Forum or Fourth Stakeholders' day opened at 9.00 am local time on May 19, 2010, in Helsinki. Event is available online both live during the event, and afterward, for one year.

How do we safely handle all these chemicals?

The European Chemicals Agency (ECHA) is an agency of the European Union which manages the technical, scientific and administrative aspects of the famous chemical regulation called REACH. REACH is the Registration, Evaluation, Authorisation and Restriction of Chemicals. It's an environmental chemical overseer system meant to keep modern manufacturing non-toxic. ECHA is headed by Executive Director Geert Dancet.

Stakeholders’ Day is held in Helsinki, Finland.

Stakeholders’ Day intends to be a summit of sorts for sharing REACH solutions, case studies, experiences, and lessons. It intends to promote sharing material disclosure best practices in this crucial year for REACH and Classification and Labelling.

Experts from the chemical industry and stakeholders from around come together to discuss issues and best practices. Over 350 people from the EU, Russia, China, Japan, Brazil, India and the United States are participating. This year's Stakeholders’ Day attendees include: chemical industry representatives, NGOs, consumer groups, environmental groups, health based and women’s organisations, and worker representatives. Animal welfare associations are there.

More info:

4TH Stakeholders’ Day Agenda
Live web streaming
4TH Stakeholders’ Day web page
4TH Stakeholders’ Day - Flyer

Please see those links for more information. We'll follow-up on this blog with any breaking news from the event.

May 17, 2010

Health professionals: recalls and materials management - top 3 news bites

Three (3) news items for medical facilities and health professionals -- and of general interest to all:

1. The U.S. FDA is asking health care professionals to help make sure prescription drugs are promoted honestly. The FDA's Bad Ad Program aims to keep drug promotion and marketing truthful.

2. How do health professionals get info on the latest recalls? A tv show on the web is one way. The FDA produces a show with relevant, timely product news. Any one - including you - can tune in any time to find out:

if a certain gauze is defective
what surgical tools have been recalled
what to do with Maalox - and what not to do with it

Or: find out about all three, as in last week's episode.

3. Health care facilities and science centers are finding new ways to handle chemical management and management of hazardous materials.

1. Let's play doctor

A note on drug promotion and disclosure: the pharmaceutical industry spends nearly three times as much on advertising to health care professionals as they do advertising to consumers, according to the Congressional Budget Office. "Ask your doctor" is not a pleasant suggestion at the end of a drug commercial, it's part of the sales cycle. The so-called "Bad Ad Program" is an effort to keep things honest.

2. The FDA recall report

Want to see a news show about recalls in the medical industry? Check out the TV-style episodes from the FDA for patient safety news. This episode features:

- avoiding Maalox Mix-ups: Why using the wrong liquid Maalox product could be harmful… !
- an overview of recalled products (certain mesh, certain instruments, etc).

It's one way medical professionals get news on product recalls -- what not to use, what to use, and how to use it. You can get the same news to keep yourself informed. Just watch the show!

The blurb: FDA Patient Safety News (PSN) is a monthly video news show for healthcare professionals. It covers significant safety alerts, recalls, new product approvals, and offers important tips on protecting patients. Read the complete stories and watch or download the video program at www.fda.gov/psn. The Health Care audience may have already received notification of some of these safety issues through the MedWatch E-list.

Also, many of these PSN stories contain video footage and demonstrations of particular usefulness to clinicians, educators in healthcare facilities. and academic institutions.

3. Chemical management / safety in health care

In most business environments, chemical management is organized by plant locations where chemicals are routinely and predictably purchased and used. In a campus or hospital setting, access to hazardous chemical information is more complicated because of numerous physical locations using a variety of different chemicals purchased by researchers or laboratory personnel on a P-Card. Crucial compliance documents like (M)SDS come in with a shipment and are frequently thrown away or put in the recipient’s file, thereby not providing access according to the requirements of OSHA’s Hazardous Communication Standard.

HazCom

We asked healthcare professionals how they deal with chemical management. Tom Schussler, Director Safety Management at St. Patrick Hospital and Health Sciences Center, put it this way:

"I am the Director of Safety Management at a 214 bed Level II Trauma Center located in Western Montana," said Schussler. "For the past two years we have used Actio Corporation's "MSDS Vault" as our primary means of managing our hazardous material inventory. We have found Actio's product to be state of the art and a pleasure to use. Employee training time, and expense, is minimal."

Is it just a digital, automated service or are there actual people who help you with your account? Turns out each customer has a real person: a Client Services Manager. "The customer service is beyond parallel," said Schussler.

The University of California, University of Iowa, Baltimore-Washington Medical Center, and University of North Carolina are just a few of the academic and non-profit institutions that rely on a similar solution. Available on-demand, around the clock, from any time zone, these centralized (M)SDS libraries provides online access to (M)SDS-compliant documents. All users get instant accessibility and consistency across the organization. It also minimizes distribution costs of this critical HazCom information.

As safety and chemical management edge closer the center spotlight, these programs -- which are actually the safest way to go -- start to look cutting edge. A good example of conservative choices turning out to be innovative, exciting, and market-leading.

More news later this week.

May 14, 2010

Chemical ingredients in Perfume, Fragrances, Cosmetics: Endocrine-Disrupting?

A new analysis reveals that top-selling fragrance products contain a dozen or more secret chemicals not listed on labels.

Okay, trade secrets are allowed. In fact, at a large conference in Denver on May 24th, manufacturing executives will be discussing just that: trade secrets and material disclosure regulation and compliance. Hot topic, timely conference.

Fragrance sprays contain chemicals not listed on labels.

(Photo by Tina Schofield, courtesy Environmental News Service)

Manufacturers' role
According to the report, multiple chemicals in popular men's and women's fragrances can not only trigger allergic reactions but can disrupt hormones. Many substances have not been assessed for safety by the beauty industry’s self-policing review panels.

This is not so "okay."

This is not good news for anybody: not for manufacturers, nor for male or female - adult or child - consumers, nor for health officials, nor for chemical regulatory agencies, like EPA (see TSCA) or the FDA.

At this point, consumers should probably be developing a little common sense about health risks and chemicals.

However, manufacturers, at this point, should also be a little more sensible. They must be prepared for this type of exposure. The way to be prepared is to have reports ready: have ingredient-data available, with CSR reports, and similar ways to show efforts at the very least toward greening in advance of being exposed. Risk management demands it. This is like the Toyota fiasco, where the company should've been ready to show Responsibility efforts. Supply chains can mess up, a manufacturer or distributor may mess up, and an executive board may make some weak choices; but still, ingredients do not have to be invisible in this day and age and manufacturing practices should be defensible.

Which perfumes in particular? The who and what
For this study, the Campaign for Safe Cosmetics, a national coalition of health and environmental groups, commissioned tests of 17 fragranced products at an independent laboratory. Campaign partner Environmental Working Group assessed data from the tests and the product labels. The analysis reveals that the 17 products contained, on average:

Fourteen secret chemicals not listed on labels due to a loophole in federal law that allows companies to claim fragrances as trade secrets. American Eagle Seventy Seven contained 24 hidden chemicals, the highest number of any product in the study.
Ten sensitizing chemicals associated with allergic reactions such as asthma, wheezing, headaches and contact dermatitis. Giorgio Armani Acqua Di Gio contained 19 different sensitizing chemicals, more than any other product in the study
Four hormone-disrupting chemicals linked to a range of health effects including sperm damage, thyroid disruption and cancer. Halle by Halle Berry, Quicksilver and Jennifer Lopez J. Lo Glow each contained seven different chemicals with the potential to disrupt the hormone system.

Hormone disruptors that may play a role in cancer were found in many of the fragrances analyzed for this study. The Cancer Panel report recommends that pregnant women and couples planning to become pregnant avoid exposure to hormone-disrupting chemicals due to cancer concerns. “This monumental study reveals the hidden hazards of fragrances,” said Anne C. Steinemann, Ph.D, Professor of Civil and Environmental Engineering, Professor of Public Affairs, University of Washington.

“Secondhand scents are also a big concern," said Steinemann. "One person using a fragranced product can cause health problems for many others.” Like second-hand smoke.

Additional resources:

FDA has precious little about fragrance regulations
TSCA has nothing on perfumes or fragrance
Actio Corp tracks chemicals, compliance and product ingredients (for manufacturers)
EPA good January blog on fragrances
GC3 (Green Chemistry out of Lowell, MA) is looking into chemicals in cosmetics
Design for Environment (DfE)on fragrances
Environmental Working Group (EWG) (Stacy Malkan, 202-321-6963, stacy@safecosmetics.org)

“Something doesn’t smell right—clearly the system is broken,” said Lisa Archer, national coordinator of the Campaign for Safe Cosmetics at the Breast Cancer Fund. “We urgently need updated laws that require full disclosure of cosmetic ingredients so consumers can make informed choices about what they are being exposed to.”

“Fragrance chemicals are inhaled or absorbed through the skin, and many of them end up inside people’s bodies, including pregnant women and newborn babies,” said Jane Houlihan, senior vice president for research at Environmental Working Group.

Perfumes on display

(Photo by Alastair Dunning, courtesy Environmental News Service)

A recent EWG study found synthetic musk chemicals Galaxolide and Tonalide in the umbilical cord blood of newborn infants. The musk chemicals were found in nearly every fragrance analyzed for this study. Twelve of the 17 products also contained diethyl phthalate (DEP), a chemical linked to sperm damage and behavioral problems that has been found in the bodies of nearly all Americans tested.

The Campaign for Safe Cosmetics is a national coalition of nonprofit women’s, environmental, public health, faith and worker safety organizations. The mission is to protect the health of consumers and workers by securing the corporate, regulatory and legislative reforms necessary to eliminate dangerous chemicals from cosmetics and personal care products.

The mission of the Environmental Working Group (EWG) - says their documentation - is to use the power of public information to protect public health and the environment. EWG is a 501(c)(3) non-profit organization, founded in 1993 by Ken Cook and Richard Wiles.

Sceinceblogs.com writes it up this way: "The President's Cancer Panel (PCP) report is very long (over 200 pages), which is why it's good that the executive summary does a good job of boiling down the vastness of the report into a more digestible chunk. I read the whole thing, but the report started to get repetitive fairly quickly. It begins, as all such reports do, by pointing out the enormity of the cancer problem in the U.S. and then proposes to address the question of environmental influences on cancer...." View the summary.

Is there a solution for manufacturers, suppliers, regulatory agencies, and consumers? There actually might just be.

More will be revealed at the conference in Denver, AIHce 2010, next week. But here's a preview:

Material Disclosure

“Environmental compliance in a supply chain is necessary today for globalization,” said Actio Corporation co-founder and CEO Russell McCann. “Globalizing products requires in-depth knowledge of all raw materials and parts in a finished product – and the status of each in regards to environmental regulations. Risk managers must analyze each component in the Bills of Material or ‘BOM.' They must get this BOM information from suppliers.”

In the past, suppliers have resisted sharing ingredient information because of the threat of losing competitive advantage.

“Suppliers engage in ingredient-disclosure for environmental compliance when a tool enables them to do so,” McCann emphasized. “If suppliers don’t get decent tools for providing compliance information, then manufacturers and customers don’t get decent compliance information; it’s that simple.”

More on tools for material disclosure can be found at www.materialdisclosure.com.

Till next week.

May 12, 2010
Chemical news: substances of very high concern, waste, chemical safety: Breaking REACH chemical news from European Chemicals Agency (ECHA):

5/12/2010
Information needed on two Substances of Very High Concern (SVHCs)
For EU REACH compliance: 2,4-dinitrotoluene and lead chromate
ECHA is looking for information on the uses and releases of two substances of very high concern on the Candidate List - 2,4-dinitrotoluene and lead chromate. The information is needed to help ECHA to judge whether they should be recommended as substances which should be subject to authorisation.
http://echa.europa.eu/doc/press/na_10_23_authorisation_of_two_substances_en_20100512.pdf

5/12/2010
ECHA publishes new guidance on waste and recovered substances
This new guidance is for companies who recycle and recover. Recycled or recovered chemical substances do not necessarily need to be registered under REACH. The guidance provides advice on the obligations under REACH and clarifies the criteria that need to be met in order for companies to benefit from that exemption. Companies who do not fulfil these obligations will have to register their recycled or recovered chemical substances. It also explains their obligation to share information on recycled and recovered substances in the supply chain.
http://echa.europa.eu/doc/press/na_10_22_waste_and_recovered%20substances_20100512.pdf

5/12/2010
The new Chemical Safety Assessment and Reporting tool, Chesar, is now available
Chesar is a tool to help companies to prepare their Chemical Safety Assessments (CSA) and Chemical Safety Reports (CSR) which are required by the REACH regulation for substances manufactured or imported at a volume above 10 tonnes per year.
http://echa.europa.eu/doc/press/na_10_21_chesar_20100512.pdf
Translated versions of press releases and news alerts:http://echa.europa.eu/news/press_en.asp
REACH reporting tools, on a broader scale, include REACHtracker software.

5/11/2010
ECHA calls for information to avoid unnecessary animal testing
http://echa.europa.eu/consultations/test_proposals/test_prop_cons_en.asp

That's the latest Chemical news from Europe.

In the U.S., most chemical news is about the chemicals used to mitigate total disaster from the BP Oil Spill in the Gulf of Mexico. We ran a piece about the oil spill. Otherwise, major press has covered it sufficiently.

If we had to point to one environmental-related article so far this week, it might be this one:

ClimateWire / NY Times got their hands on summary of Senate energy climate bill to be unveiled this afternoon (May 12, 2010): http://nyti.ms/9non60

Let us know if you have any questions or comments.