California releases draft Alternatives Analysis guidance under Safer Consumer Products program.

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Today, California’s Department of Toxic Substances Control (DTSC) released the first part of draft guidance on conducting Alternatives Analysis (AA) under the state’s Safer Consumer Products (SCP) program.

The Draft Stage 1 Alternatives Analysis Guide (AA Guide) covers the first of the two stages of the AA process, which entails an initial screening of alternatives and preliminary analysis. During Stage 1, “the responsible entity identifies the goal, scope, legal, functional, and performance requirements of the Priority Product and the Chemical of Concern, and uses this information to identify an array of alternatives to consider.” At the end of Stage 1, the analysis findings, work plan, and implementation schedule are documented in a Preliminary AA Report which is submitted to DTSC.

DTSC reports that a draft guide for Stage 2 will be released in the first quarter of 2016. In Stage 2, the responsible entity follows the Work Plan approved in Stage 1 and conducts an in-depth analysis considering impacts such as life cycle and cost. This process culminates in selecting an alternative and making a regulatory response recommendation.

The Draft Stage 1 AA Guide also notes that companies have alternative compliance options to the AA process if an AA or similar comparative analysis has already been completed, or if the company prefers a different AA approach. After demonstrating to DTSC that the alternate approach is “adequate for evaluating the Priority Product and the alternatives” and “sufficiently equivalent to the AA process described in the regulations,” responsible entities may choose instead to conduct an Abridged AA or Alternate Process AA, or use a previously completed AA.

The draft AA Guide discusses in detail the following topics:

  • Product Requirements and Alternatives – including product function and performance, legal requirements, and the role of the Chemical of Concern.
  • Relevant Factors – how to use an iterative process to identify “relevant factors” used throughout the AA process to characterize, evaluate, and compare impacts of the Priority Product and its alternatives.
  • Impact Assessments – approaches, tools, and information sources a responsible entity may use to conduct analyses throughout the AA process.
  • Screening Alternatives – considerations for and approach to screening, assessing tradeoffs, and conducting limited screens.

DTSC will hold two webinars to discuss the Draft Stage 1 Alternatives Analysis Guide, on October 7 and October 21. The comment period on the Guide runs through October 23, 2015.