Model Alternative Assessments
California Regulations and Alternatives Assessment
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New Report (October 27, 2015): Alternatives to Methylene Chloride in Paint and Varnish Strippers: Availability of Safer Alternatives & Requirements for Meeting Stage 1 of the California Safer Consumer Products Regulations. Download the entire Methylene Chloride Alternatives Assessment report
In 2013, California finalized its Safer Consumer Products (SCP) regulations, which establishes a process for evaluating chemicals of concern in consumer products and their potential alternatives. This landmark legislation addresses the critical need to reduce toxic chemicals in consumer products – chemicals that are responsible for known human health and environmental harms. The regulations require “responsible entities” (which includes manufacturers, importers, assemblers, and/or retailers) of a “priority product” (a consumer product containing a chemical of concern) to complete an alternatives analysis to determine whether feasible alternatives are available to minimize public health and environmental impacts.
BizNGO – a collaboration of leaders from businesses, environmental groups, universities, and governments – initiated a demonstration project to a draft priority product under the California SCP regulations: paint and varnish strippers with methylene chloride (also known as dichloromethane). Using the GreenScreen® comparative hazard assessment method, the goals of this demonstration project were three-fold: (1) to identify whether less hazardous alternatives to methylene chloride in formulated paint stripper products are available on the market; (2) to identify candidate alternatives for methylene chloride in paint stripping formulations that will likely be considered in actual/future Stage 1 submissions for this “priority product” in California; and (3) to identify challenges and needs confronting compliance with the alternatives analysis process under the California SCP regulations.
Lesson Learned #1: Information is readily available about functional requirements, performance requirements, and potential alternatives for methylene chloride based paint strippers.
Lesson Learned #2: Safer alternatives to methylene chloride for use in chemical paint strippers are widely available based on assessing the hazards of eleven chemical alternatives.
Lesson Learned #3: The type and range of alternatives to consider should be informed by a business entities’ capacity to adopt those alternatives.
Lesson Learned #4: Whether or not GreenScreen® is sufficient to meet the California SCP regulations concerning hazard assessment criteria remains to be determined.
Lesson Learned #5: When conducting an alternatives assessment on formulated chemical products, the hazards of other chemicals in the formulation should also be considered.