The Household & Commercial Products Association (HCPA) Finds Deficiencies in Proposed 1-4, Dioxane Alternatives Analysis Threshold (AAT) in California
September 10, 2019
The California Department of Toxic Substances Control (DTSC) is evaluating the potential listing of specific consumer products containing 1,4-dioxane as one or more Priority Products, which would make them subject to the Safer Consumer Products regulations.
Per the DTSC’s 2018-2020 Priority Product Work Plan Implementation Summary of their preliminary findings on 1,4-dioxane in two of the Work Plan’s product categories – beauty, personal care, and hygiene products and cleaning products – “the Safer Consumer Products regulations require DTSC to set an Alternatives Analysis Threshold (AAT) for contaminants such as 1,4-dioxane in proposed Priority Products. When a contaminant is present at concentrations below that threshold, manufacturers are required to submit an AAT Notification instead a full Alternatives Analysis Report. To establish an AAT for 1,4-dioxane, DTSC needs to understand how completely 1,4-dioxane can be removed from products, or from ethoxylated ingredients, using available removal technologies. We must also understand the lowest level that can be reliably detected in products and ethoxylated ingredients.”
The DTSC has held multiple public stakeholder meetings on 1-4, dioxane, including the most recent on August 21 that HCPA attended in person. Considerations for the 1,4-dioxane Alternatives Analysis Threshold (AAT) were discussed.
While HCPA appreciates DTSC’s open stakeholder process, there are a wide range of factors that have not been fully discussed or explored in either the background document or the AAT proposal document. Read our analysis of the deficiencies in the AAT proposal in the comments HCPA submitted to the DTSC on August 30. With the information presented in these comments and our other recommendations completed, HCPA recommends examination of an AAT of 10 ppm for personal care and cleaning products.
Across the country, HCPA has been the voice of the household and commercial products industry on emerging chemical contaminants, such as 1,4-dioxane. The New York legislature proposed an unreasonable threshold for 1,4-dioxane levels in cleaning products, which unfortunately passed in both the Assembly and the Senate. HCPA has worked vigorously with other allied trade associations to educate Governor Cuomo’s office about the misinformation surrounding 1,4-dioxane. As part of this effort, HCPA generated notable media coverage of the issue, including publishing an open letter to Governor Cuomo in the Albany-Times Union. Not only is the 1,4-dioxane residue from cleaning products not the source of Long Island’s polluted groundwater, but also it is important to point out that there will be significant technological and financial challenges to removing 1,4-dioxane from products. In collaboration with allied trades, HCPA submitted a chapter amendment to the bill for Governor Cuomo’s consideration that proposed a 10 ppm limit for 1,4-dioxane, which is in line with other regulations around the world.
Please contact Nicholas Georges, Senior Director, Scientific & International Affairs, at ngeorges@thehcpa.org for additional comments or questions.
The California Department of Toxic Substances Control (DTSC) is evaluating the potential listing of specific consumer products containing 1,4-dioxane as one or more Priority Products, which would make them subject to the Safer Consumer Products regulations.
Per the DTSC’s 2018-2020 Priority Product Work Plan Implementation Summary of their preliminary findings on 1,4-dioxane in two of the Work Plan’s product categories – beauty, personal care, and hygiene products and cleaning products – “the Safer Consumer Products regulations require DTSC to set an Alternatives Analysis Threshold (AAT) for contaminants such as 1,4-dioxane in proposed Priority Products. When a contaminant is present at concentrations below that threshold, manufacturers are required to submit an AAT Notification instead a full Alternatives Analysis Report. To establish an AAT for 1,4-dioxane, DTSC needs to understand how completely 1,4-dioxane can be removed from products, or from ethoxylated ingredients, using available removal technologies. We must also understand the lowest level that can be reliably detected in products and ethoxylated ingredients.”
The DTSC has held multiple public stakeholder meetings on 1-4, dioxane, including the most recent on August 21 that HCPA attended in person. Considerations for the 1,4-dioxane Alternatives Analysis Threshold (AAT) were discussed.
In the DTSC’s Alternatives Analysis Threshold Discussion Proposal, the DTSC is seeking input on an AAT of one parts per million (ppm) in personal care and cleaning products.
While HCPA appreciates DTSC’s open stakeholder process, there are a wide range of factors that have not been fully discussed or explored in either the background document or the AAT proposal document. Read our analysis of the deficiencies in the AAT proposal in the comments HCPA submitted to the DTSC on August 30. With the information presented in these comments and our other recommendations completed, HCPA recommends examination of an AAT of 10 ppm for personal care and cleaning products.
Across the country, HCPA has been the voice of the household and commercial products industry on emerging chemical contaminants, such as 1,4-dioxane. The New York legislature proposed an unreasonable threshold for 1,4-dioxane levels in cleaning products, which unfortunately passed in both the Assembly and the Senate. HCPA has worked vigorously with other allied trade associations to educate Governor Cuomo’s office about the misinformation surrounding 1,4-dioxane. As part of this effort, HCPA generated notable media coverage of the issue, including publishing an open letter to Governor Cuomo in the Albany-Times Union. Not only is the 1,4-dioxane residue from cleaning products not the source of Long Island’s polluted groundwater, but also it is important to point out that there will be significant technological and financial challenges to removing 1,4-dioxane from products. In collaboration with allied trades, HCPA submitted a chapter amendment to the bill for Governor Cuomo’s consideration that proposed a 10 ppm limit for 1,4-dioxane, which is in line with other regulations around the world.
Please contact Nicholas Georges, Senior Director, Scientific & International Affairs, at ngeorges@thehcpa.org for additional comments or questions.