Safer Products for Washington Cycle 2 Draft Priority Products Report public comment

TO: Department of Ecology

On behalf of the Polyisocyanurate Insulation Manufactures Association, attached please find our comments responding to the proposed priority products for Cycle 2 of the Safer Products for Washington Program. The letter speci...↓fically addresses insulation and organohalogen flame retardants. We look forward to working with Ecology as you review the comments and finalize the list of priority products. 

Thank you,

Justin

Ms. Morley:

The Center for the Polyurethanes Industry (CPI) of the American Chemistry Council’s (ACC) submits the attached comments regarding the Washington Department of Ecology’s Draft Identification of Priority Products Report to the Legislature: ...↓Safer Products for Washington Cycle 2 and associated Draft Technical Supporting Documentation for Priority Products: Safer Products for Washington Cycle 2 Implementation Phase 2.

CPI appreciates the opportunity to provide input and looks forward to continuing to engage Ecology on this program. If you have any questions about CPI’s comments, please let me know.

Sincerely,

Jason

Good Afternoon Ms. Kim Morley,

I hope this email finds you well!

Attached, please find the North American Modern Building Alliance’s (NAMBA) comment letter in response to the “Draft Identification of Priority Products Report to the Legislature: Safer P...↓roducts for Washington Cycle 2 Implementation Phase 2” regarding Organohalogen Flame Retardants (OFRs) in insulation materials.

Thank you for the opportunity to provide comment – we look forward to continuing our dialogue with Ecology regarding the specifics of OFRs used in insulation products.

Please feel free to reach out with any questions.

Wishing you and the team a happy New Year!

Warm regards,

Colton

Ms. Morley:

Please see the attached comments from the North American Flame Retardant Alliance regarding the “Draft Identification of Priority Products Report to the Legislature: Safer Products for Washington Cycle 2 Implementation Phase 2” regarding O...↓rganohalogen Flame Retardants in Insulation Materials. Thank you for the opportunity to provide comment; We look forward to additional opportunities during the regulatory process to discuss with Ecology the characteristics of specific flame retardants contained within insulation products.

Respectfully submitted,

To whom it may concern, 

On behalf of the Printing Industries of Washington (WAPrint), please accept the attachment as our formal comments on the Safer Products for Washington Cycle 2 Draft Priority Products Report. 

We look forward to working togeth...↓er, and please don't hesitate to reach out with any questions. 

Cheers, 

Samantha

To Whom It May Concern,

We appreciate the opportunity to comment on the draft of Safer Products for Washington Cycle 2 Priority Products Report. Anchor Packaging is a leader in designing and manufacturing rigid food containers and food service cling f...↓ilm in the USA. We are committed to protecting food and the environment by using materials that reduce food and packaging waste to conserve valuable natural resources. Preserving the taste, temperature, and texture of food is core to who we are. Food waste poses great environmental risk and has far-reaching impacts on our society and planet. Our product portfolio includes cling film used throughout the foodservice industry. Our comments below are directed towards PVC film materials and the vital role the material plays in keeping consumers safe and reducing food waste.

Feedback on PVC Film For Use In Foodservice Operations

• PVC film is a cost-effective, high-performing, and consequently essential foodservice product used universally across foodservice channels including restaurants and grocery
• There are 33k foodservice locations in Washington State (including 22k independent operators).
• 2.3k grocery locations in Washington (1.1k independents)
• 18k restaurant locations in Washington (12.8k independents)
• PVC film’s performance capabilities enable it to improve food safety, reduce food waste, mitigate food deserts, and control costs for both consumers and foodservice operators.
• Improve food safety
• Restaurants and other prepared foodservice operators rely daily on cling film during food preparation to protect food from bacteria and other contaminants.
• Reducing food waste
• PVC film significantly extends retail food shelf life keeping food safe from germs, dirt, and other contaminants.
• PVC film also keeps food visually appealing (for example, by regulating moisture and oxygen transmission to prevent packaged meat from turning gray or darkening). It helps retain the “Bloom” – the red color of meat protein.
• As a result, more food gets eaten, not wasted (this reduced overall system costs and limits the foodservice supply chain’s overall GHG impact).
• Mitigating food deserts
• Longer shelf life enables longer supply chains with greater reach into traditionally underserved areas.
• Importantly, PVC film’s primary retail application protects critical nutritional inputs for consumers: uncooked meat, poultry, fish, and fresh produce.
• Providing cost control for both consumers and foodservice operators
• PVC film helps prevent or reduce spoilage which keeps food costs lower.
• PVC film’s ability to extend shelf life provides a buffer that helps retailers match purchases to sales which also reduces waste-related food costs.
• PVC provides similar performance at a lower cost than PVDC.
• PVC’s superior cling performance (relative to PE films) means less film material is needed for each use further supporting cost control.
• PVC film is a preferred choice for retail foodservice when packaging uncooked meats, poultry, fish and produce on trays at the store or commissary.
• PVC Film is a safe and preferred foodservice packaging option .
• PVC film is the fully polymerized version of the vinyl chloride monomer, has no residual monomer, and is safe to use for food contact & medical applications.
• PVC film carries FDA approval for food and medical contact .
• Medical use includes storing and transporting blood and IV fluids which demands the highest safety levels.
• PVC film stretches better than PE – end users prefer the ease of stretch.
• PVC has better clarity – merchandises food products best.
• PVC Cling Film has better self-adhesiveness than PE Film assuring wrapped products stay wrapped and retain “freshness”.
• PVC film has half the chlorine content as PVDC (the “D” indicates “di-chloride”).
• PVDC’s double chlorine structure, while heavier and costlier than PVC, provides the more robust moisture and oxygen barrier properties required for pre-packaged foods (for example, branded meats and poultry).

For the reasons stated above, PVC film should continue to be a viable material for foodservice operators. If there are any questions or the need for further information please let us know.

Best regards,

Kellie Alvarado

Good morning,

Please see the attached comments from the American Chemistry Council Center for Biocide Chemistries and American Cleaning Institute on the Safer Products for Washington Cycle 2 Draft Priority Products Report. Please do not hesitate to r...↓each out with any questions or comments.

Kind regards,

Anastasia 

Dear Ms. Morley:

Thank you for the opportunity to submit comments on the Washington State Department of Ecology Draft Technical Supporting Documentation for Priority Products: Safer Products for Washington Cycle 2 Implementation Phase 2.Attached are c...↓omments from The Adhesive and Sealant Council (ASC).

Please feel free to reach out to me if you have any questions or if ASC can provide any additional input.

Thanks.

Best regards,

Bill Allmond

Please find attached comments on the proposed priority products for Cycle 2 of Safer Products for Washington. To support the comments, we have also attached an Excel workbook that shows entries from the CSPA database at the product brick level where ...↓synthetic polymers are reported for the presence of both styrene and ethylbenzene.

We will also be submitting these online through the web portal. Please let us know if you have any questions.

Thanks so much for all your work on this topic.

Cheri

Hi Kim and other ECY colleagues:

IN RE opinion: Safer Products for Washington Cycle 2

1st thank you for your leadership and genuine care regarding PFAS safety regulations in our products. Thank you for your kindness by including me and letting my voice...↓ be recognized. Kudos!!! 

ECY has the best Director ever. I love ECY Director Watson. I'm her Erin Brokovich here from AG days. Thanks Laura.

Has anyone done a cross sectional coorlational study with other states, California, per se, to see where they are at, what they have banned, what's working and what's not? That will cut a bunch of fat and time wasted for efficiency. 

Did you know that the World Health Organization, WHO, is resetting their global standards in re: PFAS levels, to be more consistent with USA and EU?

Also, in an unprecented move, the FDA recently hit up EWG for our imput on toxins and chemicals in food, food packaging, plus. I can forward you that email with link to chime in to see the letter to FDA. Deadline is 12/6/24. Just say the word and okie dokie.

I love, love, love the hard work and combined efforts in the ECY draft. I wish we could move quicker. People are getting sick, diseased, debilitated and dying.

We must be more aggressive in protecting all Washingtonians, in recognizing our "sensitive population" because they are vulnerable and naturally more detrimentally affected by PFAS toxins. And the Coho Salmon... our land and waters, our ecosystem that is being poisoned by this.

I'd like to see instead of grandfathering in, like artificial turf, that the businesses have to submit a consideration for exemption; at ECY discretion. No playing footsies. ECY notification letter distributed and failure to coorporate will result in heavy fines. People are fucking dying!!!

While I recognize, it might be a bit more work, (tell Governor Elect Bob to give ECY more $$$), and there are good businesses who care, I also recognize there are also shitty ones who only care about them making profits to line their personal pockets despite PFAS knowledge of harm/death. Opoids, per se.

For further example: Awhile back a few of my activist groups hit up big private business corporations apprising them of PFAS knowledge and giving them notice of opportunity to do right. Some did immediately, some had a phase out plan and the greedy gave us the middle finger. To just grandfather preexisting would let the greedy slide. No way man!

Please feel free to reach out to me anytime if you have more specific questions that you would like me to review in the draft, or whatever, so that together we can ensure Safer Products in WA for all Washingtonians.

Again, I am grateful for everything you have done, are doing, and will continue to do. You are appreciated!

Thank you.

Your Friend,

Elisia Dallüge... Lisa from Moses Lake 

CC: ECY Director Watson (Please Kudos this team. Thanks L!)