Safer Products for Washington- PFAS Draft Regulatory Determinations Report (Cycle 1.5)

Submitted By

129 Results

Search Type

Sort:

Sort Results By

Comment From: Francie Rutherford

1/23/24 @ 1:00 AM

Dear Washington State Department of Ecology, Please ban PFAS in all products to protect drinking water, public health, and wildlife. Ecology’s proposal to ban PFAS in apparel, cleaning products, and automotive washes is a good step forward, but more ...↓

No attachments

Comment From: Toxic-Free Future (Cheri Peele)

1/22/24 @ 6:06 PM

Please see attached comments on the Cycle 1.5 Draft Report.

Attachments:

Download

Comment From: The Cookware and Bakeware Alli... (Fran Groesbeck)

1/22/24 @ 5:19 PM

Attached is our PFAS Document #2 for your consideration.

Attachments:

Download

Comment From: American Apparel & Footwear As... (Steve Lamar)

1/22/24 @ 4:48 PM

Please see attached PDF for AAFA's comments.

Attachments:

Download

Comment From: David Krizan

1/22/24 @ 3:54 PM

Attachments:

Download

Comment From: Association of Home Appliance ... (John Keane)

1/22/24 @ 3:00 PM

Attachments:

Download

Comment From: Public Health - Seattle & King... (Shirlee Tan)

1/22/24 @ 1:47 PM

Attachments:

Download

Comment From: Performance Fluoropolymer Part... (Jay West)

1/22/24 @ 1:44 PM

Please find attached comments from the American Chemistry Council's Performance Fluoropolymer Partnership. Thank you.

Attachments:

Download

Comment From: King County Department of Natu... (Christie True)

1/22/24 @ 1:00 PM

Attachments:

Download

Comment From: Outdoor Industry Association (James Pollack)

1/22/24 @ 10:40 AM

Attachments:

Download

Comment From: Sarah Robinson

1/22/24 @ 1:00 AM

Dear Washington State Department of Ecology, We respect your work to ameliorate harm from toxins, circulating through our environment and, sadly, also through our bodies. We ask for your leadership to reduce the toxic loads we carry in our bodies. Al...↓

No attachments

Comment From: Clayton Compton

1/22/24 @ 1:00 AM

No attachments

Comment From: Barbara Anderson

1/22/24 @ 1:00 AM

No attachments

Comment From: Tanea Stephens

1/22/24 @ 1:00 AM

No attachments

Comment From: Janet Farness

1/22/24 @ 1:00 AM

Dear Washington State Department of Ecology, As a person of faith, I called to support all efforts to steward creation for the good of all creation. Please ban PFAS in all products to protect drinking water, public health, and wildlife. Ecology’s pro...↓

No attachments

Comment From: Derek Benedict

1/22/24 @ 1:00 AM

Dear Washington State Department of Ecology, Please ban PFAS in all products to protect drinking water, public health, and wildlife...and maybe right now? Ecology’s proposal to ban PFAS in apparel, cleaning products, and automotive washes is a good s...↓

No attachments

Comment From: Tracey Wang

1/21/24 @ 1:00 AM

No attachments

Comment From: Giles Sydnor

1/21/24 @ 1:00 AM

No attachments

Comment From: Susan and Peter Risser

1/21/24 @ 1:00 AM

No attachments

Comment From: Jessica Blanch

1/21/24 @ 1:00 AM

No attachments

Comment From: Katherine Tait

1/21/24 @ 1:00 AM

No attachments

Comment From: Naoko Noguchi

1/20/24 @ 1:00 AM

No attachments

Comment From: Rodney Cole

1/20/24 @ 1:00 AM

No attachments

Comment From: Victoria Cole

1/20/24 @ 1:00 AM

No attachments

Comment From: Denise Doherty

1/20/24 @ 1:00 AM

No attachments

Comment From: Terry Nightingale

1/20/24 @ 1:00 AM

No attachments

Comment From: Lin Nelson

1/20/24 @ 1:00 AM

No attachments

Comment From: Christina Manetti

1/20/24 @ 1:00 AM

No attachments

Comment From: Danny Arguetty

1/20/24 @ 1:00 AM

No attachments

Comment From: Irene Bensinger

1/20/24 @ 1:00 AM

No attachments

Comment From: Marguerite Winkel

1/20/24 @ 1:00 AM

No attachments

Comment From: Sarah Spear Cooke

1/20/24 @ 1:00 AM

No attachments

Comment From: Kathryn Lambros

1/20/24 @ 1:00 AM

No attachments

Comment From: Jana Hobbs

1/20/24 @ 1:00 AM

No attachments

Comment From: Kalyn Brady

1/20/24 @ 1:00 AM

No attachments

Comment From: Karen Andrade

1/20/24 @ 1:00 AM

No attachments

Comment From: Stephani Zador

1/20/24 @ 1:00 AM

No attachments

Comment From: Elizabeth Walker

1/20/24 @ 1:00 AM

Dear Washington State Department of Ecology, I am a Washington State Nutritionist with a PhD. I know that PFAS chemicals are harmful, especially to children. Please ban PFAS in all products to protect drinking water, public health, and wildlife. Ecol...↓

No attachments

Comment From: PJ Phillips

1/20/24 @ 1:00 AM

No attachments

Comment From: Jen McGill

1/20/24 @ 1:00 AM

No attachments

Comment From: Doug Faust

1/20/24 @ 1:00 AM

No attachments

Comment From: Michael Siptroth

1/20/24 @ 1:00 AM

No attachments

Comment From: Bridget O'Brien

1/20/24 @ 1:00 AM

No attachments

Comment From: Erik LaRue

1/20/24 @ 1:00 AM

No attachments

Comment From: Barbara McMichael

1/20/24 @ 1:00 AM

Dear Washington State Department of Ecology, Please move forward urgently with bans on PFAS-containing products! I'd like to see a ban on PFAS in all products to protect drinking water, public health, and wildlife. Ecology’s proposal to ban PFAS in a...↓

No attachments

Comment From: Rona Frimmer

1/20/24 @ 1:00 AM

No attachments

Comment From: Sina Case

1/20/24 @ 1:00 AM

No attachments

Comment From: Donna Musgrove

1/20/24 @ 1:00 AM

No attachments

Comment From: Barbara Blackwood

1/20/24 @ 1:00 AM

No attachments

Comment From: Dana Fontes

1/20/24 @ 1:00 AM

No attachments

Comment From: Charlene Donovan

1/20/24 @ 1:00 AM

No attachments

Comment From: Gill Fahrenwald

1/20/24 @ 1:00 AM

No attachments

Comment From: Joan Poor

1/20/24 @ 1:00 AM

No attachments

Comment From: Patricia Coffey

1/20/24 @ 1:00 AM

No attachments

Comment From: Katherine Carvlin

1/20/24 @ 1:00 AM

No attachments

Comment From: Nova Berkshires

1/20/24 @ 1:00 AM

No attachments

Comment From: Izaak Koller

1/20/24 @ 1:00 AM

No attachments

Comment From: Seth Rolland

1/20/24 @ 1:00 AM

No attachments

Comment From: King County Hazardous Waste Ma... (Maythia Airhart)

1/19/24 @ 4:49 PM

The Hazardous Waste Management Program in King County (Haz Waste Program) thanks you for the opportunity to comment on the Washington State Departments of Ecology (Ecology) draft regulatory determinations for the Safer Products for Washington Cycle 1...↓.5, focused on per- and polyfluoroalkyl substances (PFAS). We very much appreciate Ecology's work to address PFAS in widely-used consumer products, which we see as an important public health and environmental concern.

The Haz Waste Program is a coalition of local governments comprised of King County, the City of Seattle, 37 other cities, and two tribes, all located in King County, Washington. Together the Program serves more than 2.3 million Washington state residents. The Haz Waste Program works to protect and enhance public health and environmental quality. We do this by reducing the threat posed by the production, use, storage, and disposal of hazardous materials, many of which are found in common household products and small businesses.

A primary focus of the Haz Waste Program is toxics in consumer products. We strive to identify effective strategies to reduce exposure to hazardous materials from consumer products among residents and workers and to reduce generation of hazardous waste in our jurisdiction. With this goal in mind, we provide the following comments to the draft regulatory determinations report:

The Haz Waste Program supports the proposed restrictions of PFAS in apparel, cleaning products, and auto washes. Consumer products are one of the most important and largest ongoing sources of PFAS exposure and environmental contamination in Washington State. PFAS is used in many products currently available for sale in Washington, and these products can eventually cause human exposure in homes and businesses and can contaminate our environment and natural resources. At the end of these products' lifecycles, they also contribute to contamination of our waste streams, leaving local governments and utilities to manage these toxic chemicals with corresponding costs and liability. Restricting the use of PFAS in consumer products is the most effective strategy to protect people and environment from this source and is urgently needed in our state, especially when there are existing safer alternatives that are feasible and available in many products currently using PFAS.

Ecology should continue to aggressively use SPWA authority to restrict PFAS in consumer products. With the PFAS-specific "Cycle 1.5" coming to an end, we encourage Ecology to maintain focus on restricting PFAS in additional product categories as the SPWA law is implemented and to continue to investigate the availability of safer, feasible alternatives for product categories in which reporting requirements are recommended in this draft report. Many manufacturers will not voluntarily remove PFAS from their product lines without regulatory pressure, even as our understanding of the significant environmental and public health impacts grows. For example, as shown in the market analysis of the draft report, no outdoor apparel companies have fully removed PFAS despite growing public commitments, underscoring the vital role of regulation.

To accelerate the removal of toxics in consumer products, Ecology should continue to restrict PFAS and other priority chemicals in sub-categories of products when relevant safer, feasible, and available alternatives are identified. Since some product categories are large and diverse, with PFAS and other priority chemicals possibly providing multiple functions, the Haz Waste Program supports Ecology's decision to restrict PFAS in certain sub-categories (e.g., apparel) rather than waiting until alternatives are identified for every single product type within the larger category.

Ecology should clearly explain when certain functions of priority chemicals within a product category are exempted from their evaluations and regulatory determinations, such as the exemption of propellants containing PFAS in cleaning products. Text on page 27 of the draft report states, "We excluded propellants from this analysis because they are used across a variety of product categories, not just cleaning products." We see this logic as a slippery slope since many functions of PFAS and other priority chemicals are likely to be relevant to multiple product categories. By this logic, propellants will never be evaluated because they will always exist in multiple product categories. That would be an unacceptable loophole. We would have liked to see more reasoning for this decision. For example, some estimation of how widely used PFAS is in propellants for this product category (if very few cleaning products contain PFAS from propellants, this would support its exemption). Based on the draft report, we are left wondering whether PFAS will continue to be a source of exposure from cleaning products after the proposed restrictions take place. We also wonder when PFAS in propellants would ever be evaluated, since SPWA is organized by product categories and not functions of the chemicals themselves. That said, we do support Ecology taking regulatory action on surfactants in cleaning products due to adequate availability of safer alternatives. We believe an explanation that Ecology didn't have the time or capacity to evaluate alternatives for this function is reasonable, but, if that was a reason, we'd want that to be explicitly stated.

Ecology should restrict PFAS providing non-stick functionality in cookware. Our understanding is that a significant proportion of available cookware products do not contain any non-stick coating, such as stainless steel or cast-iron pots and pans that can be used with fats/oils to achieve similar non-stick performance. This suggests that PFAS are not necessary to meet non-stick performance requirements of cookware products and provides a rationale for restriction based on criteria set out in the regulatory determinations report for SPWA Cycle 1.[1] People have cooked food successfully for thousands of years before PFAS were invented, and manufacturers still produce and sell PFAS-free cookware. The notion that PFAS is essential to cookware simply strains credulity. While PFAS can also provide chemical and physical durability functions within cookware products, we urge Ecology to specifically restrict PFAS providing a non-stick function in relevant cookware products (e.g., pots, pans, sheets, utensils) this cycle. Other PFAS functions can be exempted from the restriction and evaluated in later cycles.

Ecology should submit more administrative orders to obtain product ingredient information from manufacturers in future SPWA cycles. Obtaining manufacturer data on their usage of PFAS and other priority chemicals in their products is critical for effectively identifying safer, feasible, and available alternatives, and therefore, for the implementation of SPWA. We urge Ecology to increase usage of their authority under RCW 70A.350.030(4) to request data from manufacturers, that is, to promulgate more administrative orders in future SPWA cycles.

Ecology should obtain detailed ingredient information from manufacturers of products that are potentially safer alternatives. As noted in the draft report, Ecology was frequently unable to determine if PFAS-free products met the criteria for being a safer alternative due to lack of detailed ingredient information. This lack of transparency is therefore a foremost barrier to implementing SPWA. In the only publicly available example of an administrative order (i.e., for ortho-phthalates in vinyl flooring products), questions about alternatives that are used was optional. We believe manufacturers should be required to provide this information and, if necessary, Ecology should work to strengthen confidentiality protections for manufacturers such that it lowers the barrier of business-side reporting of these data. At minimum, Ecology should clarify its authority with respect to obtaining data from manufacturers, including data that may be considered confidential business information,

The Haz Waste Program thanks you for this opportunity. If you have questions regarding the comments above, please contact Dr. Trevor Peckham, Environmental Scientist, at tpeckham@kingcounty.gov.

-----------------------------
[1] See Appendix D. Criteria for Feasible and Available in the June 2022 Regulatory Determinations Report to the Legislature Safer Products for Washington, Cycle 1 (Publication number 22-04-018 at https://apps.ecology.wa.gov/publications/summarypages/2204018.html)

Attachments:

Download

Comment From: Amy Kastelin

1/19/24 @ 1:00 AM

Dear Washington State Department of Ecology, Too many people are getting cancer in my life. We know that PFAS are not safe! Please ban them! Please ban PFAS in all products to protect drinking water, public health, and wildlife. Ecology’s proposal to...↓

No attachments

Comment From: Seattle Public Utilities (Andrew Lee)

1/19/24 @ 1:00 AM

See attached letter.

Attachments:

Download

Comment From: National Marine Manufacturers ... (Jeff Wasil)

1/18/24 @ 6:12 PM

The National Marine Manufacturers Association (NMMA) appreciates the opportunity to provide comments regarding report cycle 1.5 Phase 3. Please see the attached comments. Respectfully, Jeff Wasil & Rachel Fischer.

Attachments:

Download

Comment From: Jayme Jonas

1/18/24 @ 1:00 AM

No attachments

Comment From: Crispin Stutzman

1/17/24 @ 1:00 AM

No attachments

Comment From: Leigh Bangs

1/17/24 @ 1:00 AM

No attachments

Comment From: Briana Thiodet

1/17/24 @ 1:00 AM

No attachments

Comment From: Derek Benedict

1/17/24 @ 1:00 AM

Dear Washington State Department of Ecology, Please ban PFAS in all products to protect drinking water, public health, and wildlife...now! Ecology’s proposal to ban PFAS in apparel, cleaning products, and automotive washes is a good step forward, but...↓

No attachments

Comment From: Anastasia Searfoss

1/17/24 @ 1:00 AM

No attachments

Comment From: Lac Mac (Shelley Petrovskis )

1/16/24 @ 2:01 PM

Please see attached the comments of Lac Mac Limited on Washington State's Draft Regulatory Determinations Report to the Legislature.

Attachments:

Download

Comment From: Fran Groesbeck

1/16/24 @ 9:41 AM

Dear Washington Department of Ecology,

My name is Fran Groesbeck. I am the Managing Director for the Cookware and Bakeware Alliance. The Cookware & Bakeware Alliance is a vital housewares trade association, delivering critical industry resources a...↓

Attachments:

Download

Comment From: Janna Rolland

1/16/24 @ 1:00 AM

No attachments

Comment From: Helen Kramer

1/16/24 @ 1:00 AM

No attachments

Comment From: Ev Randles

1/16/24 @ 1:00 AM

No attachments

Comment From: Lorelette Knowles

1/15/24 @ 1:00 AM

No attachments

Comment From: Sean Edmison

1/15/24 @ 1:00 AM

No attachments

Comment From: Kippy Irwin

1/15/24 @ 1:00 AM

No attachments

Comment From: Kirsten McDade

1/15/24 @ 1:00 AM

No attachments

Comment From: Bob Meador

1/15/24 @ 1:00 AM

No attachments

Comment From: Yonit Yogev

1/15/24 @ 1:00 AM

No attachments

Comment From: Marissa Lock

1/15/24 @ 1:00 AM

No attachments

Comment From: J Mcconaughy

1/15/24 @ 1:00 AM

No attachments

Comment From: Linda Lindsay

1/15/24 @ 1:00 AM

No attachments

Comment From: Katherine Brennan

1/15/24 @ 1:00 AM

No attachments

Comment From: Patty Page

1/15/24 @ 1:00 AM

No attachments

Comment From: Jean Sargent

1/15/24 @ 1:00 AM

No attachments

Comment From: Kathy Partida

1/15/24 @ 1:00 AM

No attachments

Comment From: Sadie Holt

1/15/24 @ 1:00 AM

Dear Washington State Department of Ecology, A ban on PFAS is well overdue. It is hurting our salmon and Orca whales. Please ban PFAS in all products to protect drinking water, public health, and wildlife. Ecology’s proposal to ban PFAS in apparel, c...↓

No attachments

Comment From: Carolyn Riddle

1/15/24 @ 1:00 AM

No attachments

Comment From: Kate Kostal

1/14/24 @ 1:00 AM

No attachments

Comment From: Beth Fry

1/14/24 @ 1:00 AM

No attachments

Comment From: E Ellis

1/14/24 @ 1:00 AM

No attachments

Comment From: Ruchi Stair

1/14/24 @ 1:00 AM

Dear Washington State Department of Ecology, I am a mother who knows we must do everything we can to create a liveable planet for the next generation. Please act now to ban PFAS in all products to protect drinking water, public health, and wildlife. ...↓

No attachments

Comment From: Lorraine Johnson

1/14/24 @ 1:00 AM

No attachments

Comment From: Sarah Samnick

1/14/24 @ 1:00 AM

No attachments

Comment From: Esther Kronenberg

1/14/24 @ 1:00 AM

No attachments

Comment From: Karin Olefsky Hargrove

1/14/24 @ 1:00 AM

No attachments

Comment From: Daniel Henling

1/14/24 @ 1:00 AM

No attachments

Comment From: Lemoine Radford

1/14/24 @ 1:00 AM

No attachments

Comment From: Joyce Weir

1/14/24 @ 1:00 AM

Dear Washington State Department of Ecology, Please move forward urgently with bans on PFAS-containing products. Thank you. Sincerely, Joyce Weir

No attachments

Comment From: John Lambert

1/14/24 @ 1:00 AM

No attachments

[ Previous Page / Next Page ]