Safer Products for Washington Rulemaking

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Comment From: American Forest & Paper Associ... (Erin Hall)

9/09/22 @ 12:02 PM
We believe the industry will be able to phase out the use of BPA/BPS in thermal paper by the proposed date of January 1, 2025 without relying on Pergafast 201 as an alternative. This will allow time to develop additional alternative chemistries that ...↓
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Comment From: Glen Raven, Inc. (Heather Covert)

9/06/22 @ 5:08 AM
On behalf of Glen Raven, Inc, I would like to submit our comments on the Preliminary Draft Ruling Language for Safer Products for Washington.
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Comment From: American Apparel & Footwear As... (Nate Herman)

9/01/22 @ 4:11 AM
Please find attached comments from Steve Lamar, President & CEO of the American Apparel & Footwear Association, regarding the Washington State Department of Ecology’s Preliminary Draft Rule Language for a potential new chapter (Chapter 173-337 Washin...↓
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Comment From: Alliance for Automotive Innova... (Catherine Palin)

8/31/22 @ 7:52 PM
Please see the attached comment letter.
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Comment From: American Chemistry Council Nor... (Ben Gann)

8/31/22 @ 4:46 PM
The American Chemistry Council's North American Flame Retardant Alliance (NAFRA) submits the following supplemental comments regarding Washington Department of Ecology's Preliminary Draft Rule as part of Safer Products for Washington. NAFRA previousl...↓
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Comment From: Household & Commercial Product... (Nicholas Georges)

8/31/22 @ 4:11 PM
The Household & Commercial Products Association appreciates the opportunity to provide the attached comments.
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Comment From: American Chemistry Council (Tim Shestek)

8/31/22 @ 3:58 PM
Attached are comments from the American Chemistry Council (ACC) regarding the Dept. of Ecology’s Preliminary Draft Rule language pursuant to the Safer Products for Washington program.
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Comment From: Consumer Technology Associatio... (Dan Moyer)

8/31/22 @ 3:46 PM
Attached is the Consumer Technology Association’s comments on the Preliminary Draft Rule Language for the Safer Products law. 
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Comment From: Toxic-Free Future (Cheri Peele)

8/31/22 @ 3:36 PM
Please find attached TFF's comments on the SPW draft rule. 
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Comment From: Resilient Floor Covering Insti... (John Mavretich)

8/31/22 @ 1:07 PM
Attached please find comments from the Resilient Floor Covering Institute.
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Comment From: Chemical Users Coalition (Lawrence Culleen)

8/31/22 @ 12:57 PM
Please see attached comments of The Chemical Users Coalition concerning the Washington Department of Ecology's Preliminary Draft Rule implementing part of the Safer Products for Washington legislation.
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Comment From: Association of Home Appliance ... (John Keane)

8/31/22 @ 12:23 PM
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Comment From: Whirlpool Corporation (Ross Olchyk)

8/31/22 @ 12:04 PM
Thank you for allowing the Whirlpool Corporation to provide further comments on the Dept. of Ecology's implementation of the Safer Products for Washington Regulatory Program. 
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Comment From: GE Appliances (John Schlafer)

8/31/22 @ 10:44 AM
Please see the attached comments.
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Comment From: Alliance for Telomer Chemistry... (Shawn Swearingen)

8/31/22 @ 10:23 AM
Please find the attached the comment submission from the Alliance for Telomer Chemistry Stewardship (ATCS) on the Preliminary Draft Rule language. 
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Comment From: Can Manufacturers Institute (C... (Derek Swick)

8/31/22 @ 7:41 AM
The Can Manufacturers Institute (CMI) submits the attached comments to the Washington Department of Ecology (“Ecology”) on Ecology’s Preliminary Draft Rule Language for the Safer Products for Washington program's first implementation cycle—in particu...↓
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Comment From: The Japanese electric and elec... (Emi Yamamoto)

8/30/22 @ 7:13 PM
I am Emi Yamamoto, secretariat of JEITA (Japan Electronics & Information Technology Industries Association) and am emailing on behalf of the Japanese electric and electronic industrial associations - JEITA, CIAJ, JBMIA and JEMA*.

This mail is to send ...↓

We have submitted comments on regulatory determinations of Safer Products for Washington published on June 7, 2022 on August 6.
Today we would like to submit comments also for this preliminary report as attached together with comments for final report submitted on August 6.

We would like to express great concerns in the final report as well as this preliminary draft since the policy to regulate organohalogen flame retardants (HFRs) as a class has not changed.
In addition, rebuttable presumption based on elementary analysis in preliminary draft would not only fails to detect the deliberate addition of HFRs, but also poses a heavy burden only on the manufacturer.

We hope these comments would provide substantive information to the draft language on HFRs in EEE that Ecology plans to issue in December.

We sincerely hope to collaborate with Ecology to ensure that the HFRs restrictions are implemented in a manner that reduces risks to humans and the environment while preserving social benefits for the present and future generations in Washington State.
If you have any questions, please let me know without any hesitation.

*Four Japanese Electric and Electronic Industrial Associations are as follows:
JEITA (Japan Electronics & Information Technology Industries Association),
CIAJ (Communications and Information Network Association of Japan),
JBMIA (Japan Business Machine and Information System Industries Association) and
JEMA (Japan Electrical Manufacturers' Association).
Attachments:
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Comment From: BSEF (Bernadette Desobry)

8/30/22 @ 4:56 AM
Please find attached the BSEF submission on the recently proposed published Preliminary Draft Rule for Safer Products for Washington, the regulatory program to implement the Pollution Prevention for Healthy People and Puget Sound Act (Chapter 70A.350...↓
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Comment From: American Chemistry Council Hig... (Eileen Conneely)

8/29/22 @ 7:24 PM
Attached please find comments on the Safer Products for Washington Preliminary Draft Rule Language from the American Chemistry Council High Phthalates Panel.
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Comment From: Consumer Brands Association (Jared Rothstein)

8/26/22 @ 6:47 AM
To whom it may concern:

The Consumer Brands Association appreciates the opportunity to provide written feedback on the Safer Products for Washington program's Preliminary Draft Rule Language.

Our comments primarily concern the use of the rebuttal presu...↓

Consumer Brands is concerned that the rebuttal preemption provisions are too vague, and do not provide enough clarity and guidance to industry regarding what specific forms of evidence would be considered a complete submission. It would just be beneficial for Ecology to explain in the rule (or via separate guidance) what consistent evidentiary threshold will be utilized so that all parties have a clear understanding regarding what types of data and information should be proactively retrieved, and to ensure all companies will be held to the same standard and that the acceptance of a rebuttal presumption does not change depending on the size, revenue, product volume, or complexity of the responsible party.

The proposed regulation will present a particular challenge for non-producers that import or distribute product into the state of Washington. Such companies must conduct verification through their supply chains and leverage the producer/manufacturer or ingredient supplier to provide relevant information that will inform any reporting or rebuttal submission to the state. Many brand owners rely upon attestations of compliance from their product suppliers in circumstances such as this, and so it would be helpful for the agency to articulate when such forms are considered acceptable evidence and what specific supporting information would be considered adequate. Furthermore, knowing early what an acceptable rebuttal presumption should look like will greatly assist industry with being able to proactively meet their regulatory obligations. Ecology should consider developing a consistent rebuttal template that would guide companies through providing consistent and relevant information for their specific submissions.

Thank you again for the opportunity for comment, Consumer Brands looks forward to continued engagement throughout this regulatory process. Please do not hesitate to reach out with any questions or for additional feedback.

Respectfully submitted,

Jared Rothstein
Director, Regulatory Affairs
Consumer Brands Association
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Comment From: American Chemistry Council No... (Ben Gann)

8/23/22 @ 7:23 AM
The American Chemistry Council’s (ACC) North American Flame Retardant Alliance (NAFRA) submits the attached comments regarding Washington Department of Ecology’s Preliminary Draft Rule as part of Safer Products for Washington. NAFRA’s comments focus ...↓
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Comment From: The Japanese electric and elec... (Emi Yamamoto)

8/04/22 @ 6:16 PM
I am Emi Yamamoto, secretariat of JEITA (Japan Electronics & Information Technology Industries Association).
I accidentally sent you a comment below with a watermark "DRAFT" in an attached file just now, so I've removed the watermark and resend the co...↓

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I am Emi Yamamoto, secretariat of JEITA (Japan Electronics & Information Technology Industries Association) and am emailing on behalf of the Japanese electric and electronic industrial associations - JEITA, CIAJ, JBMIA and JEMA*.

This mail is to send you our response to the final report on regulatory determinations of Safer Products for Washington published on June 7, 2022.
We would hereby express gratitude to Washington Department of Ecology (Ecology) for years of efforts and leading-edge activities to ensure a clean, safe and sustainable environment for present and future generations. We have been operating our businesses all over the world and are firmly committed to protecting human health and the environment and to complying with chemical substance regulations as defined by many countries and regions.
We shared our concerns to the draft report on regulatory determinations of Safer Products for Washington in January 2022, especially on the draft determination to restrict organohalogen flame retardants (HFRs) as a class in electrical and electronic equipment (EEE) as well as Bisphenols in thermal paper.
It this time, we have thoroughly reviewed the final report and still have the same concerns. We would like to share our recommendations that would allay those concerns.
We hope this letter would provide substantive information to the proposed restriction on HFRs in EEE that Ecology plans to announce in December.

We sincerely hope to collaborate with Ecology to ensure that the HFRs restrictions are implemented in a manner that reduces risks to humans and the environment while preserving social benefits for the present and future generations in Washington State.
If you have any questions, please let me know without any hesitation.

*Four Japanese Electric and Electronic Industrial Associations are as follows:
JEITA (Japan Electronics & Information Technology Industries Association),
CIAJ (Communications and Information Network Association of Japan),
JBMIA (Japan Business Machine and Information System Industries Association) and
JEMA (Japan Electrical Manufacturers' Association).
Attachments: