California Safer Consumer Products Regulation
Cardno's team of experienced toxicologists, exposure assessors, resource economists, and sustainability specialists are prepared to help companies understand the California Safer Consumer Products (SCP) regulation and conduct thorough and reliable alternatives analyses.
Our services include a review of all chemistries in your product(s), prioritization of chemicals vulnerable to regulatory or supply chain deselection, risk reviews of priority chemicals, alternative analysis, and strategic assistance in evaluating alternatives versus existing solutions.
More specifically, you can tap into the following support:
Understanding of Regulations and Exemptions
The foundation of the SCP regulation is the alternatives analyses process to facilitate the removal of select chemistries from the marketplace. However in lieu of that, Cardno is adept at advising as to the costs, benefits, and feasibility of four other options including 1) remove the product from the stream of commerce in California, 2) remove the chemical from the product with no substitute, 3) replace the product-chemical combination or 4) conduct a threshold analysis to demonstrate that the chemical is present below the chemical-specific threshold.
Identification of Target Chemicals
Cardno can assist in the development of chemical inventories for all product ingredients. These should be compiled as a basis of comparison against the SCP chemicals of concern and the priority product combinations. In addition, we can identify chemistries which may receive future regulatory scrutiny, enabling effective risk management.
Investigation of Viable Alternatives
An appropriate alternative must first meet the function and performance of the chemical for which it is replacing. Therefore, viable alternatives must first be screened for effectiveness, then for their potential for risk in the product.
Toxicological Profiling of Chemicals of Concern and Potential Alternatives
Beyond the identification of viable alternatives for listed chemistries, alternatives should be evaluated for their hazard properties to characterize their toxicity. Cardno’s toxicologists are leaders in the field at providing practical assessments of chemical toxicity in “real world” exposure scenarios.
Product-Specific Exposure Assessments
The potential for chemical release from the product throughout its life cycle must be assessed to demonstrate its acceptability as an alternative. Cardno’s approach to these assessments involves both a qualitative understanding of the potential for release from the product and a quantitative estimate that shows that the chemical exposure does not pose a risk to people and the environment.
Comprehensive Risk Assessments
Both the initial and final alternatives analyses require a quantitative evaluation of the potential adverse impacts of the chemicals of concern and suggested alternatives. Cardno can help facilitate this process through comprehensive risk assessments that incorporate the information obtained from toxicology profiling and exposure assessment.
Final DTSC Report Preparation and Assistance
Cardno can develop the final alternatives analysis report for submission to the State of California. This report must contain not only the comparison of the chemicals of concern and an alternatives’ quantitative evaluation of adverse impacts, but also an evaluation of the alternatives’ acceptability in terms of function and performance in the product, along with economic feasibility. In addition, because this report must become available in the public domain, it is critical to ensure the report does not divulge sensitive competitive information or trade secrets related to the formulation of the product.