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October 12, 2012 05:50 PM

Contact: Brian Sansoni, 202-662-2517 (office) / 202-680-9327 (mobile) or via email at  

ACI: CA ‘Safer Consumer Product Rules’
Would Provide Few Benefits to Consumers

  • Attempts to Implement Green Chemistry Rules Are Unclear, Burdensome

WASHINGTON, D.C., October 12, 2012 – California’s proposed Safer Consumer Product regulations are unclear, would cause confusion in the marketplace, place heavy burdens on business and provide little benefit to consumers, says the American Cleaning Institute (ACI –

In comments to the state’s Department of Toxic Substances Control (DTSC), ACI said that the agency’s latest attempt to enforce a green chemistry law is vague and leaves “many critical details” for future rulemaking.

“While such an approach is not unusual to some extent for regulatory development, the scope in this case is breathtaking, and will result in significant confusion in the marketplace,” said Dr. Paul DeLeo, ACI Senior Director of Environmental Safety.

“Because the regulations contain so many vagaries, the regulated community will not know how to comply.”

In attempting to identify so-called “chemicals of concern,” DTSC says it is targeting roughly 1,200 chemicals.

A review of DTSC’s lists by ACI, however, found they contain over 4,000 chemicals, many of which are not used to manufacture consumer products.

ACI requested that DTSC better articulate how it has determined that there are only 1,200 chemicals on these lists.

ACI also took issue with the Department’s lack of distinction between intentionally-added ingredients and potential contaminants.

“Chemicals which are contaminants serve no useful function in a product,” said DeLeo. “They should not be the subject of an alternatives assessment, and DTSC should not require one in such a situation – it is a poor use of resources for a company to conduct such an analysis and for the Department to potentially review it.”

ACI is also concerned over DTSC’s threshold where an “alternatives analysis” (AA) is required.

“We find it disturbing that the Department proposes this approach even though it acknowledges that the AA Threshold may well be below a level that represents an insignificant or negligible risk, too small to be of concern,” said DeLeo. “It is unclear why the Department would impose such heavy regulatory burdens on companies in cases where it knows there is little or no opportunity to improve public protection or improve environmental quality.”

ACI’s full comments are available at


The American Cleaning Institute® (ACI) is the Home of the U.S. Cleaning Products Industry® and represents the $30 billion U.S. cleaning products market. ACI members include the formulators of soaps, detergents, and general cleaning products used in household, commercial, industrial and institutional settings; companies that supply ingredients and finished packaging for these products; and oleochemical producers. ACI ( and its members are dedicated to improving health and the quality of life through sustainable cleaning products and practices.