This week, the Washington State Department of Ecology published a list of 59 chemicals of high concern for children. The list was selected from a pool of roughly 2,000 prospective chemicals that are, as ABC News/AP put it, known to:
- cause cancer
- harm fetal development
- influence endocrine systems
Problem is not inside your head
The Department of Ecology is proposing to adopt the Children′s Safe Products Reporting Rule. The proposal notice will be published in the Washington State Register on November 3rd, 2010. The purpose of the proposed rule is to implement the reporting requirements of the Children′s Safe Product Act.
Online comment form is here if you have something to say about it.
Washington law requires that identifiable public records be made available promptly to members of the public for inspection and copying upon request. Some software is available on the market for material disclosure. Only records that are exempt by law may be withheld from disclosure.
Department of Ecology has begun formal rule making to carry out the reporting requirements created by the law. The agency released the proposed rules on Monday, October 25 and expects to finalize them early 2011.
Make a new plan, Stan
The Children's Safe Product Act (CSPA) is part of Washington's greater Reducing Toxic Threats Initiative. It certainly gets media attention. Even though the era of helicopter parenting and "Oh No! Save the schoolchildren from dust-mites!" is mercifully over, and frankly sometimes this sort of billing can seem quite gimmicky, fact is that limiting children's exposure to toxic chemicals will never go out of style.
Washington's Children's Safe Product Act (CSPA) requires that government officials draft a list of chemicals of concern. The current list has 59 chemicals on it. The act requires that if any chemicals from the list of 59 appear in a product, the manufacturer will have to report the presence of the chemical in the product or in the product component.
The Associated Press reported that the Toy Industry Association felt the chemical levels that require reporting might be too low. Here is an interesting letter of response to the initial draft pilot rule of the Children's Safe Products Act (dated January 28, 2010) from the Toy Industry Association; it makes several interesting suggestions, such as ensuring that manufacturers are only responsible for chemicals and substances that are "intentionally" put in products.
Don't need to be coy
Notably, insists the Washington Dept. of Ecology, the mere presence of these chemicals in children’s products does not necessarily indicate that there is a risk of exposure. "When was the last time you licked the ankle area of the inside of a boot?" is one recent battle-cry. While the point is fair, whoever said it may not have spent a lot of time around children; pretty much everything ends up in their mouths, all over their hands, and on their toes.
Anyway, as stated the point of the Act isn't to get into nickels and dimes about how much cadmium is too much -- the point is: why not just call a toxin a toxin and use another, safer, ingredient in its place? Threshold debates get very tedious and hold up the process. That, at least, is the point of view of lawmakers in Washington.
If the rule is fully implemented, manufacturers of children's products would start mandatory reporting to the Washington State Department of Ecology in 2012 if their products contain chemicals of concern on the CHCC list.
59 Ways to lose your livelihood
Can't resist a good subtitle, can we.
List is as follows. You can also view and print the alphabetized CHCC list. Place your comments at the end of this post if you have an immediate reaction. Cheers.
| CAS | Chemical |
| 50-00-0 | Formaldehyde |
| 62-53-3 | Aniline |
| 62-75-9 | N-Nitrosodimethylamine |
| 71-36-3 | n-Butanol |
| 71-43-2 | Benzene |
| 75-01-4 | Vinyl chloride |
| 75-07-0 | Acetaldehyde |
| 75-09-2 | Methylene chloride |
| 75-15-0 | Carbon disulfide |
| 78-93-3 | Methyl ethyl ketone |
| 79-34-5 | 1,1,2,2-Tetrachloroethane |
| 79-94-7 | Tetrabromobisphenol A |
| 80-05-7 | Bisphenol A |
| 84-75-3 | Di-n-Hexyl Phthalate |
| 86-30-6 | N-Nitrosodiphenylamine |
| 87-68-3 | Hexachlorobutadiene |
| 94-13-3 | Propyl paraben |
| 94-26-8 | Butyl paraben |
| 95-53-4 | 2-Aminotoluene |
| 95-80-7 | 2,4-Diaminotoluene |
| 99-76-3 | Methyl paraben |
| 99-96-7 | p-Hydroxybenzoic acid |
| 100-41-4 | Ethylbenzene |
| 100-42-5 | Styrene |
| 104-40-5 | 4-Nonylphenol; 4-NP and its isomer mixtures including CAS 84852-15-3 and CAS 25154-52-3 |
| 106-47-8 | para-Chloroaniline |
| 107-13-1 | Acrylonitrile |
| 107-21-1 | Ethylene glycol |
| 108-88-3 | Toluene |
| 108-95-2 | Phenol |
| 109-86-4 | 2-Methoxyethanol |
| 110-80-5 | Ethylene glycol monoethyl ester |
| 115-96-8 | Tris(2-chloroethyl) phosphate |
| 118-74-1 | Hexachlorobenzene |
| 119-93-7 | 3,3'-Dimethylbenzidine and Dyes Metabolized to 3,3'-Dimethylbenzidine |
| 120-47-8 | Ethyl paraben |
| 123-91-1 | 1,4-Dioxane |
| 127-18-4 | Perchloroethylene |
| 131-55-5 | Benzophenone-2 (Bp-2); 2,2',4,4'-Tetrahydroxybenzophenone |
| 140-66-9 | 4-tert-Octylphenol; 1,1,3,3-Tetramethyl-4-butylphenol |
| 140-67-0 | Estragole |
| 149-57-5 | 2-Ethylhexanoic Acid |
| 556-67-2 | Octamethylcyclotetrasiloxane |
| 608-93-5 | Benzene, pentachloro |
| 842-07-9 | C.I. Solvent Yellow 14 |
| 872-50-4 | N-Methylpyrrolidone |
| 1163-19-5 | 2,2',3,3',4,4',5,5',6,6'-Decabromodiphenyl ether; BDE-209 |
| 1763-23-1 | Perfluorooctanyl sulphonic acid and its salts; PFOS |
| 1806-26-4 | Phenol, 4-octyl- |
| 5466-77-3 | 2-Ethyl-hexyl-4-methoxycinnamate |
| 7439-97-6 | Mercury & mercury compounds including methyl mercury (22967-92-6) |
| 7439-98-7 | Molybdenum & molybdenum compounds |
| 7440-36-0 | Antimony & Antimony compounds |
| 7440-38-2 | Arsenic & Arsenic compounds including arsenic trioxide (1327-53-3) & dimethyl arsenic (75-60-5) |
| 7440-43-9 | Cadmium & cadmium compounds |
| 7440-48-4 | Cobalt & cobalt compounds |
| 25013-16-5 | Butylated hydroxyanisole; BHA |
| 25154-52-3 | Nonylphenol |
| 25637-99-4 | Hexabromocyclododecane |
