What triggers the requirement to do an alternatives analysis?
An alternatives analysis should be conducted once a chemical of “potential” concern is designated as a chemical of concern in clearly-defined consumer products through manufacture, use and end of life of product, based on level of toxicity, volume of the product being used, potential for exposure and use of the product. Thus additional data has already been collected on the chemical of concern and a simplified life cycle analysis (LCA) has been conducted for its presence in consumer products and whether alternatives are or may be available. There must be a clear demonstration of adverse impact on human health or the environment from exposure to a chemical in a product and use, and verified commercial information indicating alternatives may exist. The presence of a chemical of concern should not necessarily trigger an alternatives analysis. The nature of the product must pose a risk. +++ 2.Who should perform the analysis? State Scientists should lead this effort in collaboration with ma