Historic binding agreement reached to cut greenhouse gasses from HFC

There are roughly 1.6 billion new air conditioning units expected to come on stream by 2050, reflecting increased demand from Asia, Latin America, and Africa.

On 15 October 2016 in Kigali, Rwanda nearly 200 nations have agreed a legally binding agreement to cut back on greenhouse gasses used in refrigerators and air conditioners, a significant move against climate change.
The International deal would require countries to phase out greenhouse gasses called hydrofluorocarbons beginning in 2019.

Under the agreement, developed nations, including much of Europe, the United States, China, and India commit to reducing their use of the gasses incrementally, starting with a 10 percent cut by 2019 with the goal of an 80% reduction globally by 2047. But many wealthier nations and companies have already begun to reduce their use of HFCs.

A parallel deal was struck last year in Paris to slow the growth of carbon emissions, the most prevalent greenhouse gas emitted by the burning of fossil fuels. That deal entered into force earlier this month. But unlike the Paris agreement, the Kigali deal is legally binding, has very specific timetables and has an agreement by developed economies to help emerging countries adapt their technology.

The HFC agreement comes in the form of an amendment to the Montreal Protocol, an international treaty undertaken nearly 30 years ago to protect the Earth’s ozone layer.

According to the Wall Steet Journal article, Chemours Co., a publicly traded chemicals company spun off from DuPont Co. last year (and Locus Technologies customer), said that it was introducing a new line of gasses to help replace HFCs for some industrial-scale refrigeration and air-cooling systems.

The deal is the latest installment in the US administration’s efforts to curb the global greenhouse-gas emissions that scientists say are warming the planet with harmful consequences. Earlier this month, countries also agreed to limit carbon emissions from global aviation for the first time ( http://locustec.com/blog/epa-plans-regulate-carbon-emissions-aircraft/ ).

HFCs account for about 1% of global greenhouse-gas emissions and 1.5% of all U.S. greenhouse-gas emissions, according to the U.S. Energy Information Administration. But they are considered one of the fastest-growing greenhouses gasses in the world. The agency predicts HFC emissions could increase up to 15% a year globally if they aren’t limited.

As a greenhouse gas, HFCs are more potent than carbon dioxide. Their heat-trapping capacity can be hundreds or thousands of times that of carbon dioxide, according to the U.S. Environmental Protection Agency. Plus, some HFCs can stay in the atmosphere for hundreds of years, according to a 2007 report by the Intergovernmental Panel on Climate Change. As a result, even small amounts can have profound, long-lasting effects on the environment.

HFCs belong to a family of compounds known as fluorinated gasses. Such substances don’t exist in nature; they are entirely man-made, according to the EPA. After the Montreal Protocol, HFCs were developed to replace another class of fluorinated compounds, known as chlorofluorocarbons, because these were depleting the ozone layer.

One of the industry challenges will be to track, organize, and report on avalanches of data stemming from the binding HFC compliance requirements. SaaS like Locus Platform is ready for the challenge.

Aviation industry agrees to cap CO2 emissions, other transportation industries to follow

The first deal limiting greenhouse gasses from international aviation has been sealed after years of negotiations. Carbon emissions from international aviation will be capped under a global agreement to limit the impact of commercial flights on the climate. The deal launches a voluntary compliance system from 2021 that would become mandatory in 2027. Airlines spent about $181 billion on fuel last year, and this deal would add between $5 and $24 billion in additional costs, depending on the price of carbon at the time. The aviation carbon cuts were agreed in Montreal by national representatives at the International Civil Aviation Organization, ICAO.

The deal comes in a critical week for climate policy when the Paris agreement to stabilize climate change passed a key threshold for becoming law. International aviation is responsible for putting more carbon dioxide into the atmosphere every year than the whole of the Germany or the UK. And until now, there has been no global consensus on how to address aviation emissions.

CO2 will be allowed to grow to 2020, but after that, emissions will need to be offset. The deal will be voluntary to 2026, but most major nations are expected to take part. Airlines that pollute more than the prescribed level after 2020 would have to purchase carbon-offsetting credits.

The offsetting proposal is especially controversial. Airlines are striving to make planes more efficient, but the industry can’t innovate fast enough to contain its dynamic growth.

That led to the proposal for offsetting – but sometimes offsetting by planting trees is not enough and is prone to double-counting.

One way to offset emissions, besides planting trees, is using trees’ and other plants spoils to make sustainable fuels. The effort to use sustainable fuels has already started, and manufacturers and airlines support of alternative fuels is high.

To that end, the US biofuels leader, Amyris, Inc is developing an alternative aviation jet fuel made with a sustainably-sourced hydrocarbon using Amyris’s proprietary synthetic biology platform. It is one of the most promising developments in aviation fuels in decades.

Amyris’ jet fuel can reduce greenhouse gas emissions by up to 80 percent compared with petroleum fuels, when compared unmixed to petroleum fuels on a one-to-one basis, according to Amyris.

Attempts have been made for nearly two decades to include aviation and shipping in the UN’s climate agreements, but both sectors have managed to avoid firm targets.

US EPA earlier this year issued a final scientific assessment that concluded that carbon emissions from aircraft endanger public health and welfare, a legal prerequisite the agency must take before regulating those emissions in the US. It is widely expected that EPA will introduce its set of rules for regulating domestic aircraft emissions in the US. Domestic aviation represents about 40% of total carbon-dioxide output from commercial flights.

Environmental groups said they hope the action to curb airline emissions will spur a similar cap on maritime CO2 production. Maritime emissions aren’t covered by the Paris climate deal even though the industry is considered a major carbon emitter.

All these emissions trackings must be managed and verified and will require companies to install scalable and intelligent database systems like Locus SaaS-based EIM and Locus Platform that already help many companies comply with various emission laws and regulations around the world.

Grain Processing Corporation streamlines Clean Air Act Title V reporting using Locus Platform

SAN FRANCISCO, Calif., 20 September 2016 — Locus Technologies (Locus), a leading provider of real world software solutions to streamline EHS regulation and compliance management, has recently issued a new case study for an implementation of the Locus Platform for Clean Air Act Title V recordkeeping.

Keeping track of environmental compliance can be difficult and requires high levels of organization. Locus’ products help companies manage their environmental compliance and move forward with their tasks. One of Locus’ customers, Grain Processing Corporation (GPC), utilized Locus Platform to manage their environmental compliance needs and improve their work processes.

“Our recent successes in deploying our software solutions to customers in food and agricultural industries proves its versatile nature. GPC needed a data management system for their Title V monitoring that was tailored to their specific business practices. The Locus Platform allows for full configurability of its data collection tools, workflows, and outputs. By using these tools, the software solution fits the business, not the other way around.” said J. Wesley Hawthorne, President of Locus Technologies. “This ultimately leads to quicker adoption, reduced costs, and consensus among all the software users.”

The case study examines GPC’s use of Locus Platform to streamline their environmental compliance challenges, how they used Locus as a solution to their needs, and the results of using Locus Platform to streamline their compliance process. Follow the link to the case study on our website.

https://www.locustec.com/case-study/gpc-streamlines-clean-air-act-title-v-record-keeping-using-locus-platform/

ABOUT GRAIN PROCESSING CORPORATION

Founded in 1943, GPC is a privately owned company with a solid history of innovation and a vision for continued success in the future. Its mission is to manufacture, distribute and market customer-specified food, pharmaceutical and industrial-grade products of uncompromising quality. GPC’s substantial investment in the finest people, facilities, technology and customer support services reflects the seriousness of that commitment to quality.

Configurable software solutions—Change is good, right?

 

Modern software technology and design has enabled an unprecedented amount of creation and innovation by managers, subject matter experts, and technical staff.

Before, if you wanted a new custom facility environmental audit form, you had to create a set of specifications, outline all functionality, and engage software developers to create the application (or just do it all on paper).  This approach could take months to develop, test, debug, and rework.  With the tools we have now, this kind of custom job can be done within a day, complete with mobile-enabled forms.  It’s amazing how modern technology is such a huge time and cost saver.  But it also introduces a new list of challenges that have to be considered when taking ownership of a configurable software solution.

You need to know what you want.

While we now have easy-to-use tools for creating applications, you still need to define what you want to get out of the application you’re making.  When you buy pre-configured software, you adapt your process to fit the constraints of the system you just bought. When you buy configurable software, you’re able to create the exact workflow that you need, but you have to first develop a complete understanding of what your needs actually are. With flexible tools, it’s easy to try out different configurations with your team members.  However, it’s a challenge to have your team on the same page about what configuration will benefit the entire range of users or departments.

Just because you can make easy and fast changes, doesn’t mean you should.

Typically, you have to wait until a vendor updates the software and hope they address any changes you were hoping for.  With configurable software, you or the vendor can make those changes anytime.

However, if you’re making these kinds of changes on your own, without proper management and communication, there is a very good chance you will create usability issues for other users in your community. Even the simplest management system for changes will make everyone’s life easier. For example, you can categorize potential changes by their urgency. The urgent changes can be notified to users immediately (as soon as they are made), and the non-urgent changes can be scheduled for later. Establishing any kind of management and communication system can help you keep your team up to date with software changes.

You are not in this alone.

Configurable software, with its endless possibilities, may seem daunting.  But you don’t have to be overwhelmed with options— there are plenty of people who would love to help you:

  • The software vendor can be your configuration partner and do the work at your direction. You get real-time updates to ensure the configuration keeps heading in the right direction toward fulfilling your needs— and you can spend your time focusing on your business, rather than configuring the software.
  • Your consultants can configure for you. It’s very likely that you have great, trusted relationships with the consulting community, who already know you and have developed some understanding of your business needs.  These resources can help to ensure you get the perfect solution.
  • Your staff likely has people that would love to configure and would jump at the chance to develop an effective solution that benefits the department and the organization as a whole. They are easy to spot— they spend time in Excel and write macros for fun.
Bottom line: Plan, prioritize, partner.

Configurable software can open up a world of options and often prove to be a great choice for many customers.  But it’s important that you understand the process— including all the advantages and challenges that come with it. Decide how you want to manage the configuration and reach out to trusted people. With some preparation and an invested team, you will have no problem navigating the exciting waters that technology has made possible.

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Still looking for the right EHS software to revolutionize your environmental and compliance initiatives?  Book a demo with us today!

 

Marian Carr

About guest blogger— Marian Carr, Locus Technologies

Ms. Carr is responsible for managing overall customer solution deployments and customer relationships with Locus’ government accounts. Her career at Locus includes heading the product development team of the award-winning cloud-based environmental ePortal solution as well as maintaining and growing key customer accounts with Locus’ Fortune 100 enterprise deployments. In addition, Ms. Carr was instrumental in driving the growth and adoption of the Locus EIM platform with key federal and water organizations.

Locus Technologies creates IoT interoperability with Locus Platform

Locus helps customers leverage data, analytical, cloud, and mobile capabilities via IoT-to-Locus SaaS platform

MOUNTAIN VIEW, Calif., 9 August 2016 — Locus Technologies (Locus), the industry leader in cloud-based EHS software, announced today that its multi-tenant SaaS Platform fully interoperates with the Internet of Things (IoT). The company has been the pioneering innovator in the EHS software space since 1999 when it first introduced its Automation and Data Management Groups, which used Internet-based technologies to manage and control vast amounts of data generated at the company’s customer sites.

Locus’ automation technologies have evolved over the years to encompass the vast array of Internet-connected devices, sensors, programmable logic controllers, and other instruments to gather and organize large amounts of streaming data.

The IoT interconnects uniquely identifiable embedded computing, testing, and monitoring devices within the existing Internet infrastructure and software platform. Locus IoT services offer connectivity beyond machine-to-machine communications and cover a variety of protocols, domains, and applications.

“The IoT is one of the fastest-growing trends in tech. When applied to the environmental monitoring industry, there is an overwhelming influx of information that has to be dealt with; many companies are concerned that the sheer volume of data will render the information useless. For that reason, Locus invested in smart software and intelligent databases to deal with this new trend, long before IoT had a common name. We aspire to change the face of the environmental monitoring industry,” said Neno Duplan, CEO of Locus.

In any industry, when all incoming data are connected and centrally accessible through a multi-tenant SaaS application, the flow of information is much more efficient and effective. For example, instead of having a separate data collection protocol from software applications for water quality management, waste management, GHG management, EHS compliance and incident management, a company can have all emissions-related records—regardless of whether they originated in the laboratory, field, or Internet-connected monitoring device—in a single system of record. From this single system of record, they can manage compliance activities, perform data gathering and monitoring, manage water treatment systems remotely, and manage resources for sustainability reporting at the same time. Adopting such a structure offers Locus’ customers the ability to converge all incoming sources of information to create a much-needed integrated enterprise platform for EH&S+S management.

At the crux of this integration is Locus’ highly scalable and end-user configurable Locus Platform. The interoperability combines the Locus Platform as a service with its automation, mobile, and IoT platforms. The combined IoT suite will be hosted on Locus’ cloud.

“By combining our cloud platform and Internet of Things (IoT) platforms to make them interoperable, we provide the single platform for our customers that helps them lower their operational costs, reduce cycle time, and ultimately become better stewards of the environment. This integration will give our customers more analytics from connected devices,” added Duplan.

EPA issues Final Rule for regulating formaldehyde emissions

Six years after the passage of the Formaldehyde Emission Standards for Composite Wood Products Act of 2010 (42 U.S.C. 2697), the US Environmental Protection Agency (EPA) has issued its final rule implementing the Act (Final Rule). The Final Rule—based on the formaldehyde regulation released by the California Air Resources Board (with which EPA collaborated in formulating the Final Rule)—seeks to reduce exposure to formaldehyde vapors by establishing emission standards and labeling requirements for certain wood products.

Final rule seeks to reduce exposure to formaldehyde vapors by establishing emission standards and labeling requirements for certain wood products.

Formaldehyde is a chemical that is commonly used in wood glue for furniture and flooring. Some studies have linked formaldehyde to nasopharyngeal cancer, eye irritation, and respiratory problems, while other studies have raised questions about the chemical’s potential role in causing asthma and allergic conditions, particularly among children.

In 2008, in response to these health concerns, California became the first US jurisdiction to issue emission limits on formaldehyde in building materials and furniture used in homes. Two years later, the US Congress enacted the Formaldehyde Emission Standards for Composite Wood Products Act, which added Title VI to the Toxic Substances Control Act (TSCA). This Act directed EPA to issue regulations implementing the Act.

The Final Rule sets formaldehyde emission standards applicable to hardwood plywood, medium-density fiberboard and particleboard, and finished goods containing these products that are sold, supplied, offered for sale, imported into, or manufactured in the United States. To show that they are in compliance with the emission standards, within one year, these products will need to be labeled as TSCA Title VI compliant. Furthermore, the Final Rule establishes an EPA TSCA Title VI Third-Party Certification Program to ensure that composite wood panel producers comply with the emission limits. Under this program, Third-Party Certifiers (TPCs) will regularly inspect composite wood panel producers and conduct emissions tests. TPCs who wish to participate in the program must apply to EPA for approval and receive program recognition before certifying products.

Products that contain de minimis amounts of composite wood products (defined as products containing 144 square inches or less of regulated composite wood products) are exempt from the labeling requirements.

Some small businesses have argued that the rule’s testing, labeling, and record-keeping requirements will disproportionally impact smaller firms that aren’t equipped to handle additional costs.

EPA plans to regulate carbon emissions from aircraft

The US Environmental Protection Agency on Monday announced plans to limit carbon emissions from aircraft.

The EPA issued a final scientific assessment that concluded that carbon emissions from aircraft endanger public health and welfare, a legal prerequisite the agency must take before regulating those emissions.

EPA officials said last year when first proposing the aircraft scientific assessment that any regulation would be implemented in coordination with the International Civil Aviation Organization, a branch of the United Nations, which is drafting a global standard for airline carbon emissions.

Emissions from aircraft represent about 2% of total global carbon emissions, and the U.S. is the largest contributor to global aviation greenhouse gasses, according to federal data. The EPA said aircraft are the third-largest source of greenhouse gas emissions in the U.S. transportation sector, accounting for about 3% of such emissions in the country.

EPA has already set effective GHG standards for cars and trucks. EPA anticipates moving forward on standards that would be at least as stringent as ICAO’s standards.

Military and small piston-engine planes often used for recreational purposes would be exempt from the new regulation. Excluding these two categories, the EPA’s scientific finding applies to 89% of all U.S. aircraft carbon emissions.

Airlines for America, the trade association representing U.S. airlines and air cargo carriers, said it commends the EPA’s action because it is working within the coming international framework.

In 2009 the International Air Transport Association, a global trade group, agreed to achieve carbon-neutral growth by 2020, meaning any future growth in air travel wouldn’t produce a net increase in carbon emissions.

Then, from 2020 through 2050, the industry aims to reduce its 2005 emission levels by half, largely through the use of sustainable fuels. The effort to use sustainable fuels has already started, and manufacturers and airlines support of alternative fuels is high.

Carbon management.

EPA to regulate aircraft emissions.

To that end, the US biofuels leader, Amyris, Inc. and oil company Total have partnered to develop an alternative aviation jet fuel made with a sustainably-sourced hydrocarbon using Amyris’s proprietary synthetic biology platform. In 2014, Amyris received industry acceptance and regulatory approval for renewable jet fuel in key U.S., European and Brazilian markets. The New York Times writes that Amyris renewable jet fuel “holds the elusive promise of better energy security, reduced carbon emissions, and lower fuel costs. Amyris’ jet fuel can reduce greenhouse gas emissions by up to 80 percent compared with petroleum fuels, when compared unmixed to petroleum fuels on a one-to-one basis, according to Amyris. Renewable fuels like Amyris farnesane ‘would help reduce the carbon footprint of commercial aviation,’ the Federal Aviation Administration said.”

Amyris announced that, on May 29, 2016, Cathay Pacific commenced a two-year program of flights from Toulouse to Hong Kong using Amyris renewable jet fuel.  The initial 12-hour flight was the longest flight using a renewable jet fuel to date, further underpinning the ‘drop-in’ characteristics of Amyris Biojet fuels. Cathay took delivery of a new Airbus A350-900 that flew from the Airbus facility in Toulouse, France, to Hong Kong using a 10% biofuel jet blend provided by Amyris with the commercial and industrial support of Total S.A. The combination of the new airplane’s improvements in fuel efficiency (about 25% better than current aircraft) and the fuel’s properties resulted in an estimated 30% reduction in CO2 emissions according to Cathay when compared to comparable flights in recent-generation aircraft using fossil fuels.

Why SaaS multitenancy is key to successful and sustainable EHS management

A recently published survey by a research analyst firm indicates that 90 percent of EHS software applications installed today are single-tenant on customer premises or single-tenant, vendor hosted.  Only 10 percent are multitenant, vendor-hosted. In other words, most of the vendors in the EH&S space do not run a single version of their software maintained at one location. Instead, they run multiple copies at a single or multiple locations, with the high likelihood that these multiple copies are not alike, but instead represent multiple versions or contain specific customizations for individual customers. This model is crushing their growth and scalability potential.

Locus delivers EHS+S SaaS solutions as highly scalable, Software as a Service (SaaS) application and platform services on a multitenant technology architecture. Multitenancy is an architectural approach that allows Locus to operate a single application instance for multiple organizations, treating all customers as separate tenants who run in virtual isolation from each other. Customers can use and customize an application as though they each have a separate instance, yet their data and customizations remain secure and insulated from the activities of all other tenants. Locus multitenant services run on a single stack of hardware and software, which is comprised of commercially available hardware and a  combination of proprietary and commercially available software. As a result, Locus can spread the cost of delivering EHS SaaS services across user base, which lowers the cost for each customer. Also, because Locus does not have to manage thousands of distinct applications with their business logic and database schemas, we believe that we can scale our business faster than traditional software vendors. Moreover, we can focus our resources on building new functionality to deliver to customer base as a whole rather than on maintaining an infrastructure to support each of their distinct applications.

Multitenancy also allows for faster bug and security fixes, automatic software updates and the ability to deploy major releases and frequent, incremental improvements to Locus’ services, benefiting the entire user community. Our services are optimized to run on specific databases and operating systems using the tools and platforms best suited to serve customers rather than on-premise software that must be written to the different hardware, operating systems and database platforms existing within a customer’s unique systems environment. Locus developers build and support solutions and features on a single code base on our chosen technology platform. Locus efforts are focused on improving and enhancing the features, functionality, performance, availability and security of existing service offerings as well as developing new features, functionality, and services.

Locus customers and third-party developers can create apps rapidly because of the ease of use of Locus Platform and the benefits of a multitenant platform. Locus provides the capability for business users to configure applications easily to suit their specific needs.

Also, Locus multitenant cloud platform makes it possible to use a remarkably small number of servers as efficiently as possible. When organizations move business applications to Locus, they can significantly reduce their energy use and carbon footprints compared to traditional on-premises or single-tenant or ASP solutions

Locus built and maintains a multitenant application architecture that has been designed to enable service to scale securely, reliably and cost effectively. Locus’ multitenant application architecture maintains the integrity and separation of customer data while still permitting all customers to use the same application functionality simultaneously.

Both Locus and its data centers providers hold independent  AICPA SOC1 (SSAE16)  and SOC2 certification.

Locus Technologies introduces indoor air management application

The Locus indoor air management application is fully integrated with the dynamic Locus Platform and will automate indoor air management for small and large enterprises.

MOUNTAIN VIEW, Calif., 6 June 2016 — Locus Technologies (Locus), the leader in cloud-based environmental compliance and sustainability management software, introduces an all-new vapor intrusion and indoor air management application to its newest platform to redefine how companies organize, manage, and report their indoor air and vapor intrusion data. The Locus platform— a true, multi-tenant SaaS— offers a highly configurable, user-friendly interface to meet individual organizations’ environmental management needs.

Indoor air quality is becoming an important environmental and chemical exposure challenge for many companies whose properties may be impacted by contaminated groundwater or soil that release vapors or fumes.  Once the indoor air quality problem is identified, it follows a lengthy investigation that can involve several phases of sampling (including soil-gas, subslab, pathway, and ambient indoor air samples) using either active or passive sampling techniques. Samples are typically composited over time periods that can range from hours to weeks. A substantial amount of additional metadata is collected surrounding each sampling event, including information on the building construction, layout, occupancy, chemical use, and heating and ventilation systems.

All these activities generate large quantities of data, which until now were managed primarily by spreadsheet scattered on laptops or desktops. Locus’ new application brings an organized approach and workflow process to schedule, sample, and manage analytical results stemming from investigation and ongoing monitoring programs. Tools are also included to track the status and effectiveness of mitigation efforts related to indoor air quality. The data are easily summarized for review through reporting and built-in mapping tools, which can identify adjacent properties at potential risk for indoor air quality issues. Plus, if a customer is already a subscriber to Locus EIM, Incidents, or other Locus Platform applications, they can correlate data among various applications and facilitate finding the cause of degradation of the indoor air quality.

“Indoor air quality and vapor intrusion are gaining more and more attention from regulators, property owners, and managers of environmental sites. These projects generate a large volume of structured and unstructured data as part of the investigation and mitigation processes.  To successfully compile and review this information, companies need a software that can manage these various data types and allow quick review and decision making. The right software can reduce the stress, time, and potential inaccuracies associated with these projects.” said Wes Hawthorne, Senior Vice President of Locus.

The new TSCA law not REACH (in data requirements)

After a bipartisan accord, the US Congress overhauled the 40-year-old Toxic Substances Control Act (TSCA), with legislation to give the EPA greater powers to regulate about 100 hazardous chemicals. This is the first major statutory update to US environmental law that’s been passed in over 25 years. On a 403-12 vote, the U.S. House of Representatives on 24 May 2016 approved bipartisan legislation to amend the key provisions of the TSCA.

Under existing law, the Environmental Protection Agency (EPA) has succeeded in regulating only five toxic chemicals since 1976, prompting public health advocates to decry TSCA as broken. Part of the problem is that the law grants EPA only 90 days to decide whether a new chemical poses “unreasonable risk” before it can enter the market, and agency officials say they rarely get the toxicity data they need to make that call in time.

The compromise legislation will remove those procedural hurdles, require EPA to focus on “high priority” chemicals such as arsenic and asbestos, and give the agency new tools to collect data from companies. It also grandfathers in some existing state chemical safety laws, such as those enacted under California’s Proposition 65, but limits states’ authority to create their own restrictions on chemicals in the future. State pre-emption was a key point of contention between Democrats and Republicans during negotiations.

So how does the new TSCA law compare to the EU REACH program? REACH (Registration, Evaluation, Authorization and Restriction of Chemical substances) is a regulation of the European Union, adopted to improve the protection of human health and the environment from the risks that can be posed by chemicals. REACH also promotes alternative methods for the hazard assessment of substances to reduce the number of tests on animals. Under the REACH Regulation, companies are responsible for providing information on the hazards, risks and safe use of chemical substances that they manufacture or import.

One notable difference between  REACH and TOSCA is how they support downstream users in implementing their chemicals management programs. Regarding knowing chemicals in products, REACH provides clear direction that downstream users must communicate uses up to suppliers and know and publicly disclose (if requested) if their product contains substances of very high concern (SVHC). The TSCA  does essentially nothing to support downstream users in knowing chemicals in products and disclosing them to the public, and its requirements for upstream communication to suppliers on uses are uncertain.

Significantly, REACH requires companies to provide minimum data sets on the inherent hazards of chemicals. This data enables downstream users to evaluate and compare chemicals on their hazard characteristics. TSCA, while expanding the ability of the US EPA to require testing of chemicals, explicitly prohibits the agency from requiring minimum data sets.

While it is important to avoid the unnecessary testing of chemicals, it is also vital to have a data set on chemicals that enable their comparison on a common set of endpoints. The EPA needs the authority to establish a minimum data set on chemicals, although this may differ depending on the specific chemical.

On assessing the hazards of chemicals, the new  US law falls short of REACH and impedes harmonizing European and US requirements for chemical testing. Given that most US chemical companies sell into the European market, and therefore are already meeting those requirements, it is inefficient and wasteful to establish a totally separate testing regime in the US.

To support the use of inherently safer chemicals, REACH provides a clear and more streamlined process for identifying and restricting SVHCs. Over the course of seven years, the Regulation has identified 161 Candidate SVHCs, while over five years, the  US bill only requires the designation of 25 high priority chemicals and with new law extending that number to about 100 chemicals. Harmonization, consistency, and predictability are critical for downstream users, and these elements are all lacking in the new TSCA law.