California Releases its First Draft of its Alternatives Analysis Guide (AA Guide)

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All manufacturers and sellers of consumer products into California should take note.    California has just released its first draft of stage one of its Alternatives Analysis Guide (AA Guide).  You can read all 103 pages here.

If your product is selected as a “priority product” under the California Safer Consumer Product Regulations, then your company will be required to prepare and submit for public review an alternatives analysis (AA).  Learn more here, here or here.

An AA is a brand new paperwork beast.  It is in parts a large CEQA/NEPA-type document, in parts a hazard assessment, in parts a life cycle assessment, and more.  It has the potential to make a CEQA document look like a haiku poem in comparison.

Manufacturers are encouraged to look at this initial draft AA Guide to determine whether what California is asking for is doable and feasible, and to provide comments to the California Department of Toxic Substances Control to modify the draft AA Guide to the extent they find it infeasible or impractical and help the State develop a document that will enhance manufacturer’s ability to comply, rather than make it impossible.

Comments can be submitted here.  Comments are due by October 23, 2015.