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3.5 Regulatory Foundation for Product Stewardship
ОглавлениеThere are no specific regulatory requirements for chemical producers or other manufacturers to have PS programs. However, if one can agree to describe the elements of PS as discussed in this chapter, then there are clear regulatory requirements that support individual elements of the concept.
At this time, in the United States Federal statutory authority to control the environmental impacts of products downstream from the manufacturing operations as contrasted to manufacturing locations and operations is limited. SHE regulation has traditionally focused on regulating manufacturing facilities. Transportation regulations apply to the portion of the products in commerce that meet specific Department of Transportation (DOT), or equivalent transportation agencies, hazard classifications. However, some select elements of PS are becoming increasingly evident in regulations, or requirements, involving the life cycle aspects of products. These range in scope from individual chemicals to manufactured articles. There is a new emphasis or focus on human and environmental protection through the regulation of products. As an example the revised Toxic Substances Control Act (TSCA), now known as the Lautenberg Chemical Safety Act (LCSA) is resulting in a broader scope of authority for the US Environmental Protection Act to regulate the commercialization and use of existing chemicals (2).
Much of this regulatory activity is outside of the North American region, best exemplified by registration, evaluation, and authorization of chemicals (REACH) in the EU but it has impact on this region as business is increasingly global in nature. Details on REACH are found later in this chapter.