Global Automakers and the Alliance submitted joint comments to the California Department of Toxic Substance Control (DTSC) in response to their request for comment on considering lead-acid batteries (LABs) as a Priority Product in the California Safer Consumer Products Workplan.
The comments' main points included:
- Our concern about the State of California's rationale in pursuing the potential listing of LABs as a Priority Product.
- While California has experienced issues with the recycling of these batteries in the past, the targeting of the entire automotive battery supply chain for the past mistakes of an individual "bad actor" does not represent a science-based, data-driven approach to remedy any outstanding concerns associated with the product.
- In its consideration of LABs as a potential Priority Product, DTSC must take into account the primary factors identified in the Safer Consumer Products regulations that include:
- The potential exposure to the Candidate Chemical(s) in the products; and
- Potential for one or more exposures to contribute to or cause significant or widespread adverse impacts to human health or the environment.
- In addition to the primary factors, DTSC must consider various secondary factors, including:
- The extent to which existing state and federal regulations may be addressing these concerns;
- Whether the listing would meaningfully enhance protection of public health and the environment; and
- Availability of safer alternatives that are functionally acceptable, technically feasible, and economically feasible.
For all of these reasons, the automotive industry is requesting that DTSC not list LABs as a Priority Product in its update to the Workplan.