Annex: Questions to open forum discussion
- How is bisphenol A used by your organization? (e.g. paint, coating, sealant, adhesive, metal, paper plastics, etc.)
- What are the trends for bisphenol A use (has consumption increased, decreased, remained the same…)?
- Are there bisphenol substitutes available?
- Do you know if you use a product containing BPA? If so, who is your supplier?
- If available, please provide the MSDS for your product containing BPA.
- Do you consider the proposed concentration limit of 1.75 µg/L of bisphenol A achievable? If not, please explain why and what changes would be needed to achieve this level?
- Do you consider concentration limit of 1.75 µg/L of bisphenol A sufficient to protect the environment? If not, what concentration would be sufficient and why?
- How is industry currently managing the industrial effluent releases of bisphenol A to water?
- Which process, technology or methods would be most appropriate to control the release of bisphenol A to water and how prevalent are they used by industry?
- Are the costs of implementing, maintaining or developing capture and release technologies economically feasible? Please explain.
- What effluent sampling and test analysis methodology does your company use for bisphenol A?
- What sampling frequency and equipment would be required to obtain representative data of bisphenol A of effluent discharge?
- Does your facility currently sample industrial effluents? If so, was bisphenol A tested for?
- What are the costs associated with sampling and testing for bisphenol A?
- Are the proposed requirements for an EMS achievable? Please explain.
- How prevalent is an EMS used to manage substance by industry?
- Is the requirement for an EMS sufficient to manage, prevent or reduce the release of bisphenol A? Please explain.
- If your facility does not have an environmental management system, what methodology is used to ensure that the environmental requirements to which your organization are currently subject to are being met?
- What costs would be associated with maintaining or updating your current environmental management system to include actions to prevent or reduce the release of bisphenol A to water?
- How long would it take your company to comply with the proposed maximum concentration limit and the proposed environmental management system requirements?
- What are the estimated costs associated with compliance?
- How would this regulatory proposal affect your company? (Market share, increase cost, loss of market, etc.)