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COMk.171
From: Georjean Adams
Sent: Monday, May 30, 2022 3:16 PM
To: Council Testimony
Subject: Proposed Bill 167 Nonmetallic Sunscreens
I am resubmitting testimony in opposition to BILI 167 provided to the Climate Resilience and Natural Resource
Management Committee on May 16, 2022, below.
FYI - ZInc Oxide aquatic toxicity data is summarized here: https://echa.europa.eu/registration-dossier/-/registered-
dossier/16139/6/2/5. This is the packaging label required in Europe for ZnO based on this data:
1111'.11IPn W -=t
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.111;11' Cep
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Warning! According to the harmonised classification and labelling (CLP00) approved by the European
Union, this substance is very toxic to aquatic life and is very toxic to aquatic life with long lasting effects.
Again, I advise waiting for the NAS study.
Georjean Adams
District 9 resident
On Mon, May 16, 2022 at 10:22 AM Georjean Adams <georjean@gmail.com>wrote:
I oppose Bill 167.
1. The County Council is not qualified to make the determination that
"The chemical compounds contained in non-mineral sunscreen inhibit coral growth and degrade the
integrity of our reefs."[which include water among other nonmetallic chemicals]
Nor is the County Council qualified to evaluate the life cycle risks presented by titanium dioxide and zinc
oxide for whether or not they actually "...preserve the health, safety, and welfare of humans and the
environment...."
2. The County should, at a minimum, wait for the results of the National Academies of Science (NAS) study,
whose results should be published this year: "Environmental Impact of Currently Marketed Sunscreens and
Potential Human Impacts of Changes in Sunscreen Usage"
https://www.nationalacademies.org/our-work/environmental-impact-of-currently-marketed-sunscreens-and-
potential-human-impacts-of-changes-in-sunscreen-usage
3. Zinc Oxide is classified as very toxic to aquatic organisms by the European Chemicals Agency
(ECHA): https://echa.europa.eu/substance-information/-/substanceinfo/100.013.839 Comm. No. 111'11%
Ref.To: Fl£ounC!l
1
Ref. Dote JUN - 1 2022
4. Titanium Dioxide is classified by_ECHA as a category 2 possible carcinogen (https://echa.europa.eu/-/new-
guide-available-on-classifying-and-labelling-titanium-dioxide) and appears on the California Proposition 65 LIst for
risk of cancer- when in respirable powder form (https://www.p65warnings.ca.gov/fact-sheets/titanium-dioxide-
airborne-unbound-particles-respirable-size). Spray sunscreens are suspect. Ocean spray-unknown. Certainly there
are potential workplace exposure concerns when compounding titanium dioxide sunscreens.
5. Marketplace restrictions by county are confusing and difficult to implement, especially with e-commerce and
what tourists may bring on island. Preferably, the NAS study will support a science-based nationwide response.
6. The County's Department of Environmental Management is not funded or staffed to administer and police this
bill. Passing ordinances that cannot be enforced is poor governance. Even SB 2571 is acknowledged as unenforced.
Georjean Adams
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