Applications | Page 30 of 62 | Locus Technologies

Configurable software solutions—Change is good, right?

Modern software technology and design has enabled an unprecedented amount of creation and innovation by managers, subject matter experts, and technical staff.

Before, if you wanted a new custom facility environmental audit form, you had to create a set of specifications, outline all functionality, and engage software developers to create the application (or just do it all on paper). This approach could take months to develop, test, debug, and rework. With the tools we have now, this kind of custom job can be done within a day, complete with mobile-enabled forms. It’s amazing how modern technology is such a huge time and cost saver. But it also introduces a new list of challenges that have to be considered when taking ownership of a configurable software solution.

You need to know what you want.

While we now have easy-to-use tools for creating applications, you still need to define what you want to get out of the application you’re making. When you buy pre-configured software, you adapt your process to fit the constraints of the system you just bought. When you buy configurable software, you’re able to create the exact workflow that you need, but you have to first develop a complete understanding of what your needs actually are. With flexible tools, it’s easy to try out different configurations with your team members. However, it’s a challenge to have your team on the same page about what configuration will benefit the entire range of users or departments.

Just because you can make easy and fast changes, doesn’t mean you should.

Typically, you have to wait until a vendor updates the software and hope they address any changes you were hoping for. With configurable software, you or the vendor can make those changes anytime.

However, if you’re making these kinds of changes on your own, without proper management and communication, there is a very good chance you will create usability issues for other users in your community. Even the simplest management system for changes will make everyone’s life easier. For example, you can categorize potential changes by their urgency. The urgent changes can be notified to users immediately (as soon as they are made), and the non-urgent changes can be scheduled for later. Establishing any kind of management and communication system can help you keep your team up to date with software changes.

You are not in this alone.

Configurable software, with its endless possibilities, may seem daunting. But you don’t have to be overwhelmed with options— there are plenty of people who would love to help you:

The software vendor can be your configuration partner and do the work at your direction. You get real-time updates to ensure the configuration keeps heading in the right direction toward fulfilling your needs— and you can spend your time focusing on your business, rather than configuring the software.
Your consultants can configure for you. It’s very likely that you have great, trusted relationships with the consulting community, who already know you and have developed some understanding of your business needs. These resources can help to ensure you get the perfect solution.
Your staff likely has people that would love to configure and would jump at the chance to develop an effective solution that benefits the department and the organization as a whole. They are easy to spot— they spend time in Excel and write macros for fun.

Bottom line: Plan, prioritize, partner.

Configurable software can open up a world of options and often prove to be a great choice for many customers. But it’s important that you understand the process— including all the advantages and challenges that come with it. Decide how you want to manage the configuration and reach out to trusted people. With some preparation and an invested team, you will have no problem navigating the exciting waters that technology has made possible.

—

Still looking for the right EHS software to revolutionize your environmental and compliance initiatives? Book a demo with us today!

About guest blogger— Marian Carr, Locus Technologies

Ms. Carr is responsible for managing overall customer solution deployments and customer relationships with Locus’ government accounts. Her career at Locus includes heading the product development team of the award-winning cloud-based environmental ePortal solution as well as maintaining and growing key customer accounts with Locus’ Fortune 100 enterprise deployments. In addition, Ms. Carr was instrumental in driving the growth and adoption of the Locus EIM platform with key federal and water organizations.

Locus makes the ENR Top 200 Environmental Firms List

ENR’s Top 200 Environmental Firms saw their revenue grow in the past year…

Locus Technologies creates IoT interoperability with Locus Platform

Locus helps customers leverage data, analytical, cloud, and mobile capabilities via IoT-to-Locus SaaS platform

MOUNTAIN VIEW, Calif., 9 August 2016 — Locus Technologies (Locus), the industry leader in cloud-based EHS software, announced today that its multi-tenant SaaS Platform fully interoperates with the Internet of Things (IoT). The company has been the pioneering innovator in the EHS software space since 1999 when it first introduced its Automation and Data Management Groups, which used Internet-based technologies to manage and control vast amounts of data generated at the company’s customer sites.

Locus’ automation technologies have evolved over the years to encompass the vast array of Internet-connected devices, sensors, programmable logic controllers, and other instruments to gather and organize large amounts of streaming data.

The IoT interconnects uniquely identifiable embedded computing, testing, and monitoring devices within the existing Internet infrastructure and software platform. Locus IoT services offer connectivity beyond machine-to-machine communications and cover a variety of protocols, domains, and applications.

“The IoT is one of the fastest-growing trends in tech. When applied to the environmental monitoring industry, there is an overwhelming influx of information that has to be dealt with; many companies are concerned that the sheer volume of data will render the information useless. For that reason, Locus invested in smart software and intelligent databases to deal with this new trend, long before IoT had a common name. We aspire to change the face of the environmental monitoring industry,” said Neno Duplan, CEO of Locus.

In any industry, when all incoming data are connected and centrally accessible through a multi-tenant SaaS application, the flow of information is much more efficient and effective. For example, instead of having a separate data collection protocol from software applications for water quality management, waste management, GHG management, EHS compliance and incident management, a company can have all emissions-related records—regardless of whether they originated in the laboratory, field, or Internet-connected monitoring device—in a single system of record. From this single system of record, they can manage compliance activities, perform data gathering and monitoring, manage water treatment systems remotely, and manage resources for sustainability reporting at the same time. Adopting such a structure offers Locus’ customers the ability to converge all incoming sources of information to create a much-needed integrated enterprise platform for EH&S+S management.

At the crux of this integration is Locus’ highly scalable and end-user configurable Locus Platform. The interoperability combines the Locus Platform as a service with its automation, mobile, and IoT platforms. The combined IoT suite will be hosted on Locus’ cloud.

“By combining our cloud platform and Internet of Things (IoT) platforms to make them interoperable, we provide the single platform for our customers that helps them lower their operational costs, reduce cycle time, and ultimately become better stewards of the environment. This integration will give our customers more analytics from connected devices,” added Duplan.

Hinkley Point, the new nuclear power plant in Somerset, UK delayed by new government

Plans to build the UK’s first new nuclear plant in decades, Hinkley Point in Somerset, received an unexpected setback when the government said it wanted to delay its final decision on the project.

The proposed plant is known as Hinkley Point C and would be built next to two existing facilities, Hinkley Point A and B. For the UK it would deliver 7 percent of UK’s electricity when most other nuclear power stations have closed down. At £24bn, it is the biggest and riskiest energy infrastructure project in British history and the decision as to whether it goes ahead lies with the new government that postponed the decision to September. The new UK government will “consider carefully” before proceeding with the project.
French firm EDF, which is financing most of the Hinkley Point project, approved the funding at a board meeting last week. Some in the new government are also concerned that the plant is being built by foreign governments. One-third of the total cost is being provided by Chinese investors. These funding arrangements mean the cost will not end up on the government’s books.

The low-carbon electricity will help towards EU and British climate change goals. The huge project, the largest in Europe, would provide an economic stimulus.

Ever since the UK government committed the nuclear energy in 2006, successive governments have argued that nuclear power is necessary as part of UK’s generation mix and to meet the UK’s climate change commitments.

Nuclear also delivers base load electricity – that is, the amount of power that is needed to satisfy minimum demand – because it is always available. That’s important as more intermittent renewables – such as the wind and solar power – come on to the grid.

EPA issues Final Rule for regulating formaldehyde emissions

Six years after the passage of the Formaldehyde Emission Standards for Composite Wood Products Act of 2010 (42 U.S.C. 2697), the US Environmental Protection Agency (EPA) has issued its final rule implementing the Act (Final Rule). The Final Rule—based on the formaldehyde regulation released by the California Air Resources Board (with which EPA collaborated in formulating the Final Rule)—seeks to reduce exposure to formaldehyde vapors by establishing emission standards and labeling requirements for certain wood products.

Final rule seeks to reduce exposure to formaldehyde vapors by establishing emission standards and labeling requirements for certain wood products.

Formaldehyde is a chemical that is commonly used in wood glue for furniture and flooring. Some studies have linked formaldehyde to nasopharyngeal cancer, eye irritation, and respiratory problems, while other studies have raised questions about the chemical’s potential role in causing asthma and allergic conditions, particularly among children.

In 2008, in response to these health concerns, California became the first US jurisdiction to issue emission limits on formaldehyde in building materials and furniture used in homes. Two years later, the US Congress enacted the Formaldehyde Emission Standards for Composite Wood Products Act, which added Title VI to the Toxic Substances Control Act (TSCA). This Act directed EPA to issue regulations implementing the Act.

The Final Rule sets formaldehyde emission standards applicable to hardwood plywood, medium-density fiberboard and particleboard, and finished goods containing these products that are sold, supplied, offered for sale, imported into, or manufactured in the United States. To show that they are in compliance with the emission standards, within one year, these products will need to be labeled as TSCA Title VI compliant. Furthermore, the Final Rule establishes an EPA TSCA Title VI Third-Party Certification Program to ensure that composite wood panel producers comply with the emission limits. Under this program, Third-Party Certifiers (TPCs) will regularly inspect composite wood panel producers and conduct emissions tests. TPCs who wish to participate in the program must apply to EPA for approval and receive program recognition before certifying products.

Products that contain de minimis amounts of composite wood products (defined as products containing 144 square inches or less of regulated composite wood products) are exempt from the labeling requirements.

Some small businesses have argued that the rule’s testing, labeling, and record-keeping requirements will disproportionally impact smaller firms that aren’t equipped to handle additional costs.

Making water quality data more transparent: Lessons from an annual water quality report

A few weeks ago, I received my water bill in the mail, right on schedule. But this time, it came with a glossy pamphlet containing the annual water quality report. Normally I just toss it into the trash unread. It’s full of small print and lots of numbers, and I was never that concerned about our water quality.

I live in the NC mountains, where the water comes from “pristine mountain springs and streams”. And having grown up in New Orleans— spending 21 years drinking water from the polluted tail end of the Mississippi River— I figured any damage was already done. (But that New Orleans water sure was tasty!)

This time, though, I actually read the entire report. I’d heard about recent water issues in Flint, MI, and other cities, and I do have children who drink the water here. So I looked at this City of Asheville water quality report in detail, and here’s what I discovered.

The report contains a lot of rather informative text about how the City of Asheville treats its water and what possible risks could be present from various contaminants. The centerpiece of the report is a table that lists detected substances in the water. In 2015, 13 substances were detected out of 150 substances sampled for, and those 13 were “well within safe levels”. That sounded good. But then I started looking at the report and wondering about certain things…

Let’s start with lead. The report has this:

City of Asheville water quality report- lead measurements

City of Asheville’s 2015 Water Quality Report: Lead, ppb

The “Highest Level Allowed” (the maximum contaminant level, or MCL) is 15 parts per billion (ppb). I did some searching and found a good article explaining lead sampling in water. If over 10% of tests come back over that level of 15 ppb, then the water utility must warn residents.

Asheville seems to have passed this test (only one sample exceeded the action level). However, the article mentioned above also describes how the tests for Flint, MI had possible problems because the Michigan Department of Environmental Quality threw out two samples. With those samples included, the number of samples over the limit would have exceeded 10%, and water customers would have received a much earlier warning of possible lead issues.

So, back to Asheville. Were any samples thrown out— and if so, why? That information is not in the report.

Let’s take one more example: hexavalent chromium. Here is the City of Asheville report:

City of Asheville water quality report- hexavalent chromium measurements

City of Asheville’s 2015 Water Quality Report: Hexavalent Chromium, ppb

So, the average hexavalent chromium level in the water is 0.05 ppb. But there is no action level given, and the EPA definition text says nothing about any possible side effects. Through more searching, I learned that although hexavalent chromium is a carcinogen, the US EPA does not have a maximum contaminant level (MCL) for this compound.

California has a public health goal of 0.02 ppb, but North Carolina has a public health goal of 0.07 ppb. So, how would I interpret the Asheville value of 0.05 that falls in the middle of those two numbers? At least the report provides the detected range (ND – 0.08), so the maximum level in any sample was only a bit higher than the 0.07 level.

These two examples are not meant to disparage Asheville’s Annual Water Quality Report— it is a great way to deliver some basic information to water users. But for motivated water users, the report will lead to other questions— to answer these questions would require more context or a deeper dive into the actual data. Also, while I’m personally fairly tech-savvy and scientifically literate, many water users may lack the numerical and verbal literacy skills needed to understand the report.

For some closing thoughts:

How can water utilities make their sample data more transparent and available to users who want to take the “deeper dive”? How can users learn about sampling processes and decisions made— for example, “were any lead samples rejected, and why?”
How do users evaluate risks from compounds without EPA maximum contaminant levels, especially when states and regulators have conflicting levels?
How do water utilities present trend information and changes in water quality procedures over time? The 2015 report only shows data from that year. I dug up some older reports and found that hexavalent chromium was not detected at all in 2014. So what caused the detects in 2015? Also, lead was sampled at 100 sites in 2014, but only 50 sites in 2015. Why was the number of samples cut in half?
How do you balance presenting too much information to the public (causing information overload) with presenting too little (causing users to be uninformed about quality issues)? Is there a way to show key information, but let users drill down into actual sampling data results for further details?
As a follow up to that last question— if you allow public access to sampling data, how do you ensure customers can interpret that data correctly, if those customers lack knowledge of sampling processes and any statistical techniques used?
Can the power of the internet be harnessed to distribute this data and make it understandable to customers? Are there tools that customers can use to explore the data on their own and see key findings and trends? I could not find anything online for Asheville.
Finally, given that a certain level of technical understanding is needed to read the Annual Report and explore any actual data— do we need a neutral party to serve as interpreter and interlocutor for the public when dealing with water utilities? Who would play that role?

Other Locus contributors will explore some of these issues in future posts. In the meantime, please share your own thoughts and ideas in the comments section below.

About guest blogger— Dr. Todd Pierce, Locus Technologies

Dr. Pierce manages a team of programmers tasked with development and implementation of Locus’ EIM application, which lets users manage their environmental data in the cloud using Software-as-a-Service technology. Dr. Pierce is also directly responsible for research and development of Locus’ GIS (geographic information systems) and visualization tools for mapping analytical and subsurface data.

EPA plans to regulate carbon emissions from aircraft

The US Environmental Protection Agency on Monday announced plans to limit carbon emissions from aircraft.

The EPA issued a final scientific assessment that concluded that carbon emissions from aircraft endanger public health and welfare, a legal prerequisite the agency must take before regulating those emissions.

EPA officials said last year when first proposing the aircraft scientific assessment that any regulation would be implemented in coordination with the International Civil Aviation Organization, a branch of the United Nations, which is drafting a global standard for airline carbon emissions.

Emissions from aircraft represent about 2% of total global carbon emissions, and the U.S. is the largest contributor to global aviation greenhouse gasses, according to federal data. The EPA said aircraft are the third-largest source of greenhouse gas emissions in the U.S. transportation sector, accounting for about 3% of such emissions in the country.

EPA has already set effective GHG standards for cars and trucks. EPA anticipates moving forward on standards that would be at least as stringent as ICAO’s standards.

Military and small piston-engine planes often used for recreational purposes would be exempt from the new regulation. Excluding these two categories, the EPA’s scientific finding applies to 89% of all U.S. aircraft carbon emissions.

Airlines for America, the trade association representing U.S. airlines and air cargo carriers, said it commends the EPA’s action because it is working within the coming international framework.

In 2009 the International Air Transport Association, a global trade group, agreed to achieve carbon-neutral growth by 2020, meaning any future growth in air travel wouldn’t produce a net increase in carbon emissions.

Then, from 2020 through 2050, the industry aims to reduce its 2005 emission levels by half, largely through the use of sustainable fuels. The effort to use sustainable fuels has already started, and manufacturers and airlines support of alternative fuels is high.

EPA to regulate aircraft emissions.

To that end, the US biofuels leader, Amyris, Inc. and oil company Total have partnered to develop an alternative aviation jet fuel made with a sustainably-sourced hydrocarbon using Amyris’s proprietary synthetic biology platform. In 2014, Amyris received industry acceptance and regulatory approval for renewable jet fuel in key U.S., European and Brazilian markets. The New York Times writes that Amyris renewable jet fuel “holds the elusive promise of better energy security, reduced carbon emissions, and lower fuel costs. Amyris’ jet fuel can reduce greenhouse gas emissions by up to 80 percent compared with petroleum fuels, when compared unmixed to petroleum fuels on a one-to-one basis, according to Amyris. Renewable fuels like Amyris farnesane ‘would help reduce the carbon footprint of commercial aviation,’ the Federal Aviation Administration said.”

Amyris announced that, on May 29, 2016, Cathay Pacific commenced a two-year program of flights from Toulouse to Hong Kong using Amyris renewable jet fuel. The initial 12-hour flight was the longest flight using a renewable jet fuel to date, further underpinning the ‘drop-in’ characteristics of Amyris Biojet fuels. Cathay took delivery of a new Airbus A350-900 that flew from the Airbus facility in Toulouse, France, to Hong Kong using a 10% biofuel jet blend provided by Amyris with the commercial and industrial support of Total S.A. The combination of the new airplane’s improvements in fuel efficiency (about 25% better than current aircraft) and the fuel’s properties resulted in an estimated 30% reduction in CO2 emissions according to Cathay when compared to comparable flights in recent-generation aircraft using fossil fuels.

Why SaaS multitenancy is key to successful and sustainable EHS management

A recently published survey by a research analyst firm indicates that 90 percent of EHS software applications installed today are single-tenant on customer premises or single-tenant, vendor hosted. Only 10 percent are multitenant, vendor-hosted. In other words, most of the vendors in the EH&S space do not run a single version of their software maintained at one location. Instead, they run multiple copies at a single or multiple locations, with the high likelihood that these multiple copies are not alike, but instead represent multiple versions or contain specific customizations for individual customers. This model is crushing their growth and scalability potential.

Locus delivers EHS+S SaaS solutions as highly scalable, Software as a Service (SaaS) application and platform services on a multitenant technology architecture. Multitenancy is an architectural approach that allows Locus to operate a single application instance for multiple organizations, treating all customers as separate tenants who run in virtual isolation from each other. Customers can use and customize an application as though they each have a separate instance, yet their data and customizations remain secure and insulated from the activities of all other tenants. Locus multitenant services run on a single stack of hardware and software, which is comprised of commercially available hardware and a combination of proprietary and commercially available software. As a result, Locus can spread the cost of delivering EHS SaaS services across user base, which lowers the cost for each customer. Also, because Locus does not have to manage thousands of distinct applications with their business logic and database schemas, we believe that we can scale our business faster than traditional software vendors. Moreover, we can focus our resources on building new functionality to deliver to customer base as a whole rather than on maintaining an infrastructure to support each of their distinct applications.

Multitenancy also allows for faster bug and security fixes, automatic software updates and the ability to deploy major releases and frequent, incremental improvements to Locus’ services, benefiting the entire user community. Our services are optimized to run on specific databases and operating systems using the tools and platforms best suited to serve customers rather than on-premise software that must be written to the different hardware, operating systems and database platforms existing within a customer’s unique systems environment. Locus developers build and support solutions and features on a single code base on our chosen technology platform. Locus efforts are focused on improving and enhancing the features, functionality, performance, availability and security of existing service offerings as well as developing new features, functionality, and services.

Locus customers and third-party developers can create apps rapidly because of the ease of use of Locus Platform and the benefits of a multitenant platform. Locus provides the capability for business users to configure applications easily to suit their specific needs.

Also, Locus multitenant cloud platform makes it possible to use a remarkably small number of servers as efficiently as possible. When organizations move business applications to Locus, they can significantly reduce their energy use and carbon footprints compared to traditional on-premises or single-tenant or ASP solutions

Locus built and maintains a multitenant application architecture that has been designed to enable service to scale securely, reliably and cost effectively. Locus’ multitenant application architecture maintains the integrity and separation of customer data while still permitting all customers to use the same application functionality simultaneously.

Both Locus and its data centers providers hold independent AICPA SOC1 (SSAE16) and SOC2 certification.

Locus Technologies introduces indoor air management application

The Locus indoor air management application is fully integrated with the dynamic Locus Platform and will automate indoor air management for small and large enterprises.

MOUNTAIN VIEW, Calif., 6 June 2016 — Locus Technologies (Locus), the leader in cloud-based environmental compliance and sustainability management software, introduces an all-new vapor intrusion and indoor air management application to its newest platform to redefine how companies organize, manage, and report their indoor air and vapor intrusion data. The Locus platform— a true, multi-tenant SaaS— offers a highly configurable, user-friendly interface to meet individual organizations’ environmental management needs.

Indoor air quality is becoming an important environmental and chemical exposure challenge for many companies whose properties may be impacted by contaminated groundwater or soil that release vapors or fumes. Once the indoor air quality problem is identified, it follows a lengthy investigation that can involve several phases of sampling (including soil-gas, subslab, pathway, and ambient indoor air samples) using either active or passive sampling techniques. Samples are typically composited over time periods that can range from hours to weeks. A substantial amount of additional metadata is collected surrounding each sampling event, including information on the building construction, layout, occupancy, chemical use, and heating and ventilation systems.

All these activities generate large quantities of data, which until now were managed primarily by spreadsheet scattered on laptops or desktops. Locus’ new application brings an organized approach and workflow process to schedule, sample, and manage analytical results stemming from investigation and ongoing monitoring programs. Tools are also included to track the status and effectiveness of mitigation efforts related to indoor air quality. The data are easily summarized for review through reporting and built-in mapping tools, which can identify adjacent properties at potential risk for indoor air quality issues. Plus, if a customer is already a subscriber to Locus EIM, Incidents, or other Locus Platform applications, they can correlate data among various applications and facilitate finding the cause of degradation of the indoor air quality.

“Indoor air quality and vapor intrusion are gaining more and more attention from regulators, property owners, and managers of environmental sites. These projects generate a large volume of structured and unstructured data as part of the investigation and mitigation processes. To successfully compile and review this information, companies need a software that can manage these various data types and allow quick review and decision making. The right software can reduce the stress, time, and potential inaccuracies associated with these projects.” said Wes Hawthorne, Senior Vice President of Locus.

The new TSCA law not REACH (in data requirements)

After a bipartisan accord, the US Congress overhauled the 40-year-old Toxic Substances Control Act (TSCA), with legislation to give the EPA greater powers to regulate about 100 hazardous chemicals. This is the first major statutory update to US environmental law that’s been passed in over 25 years. On a 403-12 vote, the U.S. House of Representatives on 24 May 2016 approved bipartisan legislation to amend the key provisions of the TSCA.

Under existing law, the Environmental Protection Agency (EPA) has succeeded in regulating only five toxic chemicals since 1976, prompting public health advocates to decry TSCA as broken. Part of the problem is that the law grants EPA only 90 days to decide whether a new chemical poses “unreasonable risk” before it can enter the market, and agency officials say they rarely get the toxicity data they need to make that call in time.

The compromise legislation will remove those procedural hurdles, require EPA to focus on “high priority” chemicals such as arsenic and asbestos, and give the agency new tools to collect data from companies. It also grandfathers in some existing state chemical safety laws, such as those enacted under California’s Proposition 65, but limits states’ authority to create their own restrictions on chemicals in the future. State pre-emption was a key point of contention between Democrats and Republicans during negotiations.

So how does the new TSCA law compare to the EU REACH program? REACH (Registration, Evaluation, Authorization and Restriction of Chemical substances) is a regulation of the European Union, adopted to improve the protection of human health and the environment from the risks that can be posed by chemicals. REACH also promotes alternative methods for the hazard assessment of substances to reduce the number of tests on animals. Under the REACH Regulation, companies are responsible for providing information on the hazards, risks and safe use of chemical substances that they manufacture or import.

One notable difference between REACH and TOSCA is how they support downstream users in implementing their chemicals management programs. Regarding knowing chemicals in products, REACH provides clear direction that downstream users must communicate uses up to suppliers and know and publicly disclose (if requested) if their product contains substances of very high concern (SVHC). The TSCA does essentially nothing to support downstream users in knowing chemicals in products and disclosing them to the public, and its requirements for upstream communication to suppliers on uses are uncertain.

Significantly, REACH requires companies to provide minimum data sets on the inherent hazards of chemicals. This data enables downstream users to evaluate and compare chemicals on their hazard characteristics. TSCA, while expanding the ability of the US EPA to require testing of chemicals, explicitly prohibits the agency from requiring minimum data sets.

While it is important to avoid the unnecessary testing of chemicals, it is also vital to have a data set on chemicals that enable their comparison on a common set of endpoints. The EPA needs the authority to establish a minimum data set on chemicals, although this may differ depending on the specific chemical.

On assessing the hazards of chemicals, the new US law falls short of REACH and impedes harmonizing European and US requirements for chemical testing. Given that most US chemical companies sell into the European market, and therefore are already meeting those requirements, it is inefficient and wasteful to establish a totally separate testing regime in the US.

To support the use of inherently safer chemicals, REACH provides a clear and more streamlined process for identifying and restricting SVHCs. Over the course of seven years, the Regulation has identified 161 Candidate SVHCs, while over five years, the US bill only requires the designation of 25 high priority chemicals and with new law extending that number to about 100 chemicals. Harmonization, consistency, and predictability are critical for downstream users, and these elements are all lacking in the new TSCA law.