On behalf of its 12 member companies, the U.S. Tire Manufacturers Association (USTMA) submitted formal comments in support of the proposed rulemaking by California’s Department of Toxic Substances Control (DTSC) to list 6PPD in tires as a priority product in the state’s Safer Consumer Products (SCP) program.

USTMA highlighted four primary points in its formal comments to DTSC:

• USTMA supports a review of 6PPD in tires under the SCPR.
• Protection materials, such as 6PPD, are essential for tire performance and safety and any potential alternative must continue to ensure compliance with Federal Motor Vehicle Safety Standards (FMVSS). 6PPD provides critical functions in manufacturing safe and durable tires.
• As a newly discovered transformation material, the science on 6PPD‐Quinone is still emerging.
• USTMA recommends that the product category “tires” be focused to provide a workable Priority Product to perform an alternatives analysis.