On behalf of the American Chemistry Council (ACC), we are submitting comments on the preliminary draft rule language for the Safer Products for Washington (SPW) program. ACC supports strong, science- based regulations that support product safety and the protection of human health and the environment, but we continue to have serious concerns with the way this new program is being implemented and believe that both the final regulatory determination and this preliminary proposed rulemaking is inconsistent with some of the criteria and requirements outlined in the underlying statute (Chapter 70A.350 RCW).