Consumer Litigation, Consumer Products, Environmental + Natural Resources, Environmental Litigation, Environmental Permitting + Regulation, Product Liability and Counseling, and Proposition 65 + Chemicals
On October 6, 2017, the California Department of Toxic Substances Control (DTSC) announced it is seeking public comment on its new 2018-2020 Priority Product Work Plan (Work Plan) under its Safer Consumer Products (SCP) Program. The SCP Program, also known as the California Green Chemistry Initiative, is an innovative regulatory scheme to evaluate and seek safer substitutes for hazardous chemicals in consumer products.
DTSC seeks public input to evaluate whether certain product/chemical combinations will be targeted for future inclusion in the SCP Program. The candidates under consideration are:
Some of these products were the subject of DTSC’s prior work plan and are suggested to be carried over for inclusion in the new Work Plan.
DTSC requests the public provide comments regarding the above candidates and recommendations as to other product/chemical combinations for regulation, along with supporting documentation including:
With DTSC in the early stages of developing the Work Plan, stakeholders and other potentially regulated parties should consider engaging in the process now. Once the final Work Plan is released, it may be too late to effectively participate in the process of defining the scope and extent of important parts of any new regulations.
DTSC is accepting public comments on the Work Plan until November 6, 2017. Related useful information can be found on the Green Chemistry portal web page at https://www.mofo.com/green-chemistry.
Lois Miyashiro, an environmental analyst in the firm’s San Francisco office, assisted in the preparation of this client alert.
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