Tag Archives: DTSC

Paint Strippers Containing Methylene Chloride – State of California’s 3rd Priority Product Proposed

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On November 16, 2017, the State of California’s DTSC proposed to add its third product-chemical combination to its priority products list for regulation under its green chemistry/safer consumer products rules.   We are all still waiting to see the first, or any product, undergo the voluminous data, reporting and analytical requirements of the regulations and it remains to be seen if any ever will.   The third product to be proposed is “paint or varnish strippers containing methylene chloride” defined as “any product designed to break down paint, varnish, or any other surface coating [...]Read more

New Regulatory Hurdles Proposed for Hazardous Waste Facilities in California

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On September 22, 2017, DTSC commenced the public comment period for its proposed regulations to update the criteria for the issuance of hazardous waste facility permits and permit modifications pursuant to SB 673. The 70 pages of the proposed regulations are a radical departure from the permitting process of the past 25 years in California. In some respects, the burdens proposed are so high that one wonders if this portends the end of hazardous waste facilities in the state. On the positive side, this will have local EJ (environmental justice) communities cheering and it does present an enormous [...]Read more

Maybe 2018 will be the year we finally see how the California Safer Consumer Product Regulations will work in practice? Spray Polyurethane Foam may be first up at bat

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DTSC has released the rulemaking for its second selected “priority product” which is spray polyurethane foam systems with unreacted methylene diphenyl diicyanates. This is a product that is actually manufactured and sold in California and thus if adopted, the program’s regulatory requirements would attach to an actual entity. (As compared to the first “priority product” DTSC selected –see children’s foam-padded sleeping products   - which we understand no one actually makes or sells (and begs the question as to how the State of California could select it as a “priority”?) Makers [...]Read more

California Releases its First Draft of its Alternatives Analysis Guide (AA Guide)

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All manufacturers and sellers of consumer products into California should take note.    California has just released its first draft of stage one of its Alternatives Analysis Guide (AA Guide).  You can read all 103 pages here. If your product is selected as a “priority product” under the California Safer Consumer Product Regulations, then your company will be required to prepare and submit for public review an alternatives analysis (AA).  Learn more here, here or here. An AA is a brand new paperwork beast.  It is in parts a large CEQA/NEPA-type document, in parts a hazard assessment, [...]Read more

Global Manufacturers Take Note: DTSC’s Safer Consumer Products Priority Product Work Plan Released Today

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The final version of the California Safer Consumer Products (SCP) Priority Product Work Plan for 2015-2017 can now be viewed on the California Department of Toxic Substances Control’s (DTSC’s) website. The goal of the SCP program is to identify specific products containing potentially harmful chemicals and to ask manufacturers to determine (1) whether the chemicals are necessary; and (2) whether there are safer alternatives. The Work Plan issued in final form today identifies product categories from which such so-called “Priority Products” will be researched and selected for the next [...]Read more

California DTSC to Hold Workshops on Priority Product Work Plan

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The California Department of Toxic Substances Control (DTSC) will hold two workshops later this month on its draft Priority Products Work Plan, which will be released later this month prior to the workshops. The workshops, which will be held on August 19 and August 25, will provide an overview of the work plan and provide detailed information on how future Priority Products will be listed. The draft work plan will be open to public comment once it is released. We will provide more details on the work plan as well as an update on the workshops later this month. In March, DTSC announced their [...]Read more

DTSC Releases Initial Chemical List (Candidate Chemicals) for the Safer Consumer Product Regulations

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The California Department of Toxic Substances Control (DTSC) has released its initial list of candidate chemicals pursuant to its Safer Consumer Product Regulations (advisory). A candidate chemical is defined as one that exhibits a “hazard trait and/or an environmental or toxicological endpoint” and is found on one or more authoritative lists under section 69502.2(a) or listed by the DTSC using criteria found in section 69502.2(b). The chemicals on this initial candidate list will form the set of chemicals for which DTSC may commence seeking toxicity data and their presence in products sold [...]Read more

California Safer Consumer Product (Green Chemistry) Regulations – Final Text and FSOR

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On July 18, 2013, the California DTSC submitted the final regulatory text and the entire rulemaking package, which comprised nine (9) volumes of 3-4 inch binders. Most of the rulemaking package is available on the DTSC website, however the final regulatory text and the final statement of reasons (FSOR) are not. The final regulatory text is still subject to the review and approval of the Office of Administrative Law (OAL), but it is likely that this text represents for the most part what will be the final set of regulations. [...]Read more