Author Archives: Maya Grasse

Maya Grasse is a senior associate in the firm’s Environment, Land Use & Natural Resources Group. She counsels clients on a range of land use and environmental matters in urban, suburban and rural contexts.  Read More

Prop 65 Warning Regulations Adopted

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Today, September 2, 2016, the California Office of Environmental Health Hazard Assessment (OEHHA) published its notice of adoption of amendments to Prop 65 - essentially overhauling Title 27 of the California Code of Regulations, Article 6, which governs the warning requirements of the Safe Drinking Water and Toxic Enforcement Act The new regulations are not effective until August 30, 2018. In the interim, businesses have the option of complying either with the current regulation, or the provisions of the new regulation. OEHHA has published a side-by-side comparison of the newly adopted [...]Read more

Global Manufacturers: DTSC Announces 45 Day Comment Period on Regulation to List the First of its Proposed “Priority Products”

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The California Department of Toxic Substances Control (DTSC) is proposing to list certain children’s foam-padded sleeping products as “Priority Products” under the Safer Consumer Product (SCP) Regulations and today announced a 45-day comment period that will close on August 29, 2016. The initial list of Proposed Priority Products, published March 2014, had included children’s foam-padded sleeping products, as well as the following categories of products: Paint and Varnish Strippers, and Surface Cleaners containing Methylene Chloride Spray  Polyurethane Foam Systems containing [...]Read more

Historic TSCA Reform Signed Into Law

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The outdated Toxic Substances Control Act (TSCA) has just received the most significant update in decades. On Wednesday, June 22, President Obama signed into law sweeping reforms, which had bi-partisan support in both houses. Last month, the U.S. House of Representatives voted overwhelmingly to approve a revised version of the Toxic Substances Control Act (TSCA) reform bill, H.R. 2576, originally approved by the House last year. The Senate passed the bill on June 7. The newly signed bill was a compromise following House and Senate negotiations to reconcile differences between last year’s House [...]Read more

Short Comment Period for Revised Prop 65 Warning Regulations

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On Friday, March 25, 2016, the California Office of Environmental Health Hazard Assessment (OEHHA) released another set of proposed revisions to the Prop 65 warning label regulations. The comment period is very short – only 15 days.  Members of the public have only until April 11, 2016 at 5:00 p.m. PST to submit comments on the revised regulations.  Requests to extend the comment period are pending, but not guaranteed. OEHAA initiated formal rulemaking for the revisions to Prop 65 warning label regulations in January 2015. That proposal was repealed and replaced with new proposed regulations [...]Read more

County-Level Pharmaceutical Take-Back Programs May Be Spreading in California and Illinois

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Los Angeles County, the nation’s largest County, has proposed a pharmaceutical take-back ordinance that would require businesses to finance a local government program for disposal of unwanted medications and potentially hazardous medical products like needles and syringes. Under the draft ordinance, termed the “Los Angeles County Pharmaceuticals and Sharps Collection and Disposal Stewardship Ordinance,” certain manufacturers, producers, or distributors of covered medications and supplies would be responsible for designing, implementing and financing the collection program. At its March 22, [...]Read more