California Green Chemistry Proposed Regulations Revised Yet Again

On January 28, 2013, the California Department of Toxic Substances Control (DTSC) issued further revisions to its proposed Safer Consumer Product Alternatives regulations, more commonly referred to as the "Green Chemistry" regulations.  This is one of a number of revisions DTSC has made to get the Green Chemistry program off the ground. 

Consistent throughout the process, the basic four-step structure of the regulations remains unchanged: 

1. Identification of Chemicals of Concern,
2. Development of a Priority Products list for which Alternatives Analyses must be conducted,
3. Performance of an Alternatives Analysis for each Priority Product by manufacturers, importers, or retailers, and
4. DTSC's "regulatory responses" following the Alternatives Analysis, which, at their most extreme, may result in prohibiting the sale of the product in California.

The 30-day public comment period on this latest revision ends on February 28, 2013.

  

Upcoming:  Josh Bloom, a Barg Coffin partner and Chair of the Bar Association of San Francisco's Environmental Law Section, will be moderating and speaking at the Bar's May 2, 2013 Green Chemistry Program, featuring Debbie Raphael, Director of DTSC.  The program will run from 5:30pm-7:30pm, at One Embarcadero Center, 18th Floor, San Francisco, at the offices of Nixon Peabody.  Further details and registration materials forthcoming, but feel free contact Barg Coffin for more information.

 

--Josh Bloom

 

Barg Coffin has an extensive consumer products practice, including Green Chemistry, Proposition 65, metals in jewelry, and CPSIA laws.  If you would like more information about the proposed Green Chemistry regulations, please contact Josh Bloom jab@bcltlaw.com, (415) 228-5406, or Rick Coffin rcc@bcltlaw.com, (415) 228-5420.  On the web at www.bcltlaw.com