Ann Grimaldi

U.S. retailer Target has announced that it will begin phasing out certain chemicals of concern from products sold at its stores. Additionally, suppliers will be required to provide a full list of ingredients for products of certain categories. The company’s new plans are a part of its new chemical policy that involves “identifying, reducing, and eliminating substances in our products, supply chain and operations when they demonstrate a potential risk to our guests or team members.” Target’s announcement, which outlines steps to be taken for chemical management, transparency, and innovation, also includes investment of up to $5 million in “green…

On January 30th, 2017, President Donald Trump issued an Executive Order on Reducing Regulation and Controlling Regulatory Costs, mandating that for every regulation issued by a federal department, two regulations be identified for repeal. The order additionally states that for the 2017 fiscal year, the total cost of any new regulation should be no greater than zero after being offset by the elimination of existing costs of at least two prior regulations, unless otherwise authorized by the Director of the Office of Management and Budget (OMB). Beginning in fiscal year 2018, the executive order requires the Director to identify the total…

The California Department of Toxic Substances Control (DTSC) published draft guidance discussing methods for conducting Alternative Analyses (AA) under the Safer Consumer Products (SCP) regulation on December 12th, 2016. Public comments are due by February 3rd, 2017. The DTSC is particularly interested in comments regarding the clarity and usefulness of the Draft Guide. Significantly, DTSC cannot finalize its initial Priority Products list until it “make[s] available on its website guidance materials to assist persons in performing AAs” (Title 22, California Code of Regulations, Section 69505.) Thus, finalizing this AA guidance is essential for DTSC to move forward with its first…

On January 12, 2017, the California Office of Environmental Health Hazard Assessment published a notice of revisions to the new Proposition 65 safe harbor warning regulations. These revisions, which OEHHA characterizes as “non-substantive,” consist largely of corrections to grammar and punctuation. However, one may have a broader, more substantive effect. In the text of each of the new safe harbor warnings, OEHHA has included a colon after the word “WARNING.” A useful clarification, the colon now appears in the portion of the regulations requiring the word “WARNING” – and now the colon itself – to be in bold font. Thus,…

New California air regulatory requirements affecting adhesives, degreasers and coatings took effect on January 1st, 2017. The new requirements, promulgated by the California Air Resources Board (ARB), are contained in Sections 94507-94517 and Sections 94520-94528 of Title 17, California Code of Regulations. These changes consist of volatile organic compound (VOC) standards, the prohibition of chemical compounds with a Global Warming Potential Value (GWP) of 150 or greater, the prohibition of specific toxic compounds, and reactivity limits for certain aerosol coating products. These regulations apply to any person who sells, supplies, or manufactures the affected products for use within the state…