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DTSC Announces SCP Program Webinar on Food Packaging Evaluation

The California Department of Toxic Substances Control (DTSC) has announced it will hold a webinar on October 24, 2019 to present its initial findings from its food packaging evaluation under the Safer Consumer Products (SCP) Program. DTSC undertook this evaluation in connection with implementing its 2018-2020 Priority Product Work Plan.

In that Work Plan, DTSC identified seven product categories that it intends to evaluate under its SCP Program authority as possible Priority Products. Priority Products are product-chemical combinations identified by DTSC through formal rulemaking. Once identified, Priority Products must undergo an alternative analysis assessment to ascertain if “safer” alternatives to the chemical can be used.

In connection with food packaging, the Work Plan states that DTSC’s goal is to “protect Californians from chemicals that migrate into food from food packaging.” DTSC further explains:

Several studies have shown that chemicals can migrate directly into food from some consumer products. Because some chemicals can move from product packaging into food, potential exposures to Californians may be significant and widespread. Numerous stakeholders identified food packaging as an important category and requested that DTSC address it.

Still, DTSC acknowledges that food packaging already is regulated by under other programs, including by the Food and Drug Administration pursuant to the federal Food, Drug and Cosmetic Act. The statute that authorizes the SCP Program specifically prohibits DTSC from adopting duplicative or conflicting regulations for product categories already regulated. The upcoming webinar, in addition to presenting DTSC’s evaluation done to date, also may reveal the agency’s position as to whether this category is already fully regulated.

 

Grimaldi Law Offices has been advising clients for over 20 years on chemical and product regulation. For knowledgeable advice and in-depth analysis on your chemical regulatory compliance obligations, contact Grimaldi Law Offices at (415) 463-5186 or email us at [email protected].

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Ms. Grimaldi maintains a diverse environmental law practice focusing on chemical and product regulation and litigation defense. Her practice areas include Proposition 65, California's Safer Consumer Products Regulations, California's Rigid Plastic Packaging Container Act and the federal Toxic Substances Control Act. Ms. Grimaldi graduated from the University of California Hastings College of the Law magna cum laude and holds a Bachelor of Science Degree in Bacteriology from University of California, Davis. Prior to attending law school, she worked as a research assistant in laboratories at the University of California, San Francisco Cancer Research Institute and at the University of California, San Francisco School of Medicine.