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DTSC Extends Comment Period for Draft Priority Product Work Plan – And Other Safer Consumer Products Regulations Updates

The California Department of Toxic Substances Control has extended the comment period for its draft Priority Product Work Plan to October 21, 2014.  As GLO previously reported, DTSC released the draft Work Plan under the Safer Consumer Products Regulations on September 12, 2014.  The agency encourages comments to be submitted electronically.

DTSC also has released an updated informational list of Candidate Chemicals, and has established an updated electronic database to search for chemicals identified on the list.  As GLO previously reported, the Safer Consumer Products Regulations do not themselves establish a definitive list of Candidate Chemicals.  Rather, chemicals are identified indirectly through a “list of lists” from other programs and jurisdictions.  As those underlying lists expand (or contract), the Candidate Chemicals under the Safer Consumer Products Regulations also expand or contract.  DTSC is required to release and periodically update an “informational” Candidate Chemical list to assist interested persons in identifying Candidate Chemicals.  However, those interested persons must keep in mind that the informational list almost always will be trailing behind the underlying chemical lists that establish the actual universe of Candidate Chemicals.

Finally, the Green Ribbon Science Panel will be meeting October 20-21, 2014 to review and comment on a number of DTSC activities, including the draft Priority Product Work Plan and the still-evolving alternatives analysis guidance.  DTSC’s October 8, 2014 alternative analysis guidance document synopsis, which appears to be only an outline (albeit a detailed one) of regulatory requirements pertaining to alternative analyses, also will be discussed at the meeting.

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.