Legal Blog

The Circular Economy: What It May Mean For Your Business

By Grimaldi Law Associate Jennifer Singh The Circular Economy (CE) concept is a growing trend in sustainability that is gaining popularity worldwide in both the private and public sectors. The phrase describes the global effort made across all industries to reduce waste and redesign the way that finite resources are used to ensure that materials are kept in a loop of reusability for as long as possible. To achieve a CE that produces non-toxic and reliable recycled materials, its proponents maintain that prioritizing chemical standards plays a crucial role. Although chemical legislation has not yet fully adapted to CE approaches,…

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OEHHA Schedules DARTIC Meeting on Cannabis

The California Office of Environmental Health Hazard Assessment (OEHHA) has set December 11, 2019 for the meeting of the Developmental and Reproductive Toxicant Identification Committee (DARTIC). At that meeting, the DARTIC will determine whether to identify the following cannabis-related substances as reproductive toxicants under Proposition 65: cannabis (marijuana), cannabis smoke (marijuana smoke), cannabis extracts, and Δ-9-Tetrahydrocannabinol (THC). OEHHA issued a data call-in request on these substances on March 15, 2019. Several comments were submitted, many of which requested that the DARTIC review be clear about what, exactly, is being considered for listing. For example, the Personal Care Products Council stated…

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Not So Fast…The FTC Issues Warning Letters to CBD Companies

On September 10, 2019, the Federal Trade Commission (FTC), whose mission is “[p]rotecting consumers and competition by preventing anticompetitive, deceptive, and unfair business practices,” issued warning letters to three companies that sell products containing cannabidiol (CBD).  The letters allege that the companies have made unsubstantiated health claims, including claims that the products have been proven to treat anorexia, fibromyalgia and Alzheimer’s disease. According to the FTC, such claims are illegal if made without competent and reliable scientific evidence. These warning letters follow other warning letters issued jointly by the FTC and the Food and Drug Administration (FDA) earlier this year.…

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The First California Preliminary Alternatives Assessment Report Under The SCP Regulation Gets The First Notice of Deficiency

On August 30, 2019, the California Department of Toxic Substances Control (DTSC) issued a Notice of Deficiency to the Preliminary (Stage 1) Alternatives Analysis Report on Methylene Chloride-Containing Paint or Varnish Removers (the PAA Report) submitted by the Halogenated Solvents Industry Alliance (HSIA). The HSIA submitted the report, on behalf of certain companies that manufacture methylene chloride-containing paint removers, pursuant to the California Safe Consumer Products (SCP) Regulation. According to DTSC’s Notice of Deficiency, the HSIA must submit a revised report by October 29, 2019. The PAA Report is the first alternatives assessment report submitted since the SCP regulations were…

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Different Stroke for Different Agencies: What’s The Latest With 1,4-Dioxane?

On June, 28, 2019, the US Environmental Protection Agency released a draft risk evaluation for 1,4-dioxane, concluding that the chemical poses no unreasonable risk to the environment and no unreasonable risks to occupational non-users. Meanwhile, the California Department of Toxic Substances Control (DTSC) has identified 1,4-dioxane in personal care and cleaning products as warranting further review and possible identification as Priority Products under the agency’s Safer Consumer Products (SCP) Regulation. DTSC also is seeking input on a proposed 1 ppm Alternatives Analysis Threshold under the SCP Regulation, a value that would trigger a number of obligations under the program; product…

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