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Safer Consumer Products Regulations — Update

The California Department of Toxic Substances Control continues its efforts to implement the Safer Consumer Products Regulations:

  • The Regulations require DTSC to publish a Priority Product Work Plan by October 1, 2014.  As GLO previously reported, DTSC scheduled two public workshops in August 2014 to discuss the Work Plan, which has yet to be released.  Those workshops have been cancelled.  DTSC expects to release the Priority Product Work Plan in early September 2014 and will reschedule the workshops for as-yet-unknown dates in September.
  • DTSC anticipates the release of the Priority Product List for formal rulemaking sometime in late 2014/early 2015.  As part of the formal rulemaking, DTSC must conduct specific analyses under the California Environmental Quality Act and the Administrative Procedure Act, and also must prepare a multimedia life cycle evaluation for review by the California Environmental Policy Council.
  • DTSC is aiming to finalize its Alternatives Analysis guidance materials by the end of 2014.
  • With the press of mandated milestones, DTSC is not planning any other informational guidance documents or workshops at this time.

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.