California's Department of Toxic Substances Control (DTSC) took an important step in implementing its Green Chemistry program by releasing its list of the first three "Priority Products" that will be targeted for scrutiny under the new Safer Consumer Products regulations. The list of Priority Products subjects certain types of children's sleeping mats, spray foam used in building insulation, and paint or varnish strippers for assessment, reformulation, and possible prohibition. Manufacturers of these products will have to react quickly to respond to the agency's notice.
At the same time, all manufacturers and retailers of consumer products sold in California, even those that do not make or sell any of the three proposed Priority Products, should monitor the rulemaking process and assist the agency in developing a regulatory program that works.
Ensuring a workable program is especially important because California's Green Chemistry program will likely become a model for consumer protection and chemical safety regulations nationwide. Even if other jurisdictions do not adopt similar requirements, the size and importance of the California market dictate that manufacturers and retailers of consumer products sold throughout the country will be forced to comply with the requirements, resulting in de facto nationwide product safety standards.
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This article is presented for informational purposes only and is not intended to constitute legal advice.
