March 14, 2014
The California Department of Toxic Substances Control (DTSC) has announced a proposed list of three “Priority Products” under the Safer Consumer Products (SCP) program. Also known as the California Green Chemistry Initiative, it requires that manufacturers seek safer alternative ingredients in their products.
Priority Products are identified as consumer products containing one or more chemicals – known as Candidate Chemicals – that have a hazard trait that can harm people or the environment.
The first Priority Products proposed for regulation are:
- Spray Polyurethane Foam (SPF) Systems containing unreacted diisocyanates
- Children’s Foam Padded Sleeping Products containing Tris(1,3-dichloro-2-propyl) phosphate, also known as TDCPP
- Paint and Varnish Strippers, and Surface Cleaners containing methylene chloride
Why It Matters
Priority Products are selected on the basis of their potential to expose individuals or the environment to the Candidate Chemical within the product, and on the Candidate Chemical’s potential to contribute or cause significant or widespread adverse impacts.
Publication of this draft list of products neither implies that they are banned nor imposes any new regulatory requirements on manufacturers at this time. The list of Priority Products still needs to be finalized via adoption of regulations for each individual Priority Product. Toward that end, the DTSC will hold public workshops and initiate formal rulemakings. Manufacturer requirements to notify the DTSC on their Priority Products and to begin the Alternatives Analysis process do not start until the Priority Product regulations are finalized. Once finalized, the product manufacturer has primary responsibility for compliance. However, if an overseas manufacturer does not comply, then the responsibility falls on the importer first and then on the retailer.
In October of this year, the DTSC will release a second list of Priority Products, and that list is expected to be significantly longer than the first list.
How UL Can Help
Across our global network of laboratories, UL’s third-party testing services can help ensure regulatory compliance with the California Department of Toxic Substances Control requirements.