On September 12, 2014, DTSC issued its draft three-year Priority Product Work Plan.  The Plan outlines the types of products the Department will look at over the next three years for new product-chemical combinations to be added to the Priority Products list.  The issuance of the Plan follows DTSC’s addition of the first three proposed product-chemical combinations in March 2014, and is based in part upon comments from DTSC’s Green Ribbon Science Panel earlier this summer.

Selecting product categories

In selecting product categories for the Plan, DTSC used the following screening priorities:

  • Product categories with products with clear pathways for dermal, ingestion or inhalation exposure
  • Product categories with chemicals found in biomonitoring studies
  • Product categories with chemicals observed in indoor air quality studies
  • Product categories that include product-chemical combinations that impact sensitive subpopulations
  • Product categories that contain chemicals that have aquatic resource impacts and/or which have been observed through water quality monitoring

Six product categories

Using these screening priorities, DTSC identified six product categories:

(1)   Beauty, personal care, and hygiene products

DTSC provided a number of product examples, including body wash and soaps, deodorants, lip balms and gloss, lotions, ointments, pomades, hair care products, cosmetics, and nail care products. DTSC also provided examples of chemicals it will be considering for product-chemical combinations, including aldehydes, formaldehyde, alkyl phenols and ethoxylates, azo dyes, coal tars, lead, and lead acetate, phthalates, triclosan, and toluene.

(2)   Building products and household, office furniture and furnishings

While this category is broad, DTSC has limited the scope for building products to just paints, adhesives, sealants, and flooring.  It has limited the scope for furnishings to just home and office furnishings treated with flame retardants or stain resistant chemicals (bedding, seating, and fabric and textile furnishings). DTSC provides examples of chemicals, including Brominated or chlorinated organic compounds, organophosphates, isocyanates, heavy metals in dyes and pigments, perfluorinated compounds phthalates, and VOC.

(3)   Cleaning products

Examples include bathroom cleaners, carpet cleaners, detergents, floor waxes, general-purpose cleaners, scouring cleaners, spot removers, and window cleaners. Chemicals of note include alkyl phenol and ethoxylates, hydrogen Fluoride, phthalates, triclosan, and VOC.

(4)   Clothing

DTSC listed body wear, sleepwear, sportswear, and underwear as examples of products it will be examining. Chemicals include alkyl phenol and ethoxylates, aromatic amines and azo dyes, chlorinated paraffins, halogenated compounds, and organophosphates, perfluorinated compounds, formaldehyde, phthalates, and triclosan.

(5)   Fishing and angling equipment

DTSC will be looking at heavy metals in fishing weights and gear.

(6)   Office machinery

Examples include printer inks, specialty paper (including receipt paper), and toner cartridges. Chemicals under consideration include azo dyes, bisphenols, phthalates, and VOC.

Common themes

A review of the product examples and chemicals shows some common themes. A majority of the product categories involve prolonged or repeat dermal contact over substantial time periods. More pronounced is the trend in chemicals, as many of the chemicals appear in connection with a number of product categories, especially phthalates, triclosan, VOC, azo dyes, and flame retardants.


The Plan is now open for public comment until October 13, 2014, and DTSC will hold two public workshops. The first will take place in Sacramento on September 25, 2014, and the second will take place in Cypress on September 29, 2014.  Once the public comment period closes, DTSC will review and respond to the comments on the way to finalizing it.

After finalizing the Plan, DTSC can propose product-chemical combinations, or Priority Products, at any time over the subsequent three-year period. This will start the regulatory process (public comment, etc.) for that Priority Product, which can take up to one year. In all likelihood, we are probably a couple of years away from new Priority Products. However, manufacturers, distributors, and retailers should see the writing on the wall with these product categories and chemicals.