The California Department of Toxic Substances Control has issued its final 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 upon comments from DTSC’s Green Ribbon Science Panel earlier this summer and public review and comment of of the September 2014 draft.  DTSC ultimately made very few changes from the draft.  The final plan states that DTSC intends to announce up to three new product-chemical combinations in 2015, with an expected increase in 2016 and 2017.

SCP Work Plan

Selecting product categories

In selecting product categories for the Plan, DTSC maintained the screening priorities from the draft:

  • 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 that it will focus on over the next three years to add new Priority Products to the list:

(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
  • Nail care products
  • Sunscreen

Potential candidate chemicals include aldehydes, formaldehyde, alkyl phenols and ethoxylates, azo dyes, coal tars, lead, and lead acetate, phthalates, triclosan, and toluene.

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

DTSC has limited the scope for building products to just painting products, adhesives, sealants, and flooring.  Examples pf potential products include

  • Paints and primers
  • Paint and graffiti removers and cleaners
  • Stain and varnishes
  • Adhesives and glues
  • Caulking
  • Sealants
  • Roof coatings
  • Carpeting
  • Engineered wood and laminate flooring
  • Plywood and OSB subflooring
  • Vinyl flooring

DTSC also added carpet padding and insulation and wall coverings with flame retardants, which were not in the draft plan.

Potential candidate chemicals for building products include brominated or chlorinated organic compounds, organophosphates, isocyanates, heavy metals in dyes and pigments, perfluorinated compounds phthalates, and VOC.

DTSC has limited the scope for furnishings to just home and office furnishings treated with flame retardants or stain resistant chemicals, with the examples of bedding, seating, fabric and textile furnishings.  DTSC added curtains to the final plan.

(3)   Cleaning products

Examples from the draft work plan include bathroom cleaners, carpet cleaners, detergents, floor waxes, general-purpose cleaners, scouring cleaners, spot removers, and window cleaners.

DTSC also added air fresheners, surface cleaners, floor wax removers, deodorizers, and oven cleaners.

Potential candidate chemicals 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. Potential candidate 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, limited to weights and gear that might be consumed by water fowl (in light of the risk of lead poisoning).  DTSC has stated that this excludes large weights, like those used for off-shore salmon fishing.

(6)   Consumable/refillable components of office machinery

Examples include printer inks, thermal paper (receipts paper), and toner cartridges. Potential candidate chemicals include azo dyes, bisphenols, phthalates, and VOC.


DTSC can propose product-chemical combinations, or Priority Products, at any time over the subsequent three-year period. As noted above, it intends to propose at most three new Priority Products in 2015, with more to follow in 2016 and 2017.  Issuance of a proposed Priority Product will start the regulatory process, including public review and comment for that Priority Product, which can take up to one year.  If your product does not appear in the plan right now, don’t breathe easy just yet – DTSC can add new product categories and chemicals if certain criteria are met, include changes in legal requirements or petitions.