Will Troutman (US)

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CPSC targets hoverboards

Late last week, the CPSC Office of Compliance and Field Operations issued a letter on the CPSC website to “Manufacturers, Importers, and Retailers of Self-Balancing Scooters” that ultimately makes a new voluntary safety standard for self-balancing scooters, typically called “hoverboards,” mandatory. The “voluntary” standard On February 2, 2016, UL issued its standard, UL 2272 – Outline … Continue reading

The mysterious world of green chemistry: Washington’s 180 on cadmium and phthalates

In our previous post on Washington’s Children’s Safe Products Act, we focused on the Act’s reporting requirement. But the Act also contains provisions prohibiting the sale of children’s products containing certain chemicals above the following limits: Lead: 90 parts per million (ppm) Cadmium: 40 ppm; and Phthalates in children’s products in excess of 1,000 ppm … Continue reading

The mysterious world of green chemistry: Washington’s green chemistry law

This week we turn from federal law to the patchwork of state laws that cropped up due to TSCA’s failures. First up is Washington’s green chemistry law: the Children’s Safe Products Act. The CSPA requires manufacturers of children’s products sold in Washington to file a report with the state if their product contains certain chemicals. … Continue reading

The mysterious world of green chemistry: TSCA reform

The Toxic Substances Control Act and resulting regulations are the federal regulatory structure for chemicals management. TSCA (tah-ska) authorizes the US EPA to review and regulate chemicals. For many existing chemicals, TSCA requires manufacturers to work with EPA to fill in data gaps on risk, and new chemicals must undergo pre-market screening. If EPA determines a … Continue reading

The mysterious world of green chemistry: a miniseries

Among the many consumer product buzzwords, green chemistry may be on top of the pile. Depending upon your job, industry, or viewpoint, it also may have a variety of meanings, triggering still other buzzwords — alternatives assessment; restricted substances list; chemicals of concern; life cycle assessment. In the same vein as our California Proposition 65 miniseries, we here at … Continue reading

Update: OEHHA issues revised Prop 65 warning regulations

Continuing the saga of revisions to the Prop 65 regulations, OEHHA has repealed its January 2015 clear and reasonable warning proposed rulemaking and replaced it with a new proposed regulation. The new proposed rulemaking addresses many concerns raised by the business community, either addressing the issue or explaining why OEHHA will not change it.  A … Continue reading

New REACH guidance on substances in articles

ECHA has recently issued revised guidance on substances in articles under REACH. The guidance follows a September 2015 ruling from the European Court of Justice that invalidated ECHA’s prior interpretation – effectively turning this aspect of REACH compliance on its head. The REACH Regulation The REACH Regulation addresses the production and use of chemical substances … Continue reading

The mysterious world of green chemistry: A miniseries

Among the many consumer product buzzwords, green chemistry may be on top of the pile. Depending upon your job, industry, or viewpoint, it also may have a variety of meanings, triggering still other buzzwords — alternatives assessment; restricted substances list; chemicals of concern; life cycle assessment. In the same vein as our California Proposition 65 miniseries, we here at … Continue reading

New California consumer products legislation

Last week marked the last chance for California Governor Jerry Brown to sign or veto legislation the California Legislature passed this year. The legislation goes into effect January 1, 2016. Although it was a quiet year for consumer products, several of the new laws are significant. Here is a rundown of relevant bills Governor Brown signed: AB … Continue reading

ARB starts 2013 consumer products survey enforcement roundup, launches 2014 portal

Recap on 2013 reporting and enforcement ARB reported registrations for 1,400 Responsible Parties and 700 formulators registering.  Of those, 1,300 have reported completion of the survey. ARB has published a summary of the 2013 data, which includes listing the Responsible Parties that reported. ARB has started sending letters to those who registered, but did not complete the … Continue reading

California to open rulemaking into Prop 65 lead levels

In response to a petition from the Center for Environmental, the California Office of Environmental Health Hazard Assessment will initiate a rulemaking to update the current 0.5 µg/day safe harbor level for lead. The implications are huge, as years of Prop 65 settlements over lead have been premised on the existing safe harbor level. CEH argues … Continue reading

Now that you have done the survey, don’t forget the VOC limits….

With the data demands of the California Air Resources Board Consumer Products Survey, it can be easy to miss the forest for the trees. The real concern if you are a manufacturer, importer, or private labeler of consumer products sold in California should be the underlying ARB Consumer Products Regulation. VOC limits The ARB Consumer Products Regulation establishes … Continue reading

Just when you thought you were out…2014 consumer products survey launches July 1

For many of you, responding to the 2013 California Air Resources Board consumer products survey was a real challenge. Unfortunately, the Board doesn’t plan to give you much time to recover from the trauma. The 2014 survey data entry period begins on July 1, with all data due by November 1. Responsible Parties will have … Continue reading

California seeks to expand flammability labeling law to children’s products

California recently required labeling on upholstered furniture to identify whether it contains flame retardant chemicals. Now the Legislature is seeking to expand that requirement to certain children’s products. Earlier this month, the Senate approved SB 763, which would require labeling on a variety of upholstered (stuffed or filled) products intended for infants and children under … Continue reading

California puts BPA back on Prop 65 list

Effective May 11, 2015, California’s Office of Environmental Health Hazard Assessment has put bisphenol A, or BPA, back on the Proposition 65 list. This most recent listing is through the “state’s qualified expert” listing mechanism, as the OEHHA Developmental and Reproductive Toxicant Identification Committee concluded that scientifically valid testing according to generally accepted principles clearly … Continue reading

CPSC product recall weekly rundown

Here is a rundown of CPSC recalls this week: Felt Bicycles Recalls Cruiser Bicycles Due to Crash Hazard IKEA Expands Recall of Crib Mattresses Due to Risk of Entrapment Branded LLC Recalls Kaleidoscope Toy Due to Choking, Laceration Hazards; Offered Exclusively at H-E-B Stores in Texas Pedego Recalls Electric Bicycle Batteries Due to Fire Hazard … Continue reading

CPSC continues to show it means business with Section 15(b) reporting

CPSC continues to show its intention to use Section 15(b) reporting claims as a tool to punish companies and deter the consumer products industry from taking its reporting obligations lightly. Earlier this year, CPSC Chairman Kaye stated that he is directing CPSC staff to push for significantly higher civil penalties for reporting violations settlements to … Continue reading

CPSC product recall weekly rundown

Here is a rundown of CPSC recalls this week: Roberta Roller Rabbit Recalls Children’s Pajama Sets Due to Violation of Federal Flammability Standard Shark Vacuum Cleaners Recalled by Euro-Pro Due to Shock Hazard J. Crew Expands Recall of Baby Coveralls Due to Choking Hazard (Recall Alert) Trek Recalls Bicycles Equipped with Front Disc Brakes to … Continue reading

CPSC product recall weekly rundown

Here is a rundown of CPSC recalls this week: Gena Accessories Recalls Women’s Scarves Due to Burn Hazard, Violation of Federal Flammability Standard Civia Cycles Recalls Hyland Bicycles, Aluminum Civia Fenders Due to Crash Hazard Goochie Goo Garbs Recalls Children’s Sensory Grab Garb Blankets Due to Laceration Hazard Toro Recalls Recycler Mowers Due to Injury … Continue reading

CA issues final three-year work plan for green chemistry

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 … Continue reading

DOJ issues compliance guidance on CA human trafficking law

Following up on our recent update, the California Department of Justice has started issuing notifications to California businesses stating that they are subject to the requirements of the Transparency in Supply Chains Act of 2010 (SB 657). DOJ has also issued a long-awaited guidance document explaining its interpretation of the Act’s requirements. Compliance letters The … Continue reading

CPSC product recall weekly rundown

Here is a rundown of CPSC recalls this week: Stokke Recalls Trailz Strollers Due to Fall Hazard (Recall Alert) Bauer Hockey Recalls Hockey Goalie Masks and Replacement Wires Due to Facial Impact or Laceration Hazard Blinds To Go Recalls Window Shades Due to Strangulation Hazard Giant Factories Recalls Water Heaters Due to Risk of Fire, … Continue reading
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