Home > Nanotechnology Columns > Bergeson & Campbell, P.C. > New York Further Delays Enforcement of Household Cleansing Product Information Disclosure Program
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Lynn L. Bergeson Managing Director Bergeson & Campbell, P.C. |
Abstract:
On June 12, 2019, the New York State Department of Environmental Conservation (NYSDEC) announced that it will delay enforcement of the Household Cleansing Product Information Disclosure Program (Disclosure Program) from July 1, 2019, to January 1, 2020.
June 17th, 2019
New York Further Delays Enforcement of Household Cleansing Product Information Disclosure Program
On June 12, 2019, the New York State Department of Environmental Conservation (NYSDEC) announced that it will delay enforcement of the Household Cleansing Product Information Disclosure Program (Disclosure Program) from July 1, 2019, to January 1, 2020. See https://www.dec.ny.gov/chemical/109021.html NYSDEC states in the June 12, 2019, Environmental Notice Bulletin that it will begin enforcing any violations of the required disclosure as of January 2, 2020. See https://www.dec.ny.gov/enb/20190612_not0.html According to the notice, NYSDEC "will continue to work with any manufacturers on the design of their websites, or entertain any questions regarding compliance with website design or safety data sheets." NYSDEC "remains committed to working with the manufacture[r]s to implement this program in the best manner possible."
As reported in our January 23, 2019, blog item, NYSDEC previously announced a three-month delay in its enforcement of the Disclosure Program from July 1, 2019, to October 1, 2019. See https://nanotech.lawbc.com/2019/01/new-york-delays-enforcement-of-household-cleansing-product-information-disclosure-program/ As reported in our June 8, 2018, blog item, the Disclosure Program requires manufacturers of cleaning products sold in New York to disclose chemical ingredients and identify any ingredients that appear on authoritative lists of chemicals of concern on their websites. See https://nanotech.lawbc.com/2018/06/new-york-household-cleansing-product-disclosure-program-will-require-disclosure-of-nano-ingredients/ According to the Disclosure Program Certification Form and Program Policy, for each ingredient that is a nanoscale material, a term describing the nanoscale material should be disclosed. See https://www.dec.ny.gov/docs/materials_minerals_pdf/cleansingprodfin.pdf For example, if the nanoscale material is carbon, the disclosure should use the term "nanoscale" carbon. NYSDEC's Program Policy states that a nanoscale material "is a chemical substance that meets the [Toxic Substances Control Act (TSCA)] definition of a reportable chemical substance manufactured or processed at the nanoscale. That definition provides, in part, that a ‘reportable chemical substance is a chemical substance as defined in Section 3 of TSCA that is solid at 25° C and standard atmospheric pressure, that is manufactured or processed in a form where any particles, including aggregates and agglomerates, are in the size range of 1-100 nanometers in at least one dimension, and that is manufactured or processed to exhibit unique and novel properties because of its size. A reportable chemical substance does not include a chemical substance that is manufactured or processed in a form where less than 1% of any particles, including aggregates, and agglomerates, measured by weight are in the size range of 1-100 nanometers.'"
More information regarding the Disclosure Program and the previous enforcement delay is available in Bergeson & Campbell, P.C.'s January 14, 2019, memorandum, "NYDEC Delays for Three Months Enforcement of its Household Cleansing Product Information Disclosure Program." See https://www.lawbc.com/index.php/regulatory-developments/entry/nydec-delays-for-three-months-enforcement-of-its-household-cle
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