Home > Nanotechnology Columns > Bergeson & Campbell, P.C. > Nanomaterials May Not Fit Definition of "Chemical" in "Informal Draft" Safer Consumer Products Regulations
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Lynn L. Bergeson Managing Director Bergeson & Campbell, P.C. |
Abstract:
On November 14-15, 2011, the California Department of Toxic Substances Control's (DTSC) Green Ribbon Science Panel (GRSP) met to review DTSC's "informal draft" Safer Consumer Products Regulations (SCPR) released on October 31, 2011. During the meeting, DTSC provided an explanation for how the regulations were developed and then set forth questions for discussion on three topics: (1) the Chemicals of Concern (COC) List; (2) the prioritization of products; and (3) the quality assurance of alternative assessments (AA).
November 23rd, 2011
Nanomaterials May Not Fit Definition of "Chemical" in "Informal Draft" Safer Consumer Products Regulations
On November 14-15, 2011, the California Department of Toxic Substances Control's (DTSC) Green Ribbon Science Panel (GRSP) met to review DTSC's "informal draft" Safer Consumer Products Regulations (SCPR) released on October 31, 2011. During the meeting, DTSC provided an explanation for how the regulations were developed and then set forth questions for discussion on three topics: (1) the Chemicals of Concern (COC) List; (2) the prioritization of products; and (3) the quality assurance of alternative assessments (AA).
During discussion of the "Chemicals of Concern" List, one GRSP member raised the question of whether nanomaterials, which are not specifically mentioned in these informal draft regulations, were meant to be excluded. The GRSP member thought that the regulation's definition of "chemical" may be narrow and that nanomaterials may not fit within the definition.
Based on the comments from the GRSP, it appears that most members approved of the general scope and framework of the informal draft regulations and offered comments and suggestions regarding the details of how this framework would be implemented. DTSC does not expect to hold another face-to-face GRSP meeting before the regulations are promulgated. The GRSP may schedule a teleconference sometime during the process. DTSC is holding a workshop on December 5, 2011, to "welcome comments and suggestions from the public to enhance the informal draft regulations to make them more meaningful, practical, technically sound, and legally defensible."
DTSC also is accepting comments on the regulations, which are due by December 30, 2011. DTSC emphasized that it would be helpful if those that were submitting comments offered solutions to any problems identified.
Details regarding the workshop can be found at http://www.dtsc.ca.gov/LawsRegsPolicies/Regs/upload/SCP-Workshop-Notice-10312011.pdf
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