OEHHA recently published proposed rule changes that will eliminate short- form label use to provide clear and reasonable warnings to consumers. New short-form warnings will need to be tailored to each product and identify a specific chemical and the nature of the risk to be compliant with Prop 65 requirements. If implemented, the rules may … Continue reading "Prop 65 Short Form Warning Changes: OEHHA’s 12/13/23 Public Hearing"...
Jennifer Nijman Just this month, on October 11, 2023, EPA issued its final rule under the Toxic Substances Control Act (TSCA) requiring a wide range of companies to report and retain records of extensive PFAS data. The rule will take effect November 13, 2023. https://www.govinfo.gov/content/pkg/FR-2023-10-11/pdf/2023-22094.pdf. It initially may seem like a good idea, except that … Continue reading "EPA’s New PFAS Reporting Rule – Can It Be Done?"...
U.S. EPA will host a webinar on September 6, 2023, from 1-2 CDT on its new Framework for Addressing PFAS and New Uses of PFAS under the Toxic Substances Control Act (TSCA). The Framework outlines U.S. EPA’s planned approach when reviewing new PFAS and new uses of existing PFAS. The Framework supports the U.S. EPA’s … Continue reading "U.S. EPA Announces September 6th PFAS Webinar"...
Nijman Franzetti welcomes guest blogger and college student, Annie Bart, to share this important update regarding recent CSB release reporting developments. Annie completed a shadow program with the firm in June and is interested in a career as an environmental lawyer. Thanks, Annie! Accidents happen, but when it comes to the chemical releases, it is … Continue reading "CSB Accidental Reporting Rule Update"...
The U. S. Environmental Protection Agency (EPA) recently issued a reinterpretation of the RCRA industrial ethyl alcohol exemption as it applies to the reclamation of alcohol-based hand sanitizer. EPA now takes the position that industrial ethyl alcohol-based products, including alcohol-based hand sanitizer, qualify for the exemption whether or not the materials are spent. EPA’s reinterpretation … Continue reading "EPA Update: Unused Alcohol-Based Hand Sanitizer"...