Bergeson & Campbell, P.C. (B&C®) is a Washington, D.C., law firm providing biobased and renewable chemical product stakeholders unparalleled experience, judgment, and excellence in bringing innovative products to market.

On December 22, 2016, the California Department of Toxic Substances Control (DTSC) announced that the public comment period for the draft Alternatives Analysis (AA) Guide for the Safer Consumer Products (SCP) program has been extended to February 3, 2017. The guide, which was released on December 19, 2016, aims to help relevant stakeholders navigate all phases of the SCP AA process and provide useful approaches, methods, resources, tools and examples of how to fulfill SCP's regulatory requirements. The draft AA Guide is available through the Safer Consumer Products Information Management System (CalSAFER). The SCP program aims to reduce toxic chemicals in consumer products using a four step process that identifies specific products that contain potentially harmful chemicals and asks manufacturers to assess whether the chemical is necessary and whether a safer alternative can be used.


 

The California Department of Toxic Substances Control (DTSC) has issued a draft of its Stage 1 Alternatives Analysis (AA) Guide. DTSC developed this guidance to help the regulated community conduct AA and regulatory requirements under the California Safer Consumer Products (SCP) program. Comments on the draft document can be submitted online at the SCP Information Management System (CalSafer) website and are due by October 23, 2015. DTSC is holding two webinars, the second of which occurs on October 21, 2015, for participants to learn about and discuss the draft AA Guide. Biobased and Renewable Products Advocacy Group (BRAG®) affiliate B&C's memorandum DTSC Issues Guidance to Companies on How to Prepare Alternative Analysis under the Safer Consumer Products Regulations contains an overview of the guidance with commentary for companies doing business in California.