Maureen Gorsen, partner in the firm’s Environmental & Land Use Group, was quoted in Bloomberg BNA’s Daily Environmental Report in an article featuring her comments from her speech on opening day of the Global Chemical Regulations 2014 conference in Baltimore, organized by the American Chemistry Council and the Society of Chemical Manufacturers and Affiliates (SOCMA).
California’s Department of Toxic Substances Control is hoping to release a preliminary list of products containing chemicals of concern under its Safer Consumer Products Regulation by March 13 and, according to Gorsen, the department is required to release this list by April 1.
“Prior to that date, companies that make products on the preliminary list will have a lot of work to do,” Gorsen said.
Tasks Gorsen recommended include developing new supply chain contracts that protect a company’s right to cancel supply orders.
Gorsen also said manufacturers should think through key supply chain questions such as, who will modify the department if a selected product contains a designated chemical, who will perform the alternatives analysis, should a consortium be developed to share responsibilities, who will supply data, who would perform toxicity testing if needed and how will costs be addressed.