What the Proposed Rule Changes to OSHA Hazard Communication Standard May Mean to Your Operations
Pace combines a high level of chemistry expertise with a thorough understanding of current global regulations facing chemical manufacturers. Regulatory Consulting offers product stewardship expertise to help you navigate the regulations that govern your industry. We offer understanding of the regulatory challenges you face and provide the information you need to make informed decisions.
Toxic Substances Control Act (TSCA)
The Toxic Substances Control Act, governed by the EPA, evaluates new and existing chemicals for potential risks to human or environmental health. TSCA was recently amended under the Lautenberg Act in 2016 and new chemicals must go through a review process called a pre-manufacture notice (PMN). Once approved, they may be added to the TSCA registry. Significant new use rules (SNURs) are also common for both new and existing chemicals.
The Pace Regulatory Consulting team will guide and assist with TSCA compliance and EPA questions. TSCA product stewardship activities include:
- TSCA Inventory Checks
- PMN Preparation and Submission
- Significant New Use Rules (SNURs) Review and Submission
- Chemical Data Reporting (CDR)
California Proposition 65
CA Prop 65 requires manufacturers to display on their product labels any ingredient known to the state of California to cause cancer, birth defects or other reproductive problems. California maintains an extensive list of chemicals that warrant a P65 warning and product labels must comply in order to sell in California.
A Regulatory Consultant will complete a product review to assess for compliance with California’s list of toxic chemicals. You will be provided the appropriate language and disclosure information to include on your label.
Contact me to learn more!
Josh Nelson | Account Executive, Regulatory Services
Cleaning Product Right to Know Act (SB 258)
Senate Bill No. 258 requires manufacturers of certain products sold in the state of California to disclose designated chemicals contained in the product. Information related to these chemicals must be provided on the product label and product website.
A Regulatory Consultant will provide a regulatory review of the products you sell into California. Upon completion of the review, you will be provided compliant product label statements and website guidance.
EU REACH and RoHS
The European Chemicals Agency (ECHA) uses REACH (Registration, Evaluation, Authorization, and Restriction of Chemicals) to assess the hazards of new and existing chemicals. Companies must comply by identifying and managing the risks of their specific chemicals.
The Restriction of Hazardous Substances (RoHS), similar to REACH, applies specifically to Electronics and Electrical Equipment (EEE).
Pace’s Regulatory Consultants assist with compliance under REACH and RoHS regulations.
- EU REACH Dossier Prep
- Inventory Checks for EU REACH and RoHS
- RoHS Compliance
- Waste of Electronics and Electrical Equipment (WEEE) Guidance
Product Label Reviews
Regulatory review of your product labels for compliance with the various regulatory bodies. Common label review projects include:
- CA Prop 65
- DOT Guidance
- SB258 (California Cleaner’s Right to Know Act)
- Consumer Product Safety Committee (CPSC)
- Canadian Consumer Chemicals and Containers Regulations (CCCR)
- GHS Label Review and Creation
Additional areas of expertise:
- Canadian New Substance Notification (NSN) preparation and submission
- Country Specific Inventory Checks (K-REACH, DSL and non-DSL, CPSC, Country Specific Lists)
- Product Stewardship Program Creation and Management
- Conflict Mineral Supply Chain Verification
- Testing strategy development and data interpretation
- Regulatory guidance on the use of HAPs
- VOC Calculations