August 18, 2025
Gradient’s recent comments to California Department of Toxic Substances Control on SB 502 Mandated Framework Regulations Amendments were cited recently by Chemical Watch.
Read the Chemical Watch article here: Industry seeks more scientific rigour in California SCP proposal for streamlined action.
Chemical Watch, a publication that covers regulatory developments that impact chemicals in products, noted Gradient’s recent comments on SB 502 Mandated Framework Regulations Amendments in its article, “Industry seeks more scientific rigour in California [Safer Consumer Products] SCP proposal for streamlined action.” The article summarizes reactions to the June 6, 2025, proposal from California’s Department of Toxic Substances Control (DTSC), outlining DTSC’s proposal to “streamline” chemical safety evaluation by skipping the alternatives analysis (AA) process using publicly available studies or evaluations of alternatives in lieu of an AA. Gradient commented on the insufficiency of DTSC’s proposed criteria for such third-party alternative evaluations, stating the criteria are “not robust enough.” Gradient is cited further in the Chemical Watch article as stating that the proposal would create “a two-track system where the requirements for the regulated parties are specific and extensive, but the requirements the agency must meet are substantially weaker.”
As cited by Chemical Watch:
The [current SB502 program] requires a manufacturer of a priority product “to go through the full AA process, address over 100 relevant factors, [and] provide documentation and citation support for all assertions and assumptions,” Gradient said. By contrast, the proposal would retain that process for manufacturers, but allow the DTSC to “make a determination that an AA or study is ‘sufficient’ and ‘appropriate’ based on its own judgement.”
In the Chemical Watch article, Gradient goes on to outline that the DTSC should better define minimum criteria for existing analysis it uses to “address aspects like chemical hazard, exposure potential, performance, cost and availability, impacts across the full product lifecycle, and the effects of chemical degradation products.”