Gradient Regulatory Comments on Consumer Safety Law

News & Events

July 27, 2020

Gradient scientists provided comments on new AA requirements for children’s products being proposed by OR under the Toxic-Free Kids Act. 


Alternative Assessment, Regulatory Comments,

Toxicology, Product and Consumer Safety


Gradient Provides Comments on Oregon’s Toxic-Free Kids Act Proposed Rule

Gradient scientists have provided comments on new alternative assessment (AA) requirements for children’s products being proposed by the State of Oregon Health Authority (OHA) under the Toxic-Free Kids Act of 2015.  By January 1, 2022, manufacturers of three categories of children’s products containing high priority chemicals of concern for children’s health (HPCCCH) will either have to replace those chemicals with less hazardous alternatives or petition the state to be allowed to continue selling the products in Oregon.  Petitions can be based on a regulatory exemption (e.g., the product is already covered by a certain standards or regulations), a quantitative exposure assessment demonstrating no detectable exposure to the chemical, or an alternatives assessment demonstrating that chemical substitutes are not feasible from a hazard, technical, or cost standpoint.  See Gradient’s diagram of Oregon’s proposed scheme for product evaluation, shown below.

The three product categories subject to the regulation are:

  • Mouthable children’s products
  • Children’s cosmetics
  • Products made or marketed to children under three years of age

Gradient’s Dr. Tom Lewandowski testified on the AA-related portions of the regulation at a hearing on July 16, and Gradient submitted written comments on July 22.  A copy of the proposed regulation can be found here, and Gradient’s written comments can be found here.

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