On November 16, 2017, the State of California’s DTSC proposed to add its third product-chemical combination to its priority products list for regulation under its green chemistry/safer consumer products rules.   We are all still waiting to see the first, or any product, undergo the voluminous data, reporting and analytical requirements of the regulations and it remains to be seen if any ever will.   The third product to be proposed is “paint or varnish strippers containing methylene chloride” defined as “any product designed to break down paint, varnish, or any other surface coating to facilitate its removal from any surface.”  Proposed new rule section 69511.1(a).

The toxicities of methylene chloride are well documented in this rulemaking proposal, but it is not clear what is the volume of this product in commerce in California, what is the harm that is “widespread and significant” and why this product is prioritized as a source of the harm.

Public comments may be submitted at https://calsafer.dtsc.ca.gov/ or by mail until January 18, 2018.  A public hearing will be held on the proposal on January 8, 2018 in Sacramento at the Cal/EPA building.

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