Comments to OEHHA on Proposed Amendments to Prop 65 Short-Form Warnings
ACA was among more than 40 organizations that submitted comments to the California Office of Environmental Health Hazard Assessment regarding the agency’s second modification of Text Title 27, California Code of regulations Proposed Amendments to Article 6 Clear and Reasonable Warnings - Short Form dated April 5, 2022. The group requested that the Proposed Rulemaking be withdrawn in its entirety or at least modified as suggested in the detailed comments.
Opposition to California AB B 2247 Proposing New Database for Manufacturers re. PFAS Substances
ACA was among more than 20 organizations in a letter opposing Califiornia AB 2247 (as amended), legislation proposing the creation of a new database to house information submitted by manufacturers relative to perfluoroalkyl and polyfluoroalkyl (PFAS) substances. "Collectively, we support the responsible production, use and management of fluorinated substances, including regulatory requirements that are protective of human health and the environment, taking into consideration the diversity of physical and chemical properties and the environmental and health profiles of these substances. With respect to AB 2247, the bill imposes a significant new reporting requirement on businesses but delegates virtually all the implementation activities including creating a database and managing the information collected to a 3rd party entity."