TIA Joins Coalition Urging for Economic Analysis of CA "Green" Chemistry Regulations

October 2, 2012 | The Toy Industry Association (TIA) has published a statement requesting that the Department of Toxic Substances Control (DTSC) conduct a thorough analysis of the economic impact of California’s Safer Consumer Products Regulations (SCPR). The range and scope of the SCPR regulations are such that they would allow the DTSC to regulate and/or ban any chemical or product sold in California, forcing businesses to develop costly and undefined analyses of their products. TIA’s statement follows:

In a letter sent on Monday, October 1^st, California legislators urged Governor Jerry Brown to require the Department of Toxic Substances Control (DTSC) to conduct a thorough analysis of the economic impact of its Safer Consumer Products Regulations (SCPR) in order to ensure predictability and transparency in the regulatory arena. The request is in line with provisions of California law SB 617, which will go into effect in less than four months, which requires a robust economic analysis to be conducted on any major new regulation developed by a department or agency in the state.

For the Toy Industry Association (TIA) and its 550 members, safety is the toy industry’s top priority. We support the concept of green chemistry, and are committed to using sound science that can help improve or reinforce the safety of toys, but California must approach this regulation in a way that is workable and practical for businesses while effective in protecting public health and safety. We strongly support the recommendations made by the Legislators for a thorough economic analysis of the effect the SCPR regulations will have on business. We urge Governor Brown to take action to ensure that decision-makers and the public have critical information regarding how California’s economy and jobs will be affected before these regulations are finalized.

These regulations will saddle toy companies, both large and small, with unpredictable costs related to testing, data collection, complex expert analysis, reporting, etc. Some companies will not have the resources needed for compliance, and will be at risk of being put out of business.　 Additionally, these regulations will likely result in price increases across toy categories – which could limit the purchasing options for families looking to buy safe and affordable playthings. Without a thorough economic analysis, it is impossible to determine the level of impact to the toy or any other industry, and these regulations could result in devastating unintended consequences for California consumers and the economy.

TIA will keep members apprised of any developments on this topic.