Today, the Department of Toxic Substances Control issued a 15-day notice to submit comments on: (1) nine new external scientific peer review reports; and (2) the California Environmental Policy Council resolution on the need for a multimedia life cycle evaluation adopted February 28, 2013. The public notice and associated documents can be accessed here. The public comment period will commence on March 13, 2013 and close on March 28, 2013.

Circulating these documents for review and comment appears to be DTSC’s final effort at bolstering the administrative record for the Safer Consumer Product Regulations rulemaking, and signals imminent adoption of the draft circulated for 30-day public comment on January 29, 2013. See our January 29, 2013 blog here. Notwithstanding, the release of these documents continues a disturbing trend toward procedural piecemealing (See our December 21, 2012 blog on this issue here, which makes it very difficult for anyone in the supply chain to understand what is truly at issue, or their rights with respect to any future challenge. Stay tuned…