The proposed changes were first drafted in March 2014, and AHPA, along with 200 members of various industries in the California Chamber of Commerce, submitted comments on April 8, 2015. The latest revisions were made in November 2015, and many trade associations still aren’t happy with the content.
“AHPA's comments to this most recent proposal by OEHHA reiterate many concerns and recommendations expressed in similar comments submitted to OEHHA in April 2015,” the association said in a press release.
One example is how California’s Office of Environmental Health Hazard Assessment, who drafted the proposal, defined “consumer product exposure.”
The original defines it to mean “an exposure that results from a person’s acquisition, purchase, storage, consumption, or any reasonably foreseeable use of a product.” But AHPA argues it should say that exposure results from “a person’s acquisition, purchase, storage, consumption, or use of a product in accordance with recommendations made in the product’s labels or labelling or with other actual and accepted uses of the product.”
“Although OEHHA now claims its November proposal ‘takes into account all comments received on the earlier proposal,’ almost none of the recommendations previously submitted by AHPA and others seeking reasonable regulation were accepted in the agency's current draft,” AHPA’s press release said.
Around the same time, another trade association in the supplements industry, the Natural Products Association (NPA) also submitted their concerns and comments.