Kelley Green Law

Chemical law, emerging contaminants, and regulatory news and insights

Prop 65 Battle Royale over Glyphosate: EPA vs. OEHHA

The California Office of Environmental Health Hazard Assessment (OEHHA), which administers Proposition 65, wasted no time in punching back at the U.S. Environmental Protection Agency (EPA), which declared, in an August…

Proposition 65 Enforcement Trend Alert: Plastic Packaging

The latest front in the ever-expanding Proposition 65 enforcement battle: plastic packaging. Since the start of the year, dozens of notices of violation have been filed, not for actual products, but for the packaging…

The FOIA Charade: A Brief Case Study

With the release last month of proposed new EPA regulations on how the agency intends to handle responses to requests under the Freedom of Information Act (FOIA), critics have raised concerns about provisions that…

New York Further Delays Enforcement of Cleaning Product Disclosure Program

The New York Department of Environmental Conservation (NYDEC) announced last week that it will not begin enforcement of the Household Cleansing Product Information Disclosure Program until January 2, 2020. Previously,…

BREAKING NEWS: Prop 65 Warning Exemption Approved for Coffee (UPDATE)

UPDATE: OEHHA officially published adoption of the Prop 65 exemption for coffee on June 7, 2019, announcing that the new rule is effective as of October 1. Further details on and copies of the rulemaking documents…