SB 763
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Date of Hearing: July 14, 2015
ASSEMBLY COMMITTEE ON ENVIRONMENTAL SAFETY AND TOXIC MATERIALS
Luis Alejo, Chair
SB 763 (Leno) – As Amended July 8, 2015
SENATE VOTE: 30-10
SUBJECT: Juvenile products: flame retardant chemicals.
SUMMARY: Requires manufacturers of juvenile products manufactured on or after July 1,
2016 to indicate on a label whether or not the product contains added flame retardant chemicals.
Specifically, this bill:
1) Defines “juvenile product” as a product subject to the Home Furnishings and Thermal
Insulation Act and intended for use by infants and children younger than 12 years of age,
such as a bassinet, booster seat, infant car seat, changing pad, floor play mat, highchair,
highchair pad, infant bouncer, infant carrier, infant seat, infant swing, infant walker, nursing
pad, nursing pillow, playpen side pad, playard, portable hook-on chair, stroller, children’s
nap mat, and infant foam crib mattress.
2) Defines “added flame retardant chemicals” as flame retardant chemicals that are present in
any juvenile product or component thereof at levels above 1,000 parts per million.
3) Exempts products subject to state upholstered furniture labeling requirements and specified
federal flammability standards from the requirements of the bill.
4) Exempts, when determining whether a product contains flame retardants for purposes of the
labeling requirements of the bill, electric and electronic units or components, including, but
not limited to, power cords or power supply units, motor assemblies, Bluetooth modules,
vibration units, light and sound units, and circuit boards and wiring. Authorizes the chief of
the Bureau of Electronic and Appliance Repair, Home Furnishings and Thermal Insulation
(BEARHFTI) to clarify the exemption list in regulation.
5) Requires a manufacturer of juvenile products manufactured on or after July 1, 2016 for retail
sale in California to have a label securely attached to the product, in plain view, stating the
following:
“The State of California has determined that this product does not pose a serious fire
hazard. The state has identified many flame retardant chemicals as being known to, or
strongly suspected of, adversely impacting human health or development.
The fabric, filling, and plastic parts of this product:
_____contains added flame retardant chemicals
_____contains NO added flame retardant chemicals”
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6) Requires a manufacturer of juvenile products sold in California to indicate the absence or
presence of added flame retardant chemicals by placing an “X” in one of the appropriate
blanks on the label.
7) Provides that the label for juvenile products shall comply with the labeling requirements for
the law label delineated in Article 2, Title 4, California Code of Regulations (CCR) § 1126.
8) Requires the manufacturer of the juvenile product sold in California to retain documentation
to show whether flame retardant chemicals were added. Provides that a written statement by
the supplier of each component of a juvenile product attesting either that flame retardant
chemicals were added or not added shall be sufficient documentation.
9) Requires BEARHFTI to ensure compliance with the labeling and documentation
requirements in the bill.
10) Requires, upon request, a manufacturer of a juvenile product sold in California to provide to
BEARHFTI, within 30 days of the request, documentation establishing the accuracy of the
flame retardant chemical statement on the label.
11) Requires BEARHFTI to assess fines between $2,500 and $15,000 in accordance with
specified factors for the failure of the manufacturer of the juvenile product to maintain or
provide the required documentation.
12) Provides that a manufacturer of juvenile products sold in California and component suppliers
shall be jointly and severally liable for violations of the documentation required by the bill.
13) Requires BEARHFTI to provide the Department of Toxic Substances Control (DTSC) with a
selection of samples from juvenile products marked “contains NO added flame retardant
chemicals” for testing for the presence of added flame retardant chemicals, as specified, and
to reimburse DTSC for the cost of testing.
14) Requires, no later than August 1st of each fiscal year, BEARHFTI to assess available
resources and to determine the number of tests to be conducted in the corresponding fiscal
year.
15) Authorizes BEARHFTI, if DTSC’s testing shows that a juvenile product labeled as “contains
NO added flame retardant chemicals” is mislabeled because it contains added flame retardant
chemicals, to assess fines against manufacturers of the juvenile product and component
manufacturers to be held jointly and severally liable for the violation.
16) Requires fines for mislabeling to be assessed in increasing severity, from $1,000 to $10,000,
depending on the frequency of the violation and in accordance with specified factors.
17) Requires BEARHFTI to adjust all minimum and maximum fines imposed for inflation every
five years.
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18) Authorizes BEARHFTI, if DTSC’s testing shows that a juvenile product labeled as “contains
NO added flame retardant chemicals” is mislabeled because it contains added flame retardant
chemicals, in addition to a fine or any other request, to request that the label or juvenile
products that belong to the same stock keeping unit (SKU) currently produced by the
manufacturer be corrected to reflect that flame retardant chemicals are added to the juvenile
product, and to request additional testing of more products belonging to the same SKU at the
manufacturer’s expense.
19) Requires it to be the duty of BEARHFTI to receive complaints from consumers concerning
juvenile products sold in California.
20) Authorizes BEARHFTI to adopt regulations to carry out the requirements of the bill.
21) Codifies the current exemption from fire retardant regulations applicable to specified juvenile
products. Includes two additional products in the exemption.
EXISTING LAW:
1) Establishes the Home Furnishings and Thermal Insulation Act (Act) and requires it to be
administered by BEARHFTI within the Department of Consumer Affairs (DCA). (BCP §
19000 et seq.)
2) Requires protection of the public to be the highest priority for BEARHFTI in exercising its
licensing, regulatory, and disciplinary functions. Requires, whenever the protection of the
public is inconsistent with other interests sought to be promoted, the protection of the public
to be paramount. (BCP § 19004.1)
3) Specifies that the Act applies to upholstered furniture, bedding and filling materials, and
insulation sold in California regardless of its point of origin. (BCP § 19070)
4) Defines, in reference to upholstered furniture labeling requirements, “flame retardant
chemical" as any chemical or chemical compound for which a functional use is to resist or
inhibit the spread of fire. Provides that flame retardant chemicals include, but are not limited
to, halogenated, phosphorous-based, nitrogen-based, and nanoscale flame retardants, flame
retardant chemicals listed as “designated chemicals” pursuant to Section 105440 of the
Health and Safety Code, and any chemical or chemical compound for which “flame
retardant” appears on the substance Safety Data Sheet. (BPC § 19094 (a)(3) and (4))
5) Requires a manufacturer of upholstered furniture to indicate whether or not the product
contains added flame retardant chemicals by including a statutorily required "flame retardant
chemical statement" and an "X" indicating the presence of flame retardant chemicals on the
required flame retardant (Technical Bulletin (TB) 117-2013) label. This label is substantially
similar to that required for juvenile products included in this bill. (BPC § 19094 (b)(1))
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6) Requires the manufacturer of upholstered furniture sold in California to retain documentation
to show whether flame retardant chemicals were added to their products. (BPC § 19094
(c)(1))
7) Requires BEARHFTI to ensure compliance with the flame retardant labeling and
documentation requirements for upholstered furniture. (BPC § 19094 (c)(2))
8) Requires, upon request, a manufacturer of upholstered furniture sold in California to provide
to BEARHFTI, within 30 days of the request, documentation establishing the accuracy of the
flame retardant chemical statement on the label. (BPC § 19094 (c)(3)(A))
9) Requires BEARHFTI to assess specified fines for the failure of the manufacturer of
upholstered furniture to maintain or provide to BEARHFTI the documentation establishing
the accuracy of the flame retardant chemical statement on the label. (BPC § 19094 (c)(3)(B))
10) Requires BEARHFTI to provide DTSC with a selection of samples from upholstered
furniture marked “contains NO added flame retardant chemicals” for testing for the presence
of added flame retardant chemicals, as specified, and to reimburse DTSC for the cost of
testing. (BPC § 19094 (c)(3)(D)(i))
11) Requires all flexible polyurethane foam that is offered for sale to the general public at retail
outlets to be fire retardant, as defined by BEARHFTI. (BPC § 19161.3)
12) Requires all mattresses and mattress sets manufactured for sale in this state to be fire
retardant. (BPC § 19161 (a))
13) Authorizes the chief of BEARHFTI, subject to the approval of DCA, to in his or her
discretion exempt items of upholstered furniture which are deemed not to pose a serious fire
hazard from fire retardant requirements. (BPC § 19161.5)
14) Requires, under the Safe Drinking Water and Toxic Enforcement Act of 1986 (Proposition
65), the Governor to cause a list to be published of those chemicals known to the state to
cause cancer or reproductive toxicity, and to cause such list to be revised and republished in
light of additional knowledge at least once per year. (Health and Safety Code (HSC) §
25249.8)
15) Requires, under Safer Consumer Products (Green Chemistry) statutes, DTSC to identify and
prioritize chemicals of concern and to adopt regulations to evaluate chemicals of concern in
consumer products to determine how best to limit exposure or to reduce the level of hazard
posed by a chemical of concern. Authorizes DTSC to take specified regulatory actions to
limit exposure or to reduce the level of hazard posed by a chemical of concern. (HSC §
25251 et. seq.)
16) Prohibits a person from manufacturing, processing, or distributing in commerce a product or
part of a product that contains more than 1/10th of 1% of pentaBDE or octaBDE. (HSC §
108922)
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17) Requires, pursuant to TB 117-2013, beginning January 1, 2015, all filling materials and
cover fabrics contained in upholstered furniture sold in California to meet certain smolder
resistant testing standards, and to be labeled as specified. (Article 13, Division 3, Title 4,
CCR § 1374)
18) Exempts from compliance with TB 117-2013 the following juvenile products: bassinets,
booster seats, car seats, changing pads, floor play mats, highchairs, highchair pads, infant
bouncers, infant carriers, infant seats, infant swings, infant walkers, nursing pads, nursing
pillows, playpen side pads, playards, portable hook-on chairs, and strollers. (Article 13,
Division 3, Title 4 , CCR §1374.2)
FISCAL EFFECT: Unknown.
COMMENTS:
Need for the bill: According to the author, "Growing evidence show(s) that many fire retardant
chemicals have serious human and environmental health impacts, including cancer, decreased
fertility, hormone disruption, lower IQ, and hyperactivity. A typical household can contain up to
several pounds of these chemicals, and their extensive use to meet TB 117 has led to
contamination of the global environment… Tests have found fire retardant chemicals present in
polyurethane foam in baby products which are in intimate contact with infants and young
children including nap mats, bassinets, changing pads, strollers, playpens, swings, nursing
pillows, high chairs and toddler chairs…
As is current law for furniture, consumers deserve the right to make educated choices about
purchasing children’s products that may include flame retardants associated with serious
developmental and health consequences. When consumers choose to purchase safer products,
they create a direct and positive market signal that reduces toxic exposures for their families, for
firefighters, and for the environment…
SB 763 will give parents the information they need to choose safe and healthy products for their
children."
Flame retardant chemicals: Flame retardants are chemicals added to plastic, foam, textiles,
electronics, building materials, and other products to resist or inhibit the spread of fire.
According to the American Chemistry Council, bromine, phosphorus, nitrogen and chlorine are
commonly used in flame retardants. Inorganic compounds are also used in flame retardants,
either alone or as part of a flame retardant system in conjunction with bromine, phosphorus or
nitrogen.
Human exposure to flame retardants occurs mainly through inhalation or ingestion of dust. Food
and water contaminated with flame retardants is another source of exposure. Exposure from
dermal contact with contaminated soil and dust may also occur.
Contaminated dust enters households and the environment when foam treated with flame
retardant chemicals in upholstered furniture and other products breaks down and escapes the
product as dust. Flame retardant chemicals also enter the environment through manufacturing
processes and through the disposal of treated products. Medical studies have linked flame
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retardant chemicals to job-related cancer and other illnesses in American firefighters, indicating
heightened exposure during fires.
Research conducted in 2014 by the Environmental Working Group and Duke University found
that young children typically have 3 – 5 times higher amounts of flame retardant chemicals in
their systems than do their mothers, and scientists believe it is because they spend more time on
the floor amongst contaminated dust and put their hands (and other contaminated products) in
their mouths more frequently than do adults. Studies also show that infants are also exposed to
flame retardants through the ingestion of breast milk.
Human health and environmental impacts of flame retardant chemicals: According to the Green
Science Policy Institute, while not all flame retardants present concerns, the following types
often do: 1) halogenated flame retardants (also known as organohalogen flame retardants)
containing chlorine or bromine bonded to carbon; and, organophosphorous flame retardants
containing phosphorous bonded to carbon.
Polybrominated diphenyl ethers (PBDEs), the most thoroughly studied of the flame retardant
chemicals, have been found in birds, fish, shellfish, amphibians, marine mammals, sewage
sludge, sediments, air samples, meats, dairy products, and even vegetables. There has been
extensive animal research over the past decade indicating that PBDE exposure can lead to
abnormalities in learning, memory, and neurodevelopment, and linking exposure to
hyperactivity, endocrine disruption, and other neurotoxicological effects.
In humans, PBDEs have been found to accumulate in blood, fat, and breast milk. According to
DTSC, the levels of PBDEs measured in humans in the United States and Canada are typically at
least 10 times higher than those in Europe, and appear to be doubling every few years. Recent
research has shown that PBDE exposure in humans may lead to endocrine disruption,
reproductive difficulty, neurodevelopmental issues, reduced IQ, and elevated thyroid levels.
Studies have found PBDEs in fetal cord blood, indicating that these chemicals can cross the
placenta and expose fetuses during critical times of development. American children with higher
PBDE levels score worse on assessments of learning and attention, and these deficiencies persist
throughout childhood.
While PBDEs have been largely phased out of use, alternative flame retardant chemicals are
pervasive and have raised similar and other toxicological concerns to those raised by PBDE
formulations. Studies have linked exposure to many other flame retardant chemicals to
endocrine disruption; fertility issues; and, carcinogenic, mutagenic, reprotoxic, obesogenic, and
neurotoxicological effects. The chemicals have also been found to also be persistent and
bioaccumulative.
Upholstered furniture flammability standard: BEARHFTI develops flammability standards in
the form of Technical Bulletins (TBs), which are adopted through regulation. There are also a
number of other federal flammability standards developed by the United States Consumer
Product Safety Commission (CPSC), which are currently in effect nationwide. While CPSC has
been studying a national residential upholstered furniture standard for several years, California
remains the only state with a residential upholstered furniture flammability standard. However,
since California is such a large portion of the national market, most manufacturers choose to
meet California's standards for their products sold across the country.
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TB 117: In October 1975, BEARHFTI promulgated regulations that resulted in the development
of Technical Bulletin 117 (TB 117) entitled, "Requirements, Test Procedures and Apparatus for
Testing the Flame Retardance of Filling Materials Used in Upholstered Furniture." This
mandatory performance standard required that the concealed filling materials and cover fabric of
upholstered furniture undergo individual component testing to ensure that they passed open
flame and cigarette smolder tests. The main emphasis of TB 117 was on the open flame testing
of interior filling materials, which had to withstand exposure to a 12-second small open flame.
Manufacturers predominately met this requirement through using polyurethane foam treated with
flame retardant chemicals.
In 2012, BEARHFTI determined that TB 117 did not adequately address the flammability
performance of upholstered furniture cover fabric and its interactions with underlying filling
materials and that flame retardant foam can actually increase smolder propensity. In addition,
concerns were intensifying about the negative human health and environmental impacts caused
by flame retardant chemicals. On June 18, 2012, Governor Brown directed BEARHFTI to revise
the flammability standards for upholstered furniture sold in the state, saying "Toxic flame
retardants are found in everything from high chairs to couches and a growing body of evidence
suggests that these chemicals harm human health and the environment. We must find better
ways to meet fire safety standards by reducing and eliminating—wherever possible—dangerous
chemicals."
TB 117- 2013: In recognition of TB 117’s public safety shortcomings, as well as noting the
health concerns related to flame retardant chemicals, BEARHFTI published TB 117- 2013,
entitled "Requirements, Test Procedure and Apparatus for Testing the Smolder Resistance of
Materials Used in Upholstered Furniture," in November 2013. TB 117-2013 updates
flammability standards from the open flame method of testing to a smoldering test.
Manufacturers have indicated that they can comply with TB 117-2013 without the use of flame
retardant chemicals. While TB 117-2013 became effective on January 1, 2014, manufacturers
had a year to complete the transition and come into full mandatory compliance on January 1,
2015. TB 117-2013 supersedes TB 117.
Juvenile product exemption: In 2010, BEARHFTI found that some juvenile products contain a
much lesser fuel load content (i.e. foam, batting) than average adult seating furniture. In
addition, these products are less likely to be ignited or come in contact with an ignition source
under the exercise of reasonable care and supervision of adults. Therefore, in December 2010,
BEARHFTI published the finding that three specified juvenile products (strollers, infant carriers,
nursing pillows) "will not pose a serious fire hazard to infants and children if they are exempt
from the TB 117 flammability requirements," and updated its regulations to exempt those
products from TB 117. In November 2013, BEARHFTI again amended regulations to exempt
fifteen additional juvenile products from meeting the flammability requirements of the now-ineffect TB 117-2013. The exempted juvenile products (total of eighteen) are: bassinets, booster
seats, car seats, changing pads, floor play mats, highchairs, highchair pads, infant bouncers,
infant carriers, infant seats, infant swings, infant walker, nursing pads, nursing pillows, playpen
side pads, playards, portable hook-on chairs, and strollers. This full exemption became effective
on January 1, 2014.
SB 763 requires that these eighteen juvenile products, plus children's nap mats and infant foam
crib mattresses (two additional products that BEARHFTI has indicated are exempt from TB 1172013), be labeled to indicate whether or not they contain added flame retardant chemicals.
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Flame retardants in juvenile products: Despite an exemption from California flammability
standards, tests on juvenile products show that these products continue to contain flame retardant
chemicals. For example, tests commissioned by the Center for Environmental Health and
performed by Duke University in August 2014 on children's nap mats found that six of the 10
tested mats contained flame retardant chemicals. In another example, in 2014 the State of
Washington Department of Ecology tested 10 changing pads and found that three contained
flame retardant chemicals. Additional recent testing by Duke University found that of 17 nap
mats purchased in April and May 2015, nearly a year and a half after the exemption from TB
117-2013 went into effect, three were identified as containing flame retardant chemicals.
Current flame retardant labeling requirements: SB 1019 (Leno, Chapter 862, Statutes of 2014),
which became effective on January 1, 2015, requires a manufacturer of upholstered furniture
regulated by TB 117-2013 to indicate on the product label whether or not the product contains
added flame retardant chemicals.
The labeling requirements, enforcement provisions, and testing protocols set forth in SB 1019 for
flame retardant chemicals in upholstered furniture are substantially similar to those proposed in
SB 763 for flame retardant chemicals in juvenile products.
Safer Consumer Products regulations: AB 1879 (Feuer, Chapter 559, Statutes of 2008) enacted
California's Safer Consumer Product, or Green Chemistry, program, which requires DTSC to
identify, prioritize and evaluate chemicals of concern in consumer products to determine how
best to limit exposure or to reduce the level of hazard posed by those chemicals. It also
authorizes DTSC to take regulatory action to limit exposure or to reduce the level of hazard
posed by a chemical of concern.
On March 13, 2014, under the program, DTSC released its first list of three "priority products,"
which are consumer products identified by DTSC as containing one or more chemicals of
concern– known as "candidate chemicals" – that have a hazard trait that can harm people or the
environment. DTSC placed products on list based on two criteria: 1) the products have the
potential to expose people or the environment to one or more candidate chemicals, and 2) this
exposure has the potential to “contribute to or cause significant or widespread adverse impacts.”
This list included children's foam-padded sleeping products that contain the flame retardant
chlorinated tris or tris(1,3-dichloro-2-propyl) phosphate (TDCPP).
Arguments in support:
The Center for Environmental Health argues, "Flame retardant chemicals can migrate out of
products into air and dust where children are exposed to them. These chemicals are associated
with a variety of health concerns, including cancer, lower birth weight, decreased fertility,
hormone disruption, lower IQ, and hyperactivity. Due to children’s frequent hand to mouth
behavior, young children have 3-5 times higher levels of certain flame retardants than their
mothers. It is also of great concern that children of color and children from low-income
communities of color have the highest exposure. Flame retardant chemicals can cross the
placenta and this chemical exposure places babies at greater risk than adults because infants’
brains, organs, and reproductive systems are still developing… This legislation would require
manufacturers to label juvenile products as to whether the product contains added flame
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retardant chemicals. Without this type of label it will be impossible for parents to identify
products that either do or do not contain flame retardant chemicals."
The California Professional Firefighters argue, "SB 763 provides consumers a pathway to
exercise a choice in purchasing safer juvenile products, which, in turn, creates a direct and
positive impact on the reduction of toxic exposures to firefighters. Consequently, SB 763 affords
additional long-term cost-savings to the state by aiding in reducing workers’ compensation and
disability costs for firefighters through reducing the severity and frequency at which our
members incur job-caused illnesses associated with prolonged exposure to hazardous flame
retardant chemicals and the associated toxins they convert to during combustion… Further,
science reveals that toxic retardants provide minimal, if any, additional fire safety protection."
The Consumer Federation of California argues, "The proposed disclosures would provide
uniform information to consumers in a simple and accessible manner. It would also provide
businesses a standard format to communicate the information to consumers."
Arguments in opposition:
The American Chemistry Council, along with a coalition of industry groups, argues, "These
proposed requirements lack scientific justification, conflict with existing California consumer
product and chemical safety laws and regulations, and as a result, mislead consumers about the
potential safety of these products… Just as there are different types of metals or gases,
California should recognize that there are many different types of flame retardants with different
exposure, health and environmental profiles. Yet, under SB 763, manufacturers would be
required to label whether their product contains a flame retardant chemical regardless of whether
the particular chemical presents any meaningful risk to human health or the environment."
The Juvenile Product Manufacturer’s Association (JPMA) argues, "JPMA understands the
importance of notifying consumers if a product contains a flame retardant that has been found to
be harmful. However, SB 763 would also require a product containing no flame retardants to be
labeled as “not containing flame retardants”… SB 763 would subject companies that do not use
flame retardants and are not presently subject to labeling requirements, to comply with a new
regulatory program that requires record keeping and testing data when no potential harm exists.
This requirement will add significant burdens to companies who are already complying with the
Federal Hazardous Substance Act, and the Consumer Product Safety Improvement Act… SB
763 requires a permanently affixed warning label which will cost manufacturers hundreds of
thousands of dollars, even when their product does not contain flame retardants… JPMA
believes it is very important that labeling requirements provide information to the consumer that
is easily understood and does not dilute the message it is trying to convey. This can be
accomplished in SB 763 by removing the labeling requirement for products and components that
do not contain intentionally added flame retardants."
Recent related legislation:
1) SB 1019 (Leno), Chapter 862, Statutes of 2014, requires a manufacturer of upholstered
furniture to indicate on the product label whether or not a product contains added flame
retardant chemicals.
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2) AB 2197 (Mitchell, 2012), would have required BEARHFTI to revise regulations to require
all seating furniture sold or offered for sale to meet a smolder flammability test rather than an
open flame-test. This bill was not heard in the Assembly ESTM committee, at the author’s
request. Note: The provisions of this bill were largely implemented through regulation
through the adoption of TB 117-2013.
3) SB 147 (Leno, 2011), would have required BEARHFTI, on or before March 1, 2013, to
modify the requirements for flammability of upholstered furniture to include a smolder
flammability test as an alternative method of compliance. This bill failed passage in the
Senate Committee on Business, Professions, and Economic Development. Note: The
provisions of this bill were largely implemented through regulation through the adoption of
TB 117-2013.
4) SB 1291 (Leno, 2010), would have required the DTSC to include, as a chemical under
consideration in the Green Chemistry process, any chemical that is used, or is proposed to be
used, as a flame retardant. This bill was placed on the inactive file on the Senate Floor and
died on file.
5) SB 772 (Leno, 2009), would have exempted “juvenile products,” as defined, from flame
retardant regulations, unless BEARHFTI determined that the juvenile product posed a serious
fire hazard. This bill was held under submission in the Assembly Appropriations Committee.
Note: The provisions of this bill have been largely implemented through regulation.
6) AB 706 (Leno, 2008), would have required, commencing July 1, 2010, seating furniture and
bedding products to comply with certain requirements, including that they not contain a
chemical or component not in compliance with alternatives assessment requirements, and
would have required DTSC to adopt methodology for an alternative assessment to review the
classes of chemicals used to meet fire retardant standards. This bill failed passage on the
Senate Floor.
7) AB 302 (Chan), Chapter 205, Statutes of 2003, banned the use of penta and octa PBDEs after
January 1, 2008.
Double referral: This bill passed the Assembly Committee on Business and Professions on July
7, 2015, on a 12 – 0 vote.
REGISTERED SUPPORT / OPPOSITION:
Support
California Professional Firefighters (Co-Sponsor)
Center for Environmental Health (CEH) (Co-Sponsor)
Consumer Federation of California (CFC) (Co-Sponsor)
Alameda County Board of Supervisors
Alliance for Toxic Free Fire Safety (ATFFS)
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American Congress of Obstetricians and Gynecologists (ACOG) District IX
Association of Regional Center Agencies (ARCA)
BANANAS
Breast Cancer Action
Breast Cancer Fund
CalFIRE Firefighters, Local 2881
California Chapters of the Solid Waste Association of North America (SWANA)
California League of Conservation Voters
Californians for a Healthy & Green Economy
CALPIRG
Center for Environmental Health
Child Care Coordinating Council of San Mateo County (4Cs)
City and County of San Francisco
Clean Water Action
Coalition for Clean Air
Community Action Partnership of Madera County
Community Resources for Children
Consumer Attorneys of California
Contra Costa Child Care Council
Dignity Health
Earthjustice
Environment California
Environmental Working Group
First 5 Santa Clara County
Friends of the Earth
Go Kids
Grant David Gillham, Inc.
Health Care Without Harm
Instituto de Educación Popular del Sur de California
International Association of Fire Fighters
Latinas Contra Cancer
Mommy Greenest
Natural Resources Defense Council (NRDC)
Naturepedic
Pathways LA
Pesticide Action Network North America
Physicians for Social Responsibility-Los Angeles
Physicians for Social Responsibility-San Francisco Bay Area Chapter
Plumas Rural Services
San Francisco Bay Area Physicians for Social Responsibility (SF Bay Area PSR)
Southern California Coalition for Occupational Safety & Health
Trauma Foundation
Opposition
American Chemistry Council
California Chamber of Commerce
California Citizens Against Lawsuit Abuse
California Manufacturers and Technology Association
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Chemical Industry Council of California
Civil Justice Association of California
Fullerton Chamber of Commerce
Juvenile Products Manufacturers Association (JPMA)
National Federation of Independent Business
Southwest California Legislative Council
Analysis Prepared by: Shannon McKinney / E.S. & T.M. / (916) 319-3965