Children’s Products and Tires Identified as Possible Priority in Most Recent SCP Work Plan

Posted on Behalf of  Katie Gibbs

About the 2021-2023 Priority Product Work Plan

The Safer Consumer Products (SCP) Program under the Department of Toxic Substances Control (DTSC) recently issued a draft of the 2021-2023 Priority Product Work Plan (DTSC's priority Work Plan). This triennial work plan identifies categories of consumer products the SCP will investigate to determine Priority Products (PPs), which are evaluated for potential chemicals of concern. Every three years a new Priority Product Work Plan is published, and categories of products are added, carried over, or removed in order to address emerging and changing concerns regarding consumer product safety. The product categories removed, added, and carried over from the 2018-2020 Work Plan to the 2021-2023 draft Work Plan are listed in Table 1. 

Table 1. Product categories added, carried over and removed to the 2021-2023 draft Work Plan.

Product categories added

Product categories carried over

Product categories removed

Children’s products*

Beauty, personal care, and hygiene products

Household, school, and workplace furnishing and décor

Motor vehicle tires**

Cleaning products

Consumable office, school, and business supplies


Building products and materials used in construction and renovation



Food packaging


* DTSC defines “Children’s products” as products primarily intended, made for, or marketed to children under the age of 12, such as toys; children’s cosmetics; children’s jewelry; products to help a child with sucking or teething, to facilitate sleep, relaxation, or the feeding of a child; and child safety seats designed to attach to an automobile seat (

** DTSC accepted a petition from the California Stormwater Quality Association to add motor vehicle tires that contain zinc to the PPs list. Tires containing other chemicals, such as octylphenol ethoxylates, 6PPD, 1,3-diphenylguanidine, hexa(methoxymethyl)melamine, and 1,3-dicyclohexylurea, will also be included in SCP’s evaluation (Safer Consumer Products Program 2021, p. 16).


What happens after a product category is listed on the Work Plan?

After a product category is listed in the Work Plan, the SCP identifies PPs from these product categories for further evaluation by the SCP (Safer Consumer Products Program 2021, p. 3). In identifying PPs, the SCP Program gives special consideration to products that contain Candidate Chemicals that may adversely impact the health of children and workers or adversely impact the indoor environment (Safer Consumer Products Program 2021, p. 4). The DTSC defines a Candidate Chemical as “a chemical that exhibits a hazard trait and/or an environmental or toxicological endpoint,” and is either listed on one or more of the 23 authoritative lists, including Prop 65, or is listed by DTSC using the criteria specified in section 69502.2(b) (DTSC; Authoritative Lists; Section 69502.2). Consideration is also given to products that have the potential to release microplastics into the environment, as well as to products that would leverage the work of other agencies within the California Environmental Protection Agency (Safer Consumer Products Program 2021, p. 4). 

Including a particular category of product in the Work Plan does not mean that the SCP will ultimately propose listing any products as a PP from that category, and does not subject the products in the category to immediate regulation or legal obligations. Any listing of a product as a PP would begin a process in which the manufacturer of the product would conduct an “Alternatives Analysis” to determine if the product can be made safer through chemical substitution or product redesign (Safer Consumer Products Program 2021, p. 3; Alternative Analysis). Overall, identifying a product category in the Work Plan is the first of many steps that may ultimately lead to a regulatory response. The steps to regulatory response after a PP is identified are as follows: screening; public engagement; developing a Product-Chemical Profile; rulemaking; Alternative Analysis; and, finally, a regulatory response (Safer Consumer Products Program 2021, p. 17).

The comment period for the 2021-2023 Priority Product Work Plan ended on March 19, 2021, and a date for the final publication has not been set (  

Cardno ChemRisk has assisted companies in understanding potential product exposures and health risks. Our scientists have extensive experience conducting alternative analyses and risk assessments, and have evaluated diverse scenarios for regulatory compliance, including for Candidate Chemicals, many of which are listed under California’s Prop 65. Please visit Cardno ChemRisk’s Proposition 65 and Consumer Products pages for more information regarding our capabilities.