3E EH&S Expressions Blog

3E EH&S Expressions is our forum for sharing our latest musings and observations on the ever-evolving EH&S regulatory compliance landscape. Here we will be introducing you to some of 3E’s most prolific and valued subject matter specialists weighing in on some of the more complex and time-consuming issues affecting our industry today, including TSCA Reform, REACH, GHS, Conflict Minerals and more.

May 13, 2016Bernie Henn

Significantly, HARPC has changed allergen control through the Good Manufacturing Practices (GMP) revisions. In fact, over 25 allergen related GMP mentions can be found in HARPC. Recommendations have been replaced with required GMPs under the HARPC rule. Allergen cross-contact must be mentioned in the GMP’s. Allergen controls must also address handling, storage and use.

May 12, 2016Bernie Henn

FSMA is changing how companies manage undeclared allergen risk during the production of finished products. For example, raw agricultural commodities are exempt from FALCPA. That does not mean there is not still a risk that a commodity ingredient contains an undeclared and unexpected allergen such as a peanut protein. Food fraud can also be an allergen source. An example of food fraud is an undocumented substitution of a cheaper peanut protein for an almond protein.

May 10, 2016Bernie Henn

The Food Safety Modernization Act (FSMA) has posed significant changes in the food industry, with specific changes to allergen controls and good manufacturing practices (GMPs). Having GMPs for allergen control is no longer just a company best practice but a requirement of companies under FSMA.

February 23, 2016Bernie Henn

On December 17, 2015, the European Chemical Agency (ECHA) added five new Substances of Very High Concern (SVHC) to the Candidate List for Authorization.

December 22, 2015James Lee

In the evening of 17 December 2015, the U.S. Senate passed the “Frank R. Lautenberg Chemical Safety for the 21st Century Act” (S. 697), which reforms the Toxic Substances Control Act (TSCA) for the first time since its enactment in 1976. The Senate approved the legislation by unanimous consent in a voice vote and broke its months-long deadlock on the floor vote. The language of the passed bill is an updated version of S. 697 from October. Sponsored by Senators David Vitter (R-LA) and Tom Udall (D-NM), S. 697 has gained filibuster-proof support this year. The next phase of the legislative process is a conference committee to reconcile the differences in the House and Senate versions of TSCA reform.

December 3, 2015Kirsten Wallerstedt

On 24 November 2015, the California Office of Environmental Health Hazard Assessment (OEHHA) repealed its rulemaking action published on 16 January 2015 amending Article 6 on "Clear and Reasonable Warnings" under Proposition 65. OEHHA at the same time published another proposal for a new Article 6 dated 27 November 2015, which now replaces the previous version of the proposed amendments.

November 6, 2015James Lee

On 26 October 2015, the International Agency for Research on Cancer (IARC), an agency of the World Health Organization (WHO), published its evaluation of the carcinogenicity of the consumption of red meat and processed meat. The IARC Monographs Programme has classified the consumption of red meat as probably carcinogenic to humans (Group 2A). Processed meat was classified as carcinogenic to humans (Group 1). This evaluation will be included in Volume 114 of the IARC Monographs.

October 21, 2015James Lee

On 9 October 2015, the Ministry of Labor and Social Welfare published and enacted a new Mexican Official Standard, NOM-018-STPS-2015, Harmonized System for the Identification and Communication of Hazards and Risks of Hazardous Chemicals in the Workplace.

July 13, 2015Kami Blake

On June 15, 2015, the European Chemical Agency (ECHA) added two new Substances of Very High Concern (SVHC) to the Candidate List for Authorization.

May 8, 2015Kirsten Wallerstedt

The June 1, 2015* due date is quickly approaching for year-two Form SD and Conflict Minerals Reports (CMRs) filings with the U.S. Securities and Exchange Commission (SEC). Here are some best practices and suggestions to keep in mind as you draft and finalize your public disclosure.