Product Stewardship

Review of Product Stewardship management systems and content, especially for fulfillment of the American Chemistry Council’s Product Safety Code.

Assist with compliance with the U.S. Toxic Substances Control Act (TSCA, the primary Federal chemical management law), and other major chemical management laws such as EU REACH and now UK REACH.

Assist with compliance for hazard communication (GHS Safety Data Sheets) and labeling, including California Proposition 65.

Food Contact and Pharmaceutical Excipients

Review compliance with food contact clearances for specific substances and packaging, and clearances for excipients, in the US, EU and several Asian countries. Identify high risk processes and applications via FMEA or HACCP analyses for plants that manufacture excipients or food contact materials. Provide assistance with cGMP or HACCP certification or written hazard analyses and risk-based preventative control plans as specified in the U.S. Food Safety Modernization Act. Provide guidance on upcoming major changes to California Proposition 65 for labeling and certain food contact substances.

Drinking Water

Assist drinking water suppliers to move beyond basic compliance for drinking water testing and reporting as prescribed by the U.S. Safe Drinking Water Act.  Review drinking water infrastructure (piping, plumbing, fixtures, and water treatment chemicals) for causes of lead and other contaminants, and causes of corrosion and permeation.  Currently working with world class experts to develop and deploy a lead pipe sensor, which will be integral for identifying and replacing lead pipes and service lines across the U.S.  Opportunities available for joining the team and investing in the project.  We are available to plan and test if you are switching your drinking water supply. Contact us if you have any questions or concerns regarding your drinking water supply or water at your tap.


Review EHS and Product Stewardship acquisition and integration manuals and checklists, especially for reviewing raw materials and products to ensure long term viability of the supply chain. Provide due diligence during the acquisition (or divestment) phase, and give direct assistance in the integration phase.

Expert Testimony

Review documents, conduct engineering and forensic analyses as needed, and prepare documents for depositions and expert testimony in court. Provide advocacy and comments on pending legislation and regulations pertaining to chemical management, food safety and drinking water.