Existing law establishes the State Department of Public Health and vests it with various duties, including administration of the Consumer Product Safety Program. Existing law, commencing January 1, 2025, prohibits the manufacture, sale, delivery, holding, or offer for sale in commerce of any cosmetic product that contains specified intentionally added ingredients.

This bill would, commencing January 1, 2025, prohibit the sale or delivery to a person under 13 years of age of an over-the-counter skin care product or cosmetic product advertised to address skin aging that contains vitamin A or its derivatives or an alpha hydroxy acid, and would require an entity that conducts business in California to take specified any of several specified actions to ensure that the purchaser of an above-described product is not under 13 years of age. The bill would authorize specified prosecutorial agencies, including the Attorney General, a district attorney, or a city attorney, to bring a civil action against a person or entity that violates this prohibition.

Existing law establishes the State Department of Public Health and vests it with various duties, including administration of the Consumer Product Safety Program. Existing law, commencing January 1, 2025, prohibits the manufacture, sale, delivery, holding, or offer for sale in commerce of any cosmetic product that contains specified intentionally added ingredients.

This bill would, commencing January 1, 2025, prohibit the sale or delivery to a person under 13 years of age of an over-the-counter skin care product or cosmetic product advertised to address skin aging that contains vitamin A or its derivatives or an alpha hydroxy acid. acid, and would require an entity that conducts business in California to take specified actions to ensure that the purchaser of an above-described product is not under 13 years of age. The bill would authorize specified prosecutorial agencies, including the Attorney General, a district attorney, or a city attorney, to bring a civil action against a person or entity that violates this prohibition.

Existing law requires the Department of Toxic Substances Control to establish the Hazardous Waste Resource and Research Coordination Program, which consists of a database of known hazardous waste research and a pool of research consultants qualified in the field of hazardous waste management, as provided. Existing law requires the department to assemble and annually update a bibliographic cross-referenced database containing certain information on known hazardous waste research programs, including the specific problems facing hazardous waste generators that the research is designed to address. The department is required to make the information in the database on known hazardous waste research programs available to the public at a cost not greater than the departments printing and mailing costs.

This bill would require the department to also post the information described above on its internet website. The bill would require the department, on or before July 1, 2025, to convene a stakeholder working group to identify potential technologies to reduce the generation of hazardous waste.

Date of Hearing: May 8, 2024

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Buffy Wicks, Chair

ABPCA Bill Id:AB 2491

Author:(Lee) – As Amended Ver:April 25, 2024

Urgency: No State Mandated Local Program: No Reimbursable: No

SUMMARY:

This bill prohibits a person or entity from selling to a person under 13 years of age an over-the-counter skin care product or cosmetic product advertised to address skin aging that contains specified intentionally added ingredients.

Specifically, this bill, among other things:

1) Prohibits, beginning January 1, 2025, a person or entity from selling to a person under 13 years of age an over-the-counter skin care product or cosmetic product advertised to address skin aging that contains either of the following intentionally added ingredients:

a) Vitamin A and its derivatives, including retinoids and retinol.

b) An alpha hydroxy acid (AHA), including glycolic acid, ascorbic acid (vitamin C), or citric acid.

2) Requires a person or business that conducts business in California to take a reasonable step to ensure the purchaser of a product described in 1, above, is not under the age of 13. A reasonable step includes:

a) Placing a prominent notice next to the physical product or in the product's online description that states the product is not meant for anyone under 13 years of age.

b) Requiring the purchaser to provide a date of birth or otherwise confirm their age before purchasing the product.

c) Requiring the purchaser to use a non-prepaid credit card for an online purchase.

d) Requiring the purchaser to verify their age by means of a valid form of identification that includes a photograph of the purchaser and their date of birth.

3) Provides that a person or entity who violates the provisions of the bill is liable for a civil penalty, not to exceed $10,000 per day for each violation. Provides that the civil penalty may be assessed and recovered in a civil action brought in any court of competent jurisdiction. Requires the court, in assessing the amount of a civil penalty for a violation of the bill, to consider specified factors.

4) Provides that a civil action for a violation of this bill may be brought by the Attorney General in the name of the people of the state, by a district attorney, by a city or county attorney, by a county counsel, or by a city prosecutor. Requires civil penalties collected pursuant to this section be paid to the office that brought the action.

FISCAL EFFECT:

1) Cost pressures (Trial Court Trust Fund, General Fund) to adjudicate enforcement actions filed by public prosecutors. Actual costs will depend on the number of violations and the number of cases filed by prosecutors. It generally costs approximately $1,000 to operate a courtroom for one hour. If 10 cases are filed statewide and each requires two days of court time to resolve, the resulting workload cost to the courts would be about $160,000. Although courts are not funded on the basis of workload, increased pressure on the Trial Court Trust Fund may create a need for increased funding for courts from the General Fund. The Governor’s 2024-25 budget proposes $83.1 million ongoing from the General Fund to backfill declining revenue to the Trial Court Trust Fund.

2) Workload cost pressures (General Fund) to the Department of Justice (DOJ) of an unknown but potentially significant amount. If DOJ files enforcement actions as authorized by this bill, it may result in a significant workload increase to DOJ. If DOJ needs to hire an additional attorney to handle this workload increase, costs will likely exceed $150,000 annually. If DOJ chooses not to file enforcement actions, DOJ will not incur any costs.

According to the Legislative Analyst’s Office, the General Fund faces a structural deficit in the tens of billions of dollars over the next several fiscal years.

COMMENTS:

1) Purpose. According to the author:

Platforms such as TikTok and Instagram are filled with beauty influencers promoting makeup routines and skincare products, resulting in a phenomenon dubbed "Sephora Kids." Young children exposed to this content are driven to buy trendy products, including anti-aging skincare, that are targeted to adult skin concerns, without receiving proper information about the effects or science behind the skincare…AB 2491 protects our youth from the unnecessary risks of using products that are not suitable for their skincare needs. These anti-aging products offer no benefits to children and preteens.

2) Background. As noted by the author, there has been an uptick in recent media attention regarding younger children purchasing and using anti-aging products, with social media serving a key culprit. Writing in support of this bill, a coalition of environmental and public health groups contends that retinols and AHAs, which are common ingredients in anti-aging skin products, are highly irritating, and when used regularly, can cause skin to turn red, itch, swell, become dry, and peel. Eventually, retinols and AHAs can cause topical dermatitis and eczema. The coalition argues that, “besides being an irritant, retinol is a known photo-carcinogen and developmental toxicant. The California Environmental Protection Agency lists retinol and retinyl esters as Proposition 65 developmental toxicants.”

Writing in opposition, the Personal Care Products Council and other business groups argue that while they do not support children using anti-aging products, this bill presents significant practical issues with compliance and enforcement:

AB 2491 bans a wide range of OTC cosmetic products without consideration of the concentrations of the targeted ingredients. Products including moisturizers, sunscreens and cleansers contain these ingredients at varying levels. As written, the onus is on a retail establishment or cashier to determine two things at point of sale—whether someone is under the age of 13, and whether the product they are purchasing is covered by this bill. The latter criteria requires knowledge of how the product is advertised. E-commerce sales channels would further complicate enforcement of the proposed product sales restrictions.

Analysis Prepared by: Nikita Koraddi / APPR. / (916) 319-2081

Date of Hearing: April 23, 2024

ASSEMBLY COMMITTEE ON ENVIRONMENTAL SAFETY AND TOXIC MATERIALS

Eduardo Garcia, Chair

ABPCA Bill Id:AB 2491 (

Author:Lee) – As Amended Ver:April 18, 2024

SUBJECT: Cosmetic products: safety

SUMMARY: Prohibits, beginning January 1, 2025, a person or entity from selling to a person under 13 years of age an over-the-counter skin care product or cosmetic product advertised to address skin aging that contains specified intentionally added ingredients. Specifically, this bill:

1) Prohibits, beginning January 1, 2025, a person or entity from selling to a person under 13 years of age an over-the-counter skin care product or cosmetic product advertised to address skin aging that contains either of the following intentionally added ingredients:

a) Vitamin A and its derivatives, including, but not limited to, retinoids and retinol, and

b) An alpha hydroxy acid, including, but not limited to, glycolic acid, ascorbic acid (vitamin C), or citric acid.

2) Requires a person or business that conducts business in California to take reasonable steps to ensure that the purchaser of a product described in this bill is not under the age of 13. Reasonable steps include, but are not limited to, all of the following:

a) Placing a prominent notice next to the physical product or in the product's online description that states that the product is not meant for anyone under 13 years of age;

b) Requires the purchaser to provide a date of birth or otherwise confirm their age before purchasing;

c) Requiring the purchaser to use a non-prepaid credit card for an online purchase; and,

d) Requiring the purchaser to verify their age by means of a valid form of identification that includes a photograph of the purchaser and their date of birth.

3) Provides that a person or entity who violates the provisions of the bill is liable for a civil penalty, not to exceed ten thousand dollars per day for each violation; provides that the civil penalty may be assessed and recovered in a civil action brought in any court of competent jurisdiction.

4) Requires the court, in assessing the amount of a civil penalty for a violation of the bill, to consider all of the following:

a) The nature and extent of the violation;

b) The number of, and severity of, the violations;

c) The economic effect of the penalty on the violator;

d) Whether the violator took good faith measures to comply with this section and when these measures were taken;

e) The deterrent effect that the imposition of the penalty would have on both the violator and the regulated community as a whole; and,

f) Whether there were contributing environmental factors that a reasonable person knew or should have known about.

EXISTING LAW:

1. Prohibits, commencing January 1, 2009, a person or entity from manufacturing, selling, or distributing in commerce any toy or child care article that contains di-(2-ethylhexyl) phthalate, dibutyl phthalate, or benzyl butyl phthalate. (Health and Safety Code (HSC) § 108937 (a))
2. Prohibits, commencing January 1, 2009, a person or entity from manufacturing, selling, or distributing in commerce any toy or child care article intended for use by a child under three years of age if that product can be placed in the child's mouth and contains diisononyl phthalate, diisodecyl phthalate, or di-n-octyl phthalate. (HSC § 108937(b))
3. Prohibits, on and after July 1, 2013, a person from manufacturing, selling, or distributing in commerce any bottle or cup that contains bisphenol A (BPA) if the bottle or cup is designed or intended to be filled with any liquid, food, or beverage intended primarily for consumption from that bottle or cup by children three years of age or younger. (HSC § 108940)
4. Prohibits, on and after July 1, 2023, a person, including, but not limited to, a manufacturer, from selling or distributing in commerce in this state any new, not previously owned, juvenile product that contains regulated perfluoroalkyl and polyfluoroalkyl substances (PFAS). (HSC § 108946)
5. Requires, pursuant to the federal Food, Drug & Cosmetic Act (FD&C Act), cosmetics produced or distributed for retail sale to consumers for their personal care to bear an ingredient declaration. (21 Code of Federal Regulations § 701.3)
6. Defines, pursuant to the Sherman Food, Drug, Cosmetic Law (Sherman Act), "cosmetic" as any article, or its components, intended to be rubbed, poured, sprinkled, or sprayed on, introduced into, or otherwise applied to, the human body, or any part of the human body, for cleansing, beautifying, promoting attractiveness, or altering the appearance. Provides that the term "cosmetic" does not include soap. Makes it unlawful for any person to manufacture, sell, deliver, hold, or offer for sale any cosmetic that is adulterated. Makes it unlawful for any person to adulterate any cosmetic. Makes it unlawful for any person to receive in commerce any cosmetic that is adulterated or to deliver or proffer for delivery any such cosmetic. (HSC § 109900)
7. Requires, pursuant to the Safe Consumer Cosmetic Act (Cosmetics Act), a manufacturer of a cosmetic that is subject to regulation by the federal Food and Drug Administration (FDA) to submit to the California Department of Public Health (CDPH) a list of its cosmetic products sold in California that contain any ingredient that is a chemical identified as causing cancer or reproductive toxicity. (HSC § 111792)

FISCAL EFFECT: Unknown.

COMMENTS:

Need for the bill: According to the author, "Platforms such as TikTok and Instagram are filled with beauty influencers promoting makeup routines and skincare products, resulting in a phenomenon dubbed "Sephora Kids." Young children exposed to this content are driven to buy trendy products, including anti-aging skincare, that are targeted to adult skin concerns, without receiving proper information about the effects or science behind the skincare.

Social media has kicked off a trend of children using anti-aging products with powerful active ingredients that may be harmful to them. We’re seeing this on both the national and international level. AB 2491 protects our youth from the unnecessary risks of using products that are not suitable for their skincare needs. These anti-aging products offer no benefits to children and preteens."

Federal cosmetics regulatory requirements: Neither the FDA nor CDPH require premarket safety testing, review, or approval of cosmetic products. Under the FD&C Act, cosmetics and their ingredients are not required to be approved before they are sold to the public, and the FDA does not have the authority to require manufacturers to file health and safety data on cosmetic ingredients or to order a recall of a dangerous cosmetic product.

Public health concerns with cosmetics: Cosmetic products are sold to consumers across California, including to children who are still in the formative years of development. These products are used as part of daily beauty and cleansing routines, often times on the skin’s most sensitive areas, like the face, eyelids, and lips. Cosmetic products are most heavily used by women, including those of childbearing age, increasing the likelihood of exposing mothers, fetuses, and nursing children to substances that can cause cancer and reproductive toxicity. That is why it is so important that cosmetic products are safe, properly labeled, and free of contamination.

Recent social media trend dealing with cosmetics: Recently there has been a lot of media attention regarding young children purchasing and using anti-aging products and the main culprit is social media. To highlight this media coverage, below are two articles published in USA Today:

According to the article, "Young girls are flooding Sephora in what some call an 'epidemic.' So we talked to their moms," published January 20, 2024:

"People say that there's an 'epidemic' in the works, but not the infectious disease kind. Instead, it’s swarms of preteens flooding Sephora stores across the country, ravaging makeup and skincare displays for Drunk Elephant and Rare Beauty products that some experts argue are not suitable for children. 

Videos of young girls crowding Sephora aisles with baskets carrying hundreds of dollars worth of products have dominated TikTok for several weeks. People say the store looks like an elementary school for the beauty-obsessed 10-year-olds, some of whom have been caught treating employees poorly and destroying displays.

Nannies have chimed in with stories of parents giving them unlimited budgets to take their kids makeup shopping, a 'humbling and embarrassing' experience, one noted on TikTok, wondering 'when do we say enough is enough when it’s not our problem to say enough is enough?'"

According to the article, "Sephora kids are mobbing retinol, anti-aging products. Dermatologists say it's a problem," published on January 26, 2024:

"Kids are swarming Sephora and have never been more obsessed with skincare − and it might be a problem. Dermatologists say they're seeing more and more children as patients with several-step skincare routines, more-often filled with products they either don't need or that are harming their skin.

Dermatologist Dr. Brooke Jeffy recalls one patient, around age 11, who developed a severe rash around her eyes from retinol, an ingredient known for anti-aging, which she says the child insisted on using. 'This rash had been going on for so long and was so intense, it's probably going to take at least a month, if not more, to totally resolve,' Jeffy says. 'All for trying to use an anti-aging product that she doesn't need.'

Now, Jeffy and other dermatologists are sounding the alarm against a beauty industry and culture that are pushing unnecessary products and fears of aging onto children too young to even drive.

'They don't understand the function of skin and that it's not just this wall you can throw anything at,' Jeffy says. 'It's kind of word of reason − word of their parents, sometimes, word of me or other physicians − against this huge industry of beauty and social media.'

Jeffy says she's seen children who use up to eight products every morning. On TikTok, where she makes videos about the dangers of adult skincare for kids, she's seen some routines as long as 12 steps.

The ingredients that are the main culprits for harming kids' skin, she says, are retinol, exfoliating acids and fragrance, which can cause irritation and the development of contact allergies. 'When the skin barrier is damaged by constant irritation like this, it gets dry,' Jeffy says. 'It's more prone to infection, more prone to getting rashes and more prone to breakouts.' She adds irritation also makes the skin barrier less efficient at protecting the skin from environmental damage, like ultraviolet radiation or pollution.

Dermatologists will sometimes recommend retinoid products to teens and tweens to treat a specific condition, such as acne; however, these decisions, Jeffy says, are weighed by medical professionals against potential downsides. For anti-aging purposes, retinol is unnecessary for those who haven't reached their twenties, which is when collagen begins to decrease, Dr. Danilo Del Campo, a dermatologist in Chicago, says. Jeffy largely blames social media for kids' preoccupation with skincare and anti-aging products. She also says the pandemic, which put many work and school activities on Zoom, also likely played a role, since people are now frequently confronted with how their face looks on screen."

According to the article, Kids exploring skincare may be a risk from influencers hyping incorrect products: UCLA experts advise a minimalist approach and an emphatic discussion with parents, published January 25, 2024 on UCLA Health.org:

"TikTok, Instragram—the entirety of cyberspace—are awash with Generation Alpha (under age 13) 'influencers' advising tweens and teens to start a skincare routine post haste. Young consumers are taking it to heart. What's a parent to do when faced with their kids' request for expensive skincare serums and night creams?

UCLA Health's Carl Cheng, MD, assistant clinical professor of dermatology and board-certified dermatologist and pediatric dermatologist, and Jayden Galamgam, MD, board-certified dermatologist and pediatric dermatology fellow, offer important insights:

Q: What trends are you seeing in your practice among tweens and teens:

Dr. Cheng: Parents are bringing their pre-teens and teens in for skincare routines, even though they have no skin pathology of concern – no acne or eczema, etc. These visits are requested by children themselves who want a skincare routine, largely driven by what they have seen and heard from friends and on social media. Information is widely accessible, and so is misinformation.

Dr. Galamgam: I have noticed pre-teens and teens coming in with allergic contact dermatitis of the face. Contact dermatitis is a hypersensitivity reaction that can occur due to direct contact with an allergen. It manifests as red, scaly, itchy rashes in areas of exposure. This may suggest that patients are being exposed to facial ingredients that are causing these reactions.

Q: What is not appropriate for children's skin?

Dr. Cheng: Many products have what we call 'active' ingredients—like salicylic acid, retinols, peptides. They are more suitable for mature skin to target wrinkles or skin with specific concerns like acne. But for tweens and teens, these ingredients can do damage, irritate the skin and cause the reverse effects they are hoping to achieve.

Dr. Galamgam: Retinols and retinoids can sometimes be a problem for young children, especially if there is not a clinical indication such as acne. Retinols can sometimes cause retinoid dermatitis, a type of scaly rash. Additionally, retinols can make you susceptible to sunburn and sun damage."

Laws dealing with chemicals and children: Over the years, the Legislature has passed laws that are specific to young children. Particularly these laws have focused on prohibited certain chemicals to be in products that are used by young children. Following are a few bills that prohibit the sale of products to young children if they contain certain chemicals:

• Phthalates in products for young children: AB 1108 (Ma, Chapter 672, Statutes of 2007). Prohibits the use of phthalates in toys and childcare products designed for babies and children under three years of age. Requires manufacturers to use the least toxic alternative when replacing phthalates.
• Product safety: BPA: AB 1319 (Butler, Chapter 467, Statutes of 2011) Prohibits the sale, manufacture, or distribution of a bottle or cup or a liquid, food or beverage in a can, jar or plastic bottle that contains BPA if the item is primarily intended for children three years of age or younger. Requires manufacturers to use the least toxic alternative when replacing BPA in containers. The bill provides that if the Department of Toxic Substances Control adopts a regulatory response regarding the use of BPA in a product that is prohibited by this bill, then this law shall not apply to that product.
• Product safety: juvenile products: chemicals: PFAS: AB 652 (Friedman, Chapter 500, Statutes of 2021) prohibits, on or after July 1, 2023, a person from selling or distributing in commerce any new juvenile products that contain regulated PFAS. Defines PFAS as intentionally added PFAS or the presence of PFAS in a product or product component at or above 100 parts per million, as measured in total organic fluorine.

This bill: Prohibits, beginning January 1, 2025, a person or entity from selling to a person under 13 years of age, an over-the-counter skin care product or cosmetic product advertised to address skin aging that contains either of the specified intentionally added ingredients. The goal of the bill is to protect children from certain chemicals that may, especially due to their age and developmental state, be harmful to them. Even though these social media trends can be short-lived, anything on the internet could live forever. AB 2491 ensures that consumers are better informed and children are protected from potentially harmful chemicals.

Additional discussion: As the bill moves through the legislative process, the author may wish to continue a dialogue with stakeholders to provide more clarity on how a seller of cosmetics covered under the bill can comply with the bills requirements. Additionally, the bill is placed in a code section that does not have any state entity overseeing or enforcing it. The author may wish to consider state enforcement options, perhaps including placement under the Sherman Act.

Technical issue: The bill was recently amended to provide a list of options to sellers of cosmetics covered under the bill. However, the language requires a seller of these cosmetics to use all of the reasonable options provided. The intent was a menu of options that a seller could pick from in order to be in compliance with the bill. The rationale for this menu of compliance options is to provide the seller of cosmetics with flexibility and still inform the consumer. Going forward the author may wish to clarify that this is a menu of options by changing "all" to "any".

Arguments in support: According to the California Association of Professional Scientists:

"Common ingredients in anti-aging skin products are retinols, glycolic acid and ascorbic acid. These ingredients are used to improve the appearance of fine lines and wrinkles by boosting collagen production and increasing cell turnover. However, they can also cause skin irritations such as redness, itching, swelling, dryness, peeling, and potentially lead to topical dermatitis and eczema. Children do not benefit from these products so there is only potential for harm. There is also the concern that the irritation and damage to the skin barrier these products create damages the skin's ability to protect itself from sun exposure and the chronic irritation may accelerate changes in the skin associated with aging. Thus, a product that may have benefit in an adult offers only risk in a child because they do not have the damage these products address to begin with."

Arguments in opposition: According to a coalition in opposition to the bill:

"We commend Assemblymember Lee for raising this important issue and highlighting a concerning social media trend among preteens. Our organizations do not support children using anti-aging products.

While we recognize and share Assemblymember Lee’s concerns about this trend, this bill presents significant practical issues with compliance and enforcement. AB 2491 bans a wide range of OTC [over-the-counter] cosmetic products without consideration of the concentrations of the targeted ingredients. Products including moisturizers, sunscreens and cleansers contain these ingredients at varying levels. As written, the onus is on a retail establishment or cashier to determine two things at point of sale—whether someone is under the age of 13, and whether the product they are purchasing is covered by this bill. The latter criteria requires knowledge of how the product is advertised. Ecommerce sales channels would further complicate enforcement of the proposed product sales restrictions.

We believe that manufacturers, retailers, and even parents have a role to play in ensuring children are using products that are appropriate for their skin. Cosmetic and personal care product manufacturers remain committed to consumer education and appropriate skin care regimens for all ages.

Again, we appreciate the intent of this bill. However, AB 2491 is seemingly impossible to comply with and unlikely to alleviate the impact of this social media trend."

Related legislation:

1) AB 2316 (Gabriel). Prohibits, beginning on July 1, 2025, a public school from offering, selling, or otherwise provide any food containing specified synthetic food dyes or titanium dioxide. This bill is pending action in the Assembly Environmental Safety and Toxic Materials Committee.

2) AB 2365 (Haney). Adds kratom products to the Sherman Act requires processors, as defined, to annually register their kratom products with the CDPH; requires a certificate of analysis from an accredited independent laboratory as part of the registration confirming kratom products meet the specified requirements; establishes labeling and packaging requirements for kratom products; and prohibits the sale of kratom products to individuals under 21 years of age. This bill is pending action in the Assembly Environmental Safety and Toxic Materials Committee.

3) AB 652 (Freidman, Chapter 500, Statutes of 2021). Prohibits, on or after July 1, 2023, a person from selling or distributing in commerce any new juvenile product that contains PFAS.

4) AB 1319 (Butler, Chapter 467, Statutes of 2011). Prohibits the sale, manufacture, or distribution of a bottle or cup or a liquid, food or beverage in a can, jar or plastic bottle that contains BPA if the item is primarily intended for children three years of age or younger.

5) AB 1108 (Ma, Chapter 672, Statutes of 2007). Prohibits the use of phthalates in toys and childcare products designed for babies and children under three years of age. Requires manufacturers to use the least toxic alternative when replacing phthalates in accordance with this law.

REGISTERED SUPPORT / OPPOSITION:

Support

California Association of Professional Scientists
California Nurses for Environmental Health and Justice
Center for Environmental Health
Childrens Advocacy Institute
Cleanearth4kids.org
Consumer Attorneys of California
Consumer Federation of California
Environmental Working Group
FACTS: Families Advocating for Chemical & Toxics Safety
GMO Science
Just the Goods
Moms Advocating Sustainability
Non-toxic Neighborhoods
Pink Panthers
Recolte Energy
Social Eco Education
The Keep a Breast Foundation

Opposition

Cal Chamber
California Manufacturers & Technology Association
California Retailers Association
California Trucking Association

Civil Justice Association of California
Personal Care Products Council

Analysis Prepared by: Josh Tooker / E.S. & T.M. /