California Prop 65 Updates
Sometimes I feel behind in the regulatory world. It is just a fact that regulations often change faster than one has time to process. A good case for this is California’s Proposition 65. Not only are there multiple changes for how to represent substances that are on the list, but the list itself changed in May 2018. For more information on “how to represent” and the August 30, 2018 changeover date, take a look at ICC’s blog found here
To refresh your memory, the Safe Drinking Water and Toxic Enforcement Act of 1986 is the official name for California’s Prop 65. The list has to be revised and republished at least once per year. California’s Office of Environmental Health Hazard Assessment (OEHHA) is the agency responsible for Prop 65 implementation. They consider adding chemicals to the list when some other “authoritative body” makes a determination regarding a substance’s ability to cause cancer, birth defects or other reproductive harm. Shown below are all of the new substances that were added and or removed by month. They are listed by name, type of toxicity and Chemical Abstracts Service Registry Number (CAS).
Now would be a good time to see not only if you are up to date on the new required “warnings” but if any of your products or substances were added to the new list.
Proposition 65 – Additions and Deletions
October 2017
- N, N-Dimethylformamide for cancer with CAS 68-12-2
- 2-Mercaptobenzothiazole for cancer with CAS 149-30-4
- Tetrabromobisphenol A for cancer with CAS 79-94-7
- There were no chemicals delisted this month.
November 2017
- Perfluorooctane sulfonate (PFOS) for developmental effects with CAS 1763-23-1
- Perfluorooctanoic acid (PFOA) for developmental effects with CAS 335-67-1
- There were no chemicals delisted this month.
December 2017
- Chlorpyrifos for developmental effects with CAS 2921-88-2
- n-Hexane for male reproductive effects with CAS 110-54-3
- Vinylidene chloride (1,1-Dichloroethylene) for cancer with CAS 75-35-4
- There were no chemicals delisted this month.
May 2018
- TRIM® VX for cancer. This chemical has no specific CAS number.
- There were no chemicals delisted this month.
There is no requirement to include Prop 65 information on OSHA HazCom2012 labels or Safety Data Sheets (SDS). However, many companies chose to include it in Section 15 under Regulatory Information. For access to the entire current list, last updated on May 25, 2018, click here.
Should you have any questions regarding how to list Prop 65 information on your SDS documents or any other regulatory, SDS or label questions, contact us today.