On April 5, 2022, California’s Office of Environmental Health Hazard Assessment (OEHHA) issued a notice proposing additional modifications to its proposal to modify Prop 65 Article 6 Clear and Reasonable Warnings - Short Form. The latest proposal removes the limitation on the use of short-form warnings for smaller products and retains the requirement to list a chemical for toxicity endpoints.
OEHHA first proposed revisions to the short-form warning in January 2021, after public comments the proposal was revised in December 2021. This second modification to the proposed rule was in response to the public comments received for December 2021’s notice.
Following is a summary of revisions proposed in the latest notice:
|
Prop 65 Article 6 Clear and Reasonable Warnings Short-Form Proposal |
|
| Requirements | Revisions |
| Label Size | The label size and package shape limitations of the short-form warning were removed. This modification means that the short-form can be used on product labels of any size, regardless of package size and shape. |
| Font Size | The requirement of font type size for warnings must be the same as the largest type size providing consumer information was removed. The existing provision requiring a minimum of 6-point type size when using short-form warnings remains unchanged. |
| Language | Warnings were changed from “…exposes you to…” to “…can exposure you to…” |
| Effective Date | The date that the regulation becomes operative has been modified to be two years rather than one year after the effective date of the amendments. This would be sufficient time for businesses to implement changes to the short form. |
Based on the current proposal including the modifications from January 8, 2021, and December 13, 2021, the short-form warning options are as follows:
Example short-form warning for listed carcinogen.
Example short-form warning for listed reproductive toxicant.
Example short-form warning for exposure to both listed carcinogens and reproductive toxicants:
For exposure to chemicals listed as both a carcinogen and a reproductive toxicant:
The following link provides additional information about further modifications to the proposed amendments:
https://oehha.ca.gov/media/downloads/crnr/proposedregtext2ndmodificationshortform040522.pdf
About Intertek
Intertek is a leading Total Quality Assurance provider to industries worldwide. Our network of more than 1,000 laboratories and offices and more than 100 countries, delivers innovative and bespoke Assurance, Testing, Inspection and Certification solutions for our customers’ operations and supply chains. Intertek Total Quality Assurance expertise, delivered consistently with precision, pace and passion, enabling our customers to power ahead safely.
粤ICP备08001533号-1
Copyright © 2006-2021 Intertek
