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Second Update to California Prop 65 Short-form Warning Proposed Amendment
Compliance & Regulatory NewsEnvironmental Health & Safety

Second Update to California Prop 65 Short-form Warning Proposed Amendment

By  Veronica Marrero, Regulatory Compliance Specialist

Earlier this year, we informed you of an announcement the California Office of Environmental Health Hazard Assessment (OEHHA) made on December 13, 2021 about changes made to the text of the proposed amendment to short-form warnings (Article 6 Clear and Reasonable Warnings of the California Code of Regulations, Title 27). 

On April 5, 2022, OEHHA published a second modification to the text of the proposed amendment.

Below is a summary of the new changes to the proposed amendment:

  • Consumer Product Exposure Warnings – Methods of Transmission (§ 25602):
    • The maximum label size for short-form warnings was that was previously changed from 5 square inches to 12 square inches is now completely removed. There is no longer a maximum label size for short-form warnings; short-form warnings can now be used on labels of any size.
  • Consumer Product Exposure Warnings – Content (§ 25603 (b)) and Food Exposure Warnings – Content (§ 25607.2 (b)):
  • he warning statement content (or wording format) were updated once again. The wording “exposes you to” for the statements listed below has been changed to “can expose you to.” These new wording formats are outlined below.
    • For exposures to listed carcinogens:
      • Can expose you to [name of chemical], a carcinogen
    • For exposures to listed reproductive toxicants:
      • Can expose you to [name of chemical], a reproductive toxicant
    • For exposures to both listed carcinogens and reproductive toxicants:
      • Can expose you to [name of chemical], a carcinogen, and [name of chemical], a reproductive toxicant
    • For exposures to a chemical that is listed as both a carcinogen and a reproductive toxicant:
      • Can expose you to [name of chemical], a carcinogen and reproductive toxicant

Timeline for amended regulation to go be in force is now two years (rather than one year) after the effective date of the amendments [see § 25602(e) and § 25607.2(c)].

This notice by OEHHA initiated a public comment period from December 17, 2021 to January 21, 2022. The public comment forum can be found here.

TotalSDS will consistently monitor for final rulemakings and effective dates to ensure we are maintaining the most up to date criteria in our TotalSDS Authoring software. For more information on how this may affect your company, get in touch.

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