California Publishes New Proposition 65 Warnings Website
The State of California Office of Environmental Health Hazard Assessment (OEHHA) has launched its new Proposition 65 Warnings Website https://www.p65warnings.ca.gov/. This database driven site is aimed at consumers and allows users to choose Prop 65 chemicals, product categories and places with potential for Prop 65 related exposures. The website is only partially populated with data at this time.
Several of the postings will be of interest to our manufacturer customers. For example, there is a page for Furniture Products. The page shows the new Prop 65 warning that becomes mandatory in one year (8/30/2018).
“WARNING: This product can expose you to chemicals including [name of one or more chemicals known to cause cancer, name of one or more chemicals known to cause reproductive toxicity, or name of one or more chemicals known to cause both cancer and birth defects or other reproductive harm], which is [are] known to the State of California to cause cancer or birth defects or other reproductive harm. For more information go to www.P65Warnings.ca.gov/furniture.”
Two furniture-related Fact Sheets are available: Formaldehyde in Furniture and Chlorinated Tris in Furniture. These are written in simple language. They explain how exposures may occur and then pose the question: “How can I reduce my exposure to formaldehyde gas or chlorinated Tris from furniture products?” For formaldehyde, the Fact Sheet recommends avoiding furniture made with urea-formaldehyde resins that does not have a California Air Resources Board (CARB) Phase 2 compliant label. But, two of the recommended mitigation techniques have not been proven and actually may be of little help. It is suggested that airing out furniture away from the home for a few days or applying a surface barrier (e.g., latex-based paints or formaldehyde-free varnishes) will reduce formaldehyde emissions. For chlorinated Tris, they recommend considering products with foam alternatives and looking for products with a TB 117-2013 label (Technical Bulletin 117-2013) as less likely to contain chlorinated Tris.
Additional Fact Sheets are posted by chemical. There are Fact Sheets for Bisphenol A (BPA) and four phthalate ester plasticizers, DEHP, DINP, DIDP and DBP. The BPA Fact Sheet primarily is aimed at foods and beverages that may come in contact with some types of metal food containers or drink caps, polycarbonate tableware or cookware, and older polycarbonate baby bottles. Thermal printer paper and dust are mentioned as other potential exposure sources. For the phthalates DEHP, DINP and DIDP, various types of plastic consumer products are mentioned as sources including flooring. For reducing exposures, OEHHA recommends avoiding plastics known as polyvinyl chloride (PVC) or vinyl (with recycle code 3). This ignores the fact that a number of manufacturers of PVC and vinyl products including flooring are no longer using Prop 65 listed phthalate esters. In addition, OEHHA has recently issued Safe Use Determinations for some flooring products containing DINP stating that they do not pose significant risk of exposure to this chemical. Unfortunately, these important distinctions regarding exposure are lost in the abbreviated Fact Sheets.
As a California laboratory with a long history of involvement with State agencies, Berkeley Analytical is highly experienced with the Prop 65 regulation. Our specialty is chemical analysis. We provide testing services to manufacturers in support of various Prop 65 exposure assessments:
- Bulk content testing of plastics for presence of phthalate esters and Tris flame retardants – Companies often use this testing to monitor their supply chains and to ensure that their products meet specifications for avoidance of listed chemicals.
- Surface wipe testing of plastics for migration of phthalate esters and Tris flame retardants – Since Prop 65 relates to exposures, not content, exposure assessments often need to measure potential migration due to dermal contact with surfaces.
- Chamber testing of products to assess air emissions of formaldehyde, styrene and other listed volatile organic chemicals – This testing is used to address potential inhalation exposures.
- Specialized studies in support of Safe Use Determinations.
Through Berkeley Analytical’s long involvement with Prop 65, we have developed a network of highly qualified professionals who can address a variety of Prop 65 questions. We collaborate on a regular basis with a number of toxicologists who are knowledgeable with Prop 65 exposure and risk assessments. One of the companies we collaborate with, Exponent, additionally specializes in assisting companies in developing Prop 65 strategies and compliance programs.
Please contact us directly for information and quotes regarding Berkeley Analytical’s Prop 65 services.