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New CA Prop 65 Requirements

For those of you doing business in California, have you seen this symbol?


New CA Prop 65 Icon

Beginning August 2018, you will begin seeing this symbol everywhere in California with the implementation of the new Prop 65 warning labels. Proposition 65 (California’s Safe Drinking Water and Toxic Enforcement Act of 1986) was implemented as a so-called right-to-know statute that requires everyone in the chain of commerce to ensure that California consumers receive “clear and reasonable” warnings prior to being exposed to a growing list of chemicals—now numbering more than 900. In 2018, California’s Office of Environmental Health Hazard Assessment (OEHHA) has defined “clear and reasonable” to include the above warning symbol. You’ll notice the difference.


New Prop 65 Label Requirements

To see the latest 900 cancer or reproductive compounds on the list, visit here:
oehha.ca.gov/media/downloads/crnr/p65single07072017.pdf

Having worked in the crop protection industry for many years, I recognize many of the compounds. However, one of the compounds on the list was surprising to me:

Marijuana smoke:
p65warnings.ca.gov/fact-sheets/marijuana-smoke

With the changes coming to the cannabis business in January, I wonder how this warning will affect labeling prerolls, etc. in California.

Or aspirin:
oehha.ca.gov/proposition-65/chemicals/aspirin

A list of all the published fact sheets on each compound are here:
p65warnings.ca.gov/fact-sheets

Also interesting to me, the new Prop 65 labeling requires specific font size for the warning; no smaller than 6 point font and/or no smaller than the largest font for consumer information on the label. For more specific answers to questions, see this link:
oehha.ca.gov/media/downloads/crnr/art6businessqa.pdf

You may say this new Prop 65 warning does not apply to us as our company does not sell directly to consumers. In this situation, the manufacturer of a product that contains a compound on the list must notify their customers of the requirement. Given the notification requirement, I don’t know if they’ll decide to place the warning on their labels as well. That’s a question for the regulatory experts inside each company.

For our customers already meeting the requirements for GHS labels, printing this new warning symbol on-demand and in color will not be any big deal. On our blog, colorlabelsondemand.blogspot.com, we have 59 different posts covering GHS. One of my favorite post covering GHS labels involved NIC Industries: colorlabelsondemand.blogspot.com/2016/06/c7500g-whiz.

And Engineered Lubricants:
colorlabelsondemand.blogspot.com/2015/01/ghs-needs-erin.

If you need assistance printing labels for products covered by Prop 65 and/or GHS contact us. We can help you print color labels on-demand.


Posted at 5:33 AM
Guy Mikel
855-962-7670
info@colorlabelsolutions.com

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