Environmental Update
Proposition 65 List Update for 2019

Here is one more blog in support of knowing it is autumn even though the weather may not feel like it.  The Office of Environmental Health and Hazard Assessment (OEHHA) in California just published a revised list.  If you aren’t familiar with the OEHHA, you likely do know about California’s Proposition 65 list.  As per usual, the list has changed a few times over the course of the year. 

To refresh your memory, the Safe Drinking Water and Toxic Enforcement Act of 1986 is the official name for California’s Proposition 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 the implementation.  Chemicals are added or removed from the list when some other “authoritative body” makes a determination regarding a substances 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

March 2019

  • Bevacizumab for female developmental effect with CAS 216974-75-3
  • There were no chemicals delisted this month.

June 2019

  • para-Chlorobenzotrifluoride (PCBTF) for cancer with CAS 98-56-6
  • There were no chemicals delisted this month.

September 2019

  • 2-Amino-4-chlorophenol for cancer with CAS 95-85-2
  • 2-Chloronitrobenzenefor cancer with CAS 88-73-3
  • 1,4-Dichloro-2-nitrobenzene for cancer with CAS 89-61-2
  • 2,4-Dichloro-1-nitrobenzene for cancer with CAS 611-06-3
  • N,N-Dimethylacetamide for cancer with CAS 127-19-5
  • para-Nitroanisole for cancer with CAS 100-17-4
  • There were no chemicals delisted this month.

On a side note, glyphosate is still on the list.  This is the main ingredient in Roundup Weed Killer. It was listed because of a study published by the International Agency for Research on Cancer, however, there is a lot of discussion at the federal level.  The Environmental Protection Agency (EPA) will no longer approve labels under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) that indicate glyphosate causes cancer.  This is directly opposite from what is on the California Prop 65 list for glyphosate where it is listed as a cancer-causing agent.  It will be interesting to see how this all shakes out in the end.

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 September 13, 2019 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 by visiting ICC Compliance Center’s website or by calling one of our Regulatory Specialists today! USA: 888-442-9628 | Canada: 888-977-4834

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