Cardno ChemRisk scientists keeping you up-to-date on Proposition 65

Cardno ChemRisk Proposition 65 Newsletter: October

Cardno ChemRisk offers scientific consulting services, specializing in using risk assessment methods to characterize and provide improved understanding of exposures involving chemicals in a range of products and scenarios. You can find a full list of our services and example projects on our Proposition 65 (Prop 65) qualification sheet.

Please join Cardno ChemRisk on October 13 as Dr. Ania Urban and Ms. Jennifer Bare discuss the role of risk assessment in Proposition 65. Register here.

Meet the Team

Addressing Worker Concerns about Product Proposition 65 Warnings 

Changes to the California Prop 65 rules effective in August 2018 have increased the frequency and number of warnings provided by product manufacturers or retailers. As a result, it is becoming more common for downstream worker or consumer product users to have questions about the warnings they see on products. Additionally, many users outside of California are unfamiliar with the purpose and meaning of the California regulation and may be noticing these increased warnings for the first time.

Employers, especially those located outside of California, are expected to be asked about safety and health concerns from workers using a product with a Prop 65 cancer or reproductive toxicity warning. Cardno ChemRisk scientists have developed approaches to help employers evaluate product warnings and potential chemical exposures to users. Our scientists have also developed risk communication strategies for employers to address these concerns and increase confidence in workplace health and safety.

Cardno ChemRisk Service Spotlight: Safe Harbor Level Derivations

Only a fraction of the hundreds of chemicals on the Prop 65 list have safe harbor levels (NSRL or MADL) established by OEHHA. The absence of safe harbor levels poses a challenge to businesses that perform risk assessments for warning exemptions or addressing notices of violation.

Cardno ChemRisk scientists Ms. Melissa Vincent and Ms. Lindsey Garnick recently published a derivation of an NSRL for 2-nitropropane, demonstrating how toxicological reviews and chemical dose-response assessments are used to establish defensible safe harbor levels. Our experts have derived safe harbor levels for several chemicals and exposure pathways consistent with the Prop 65 guidance specified by OEHHA.


Proposed Rule for Unintentionally Formed Chemicals in Foods

In August, OEHHA proposed to amend Title 27 of the California Code of Regulations by adopting Section 25505 covering Exposures to Listed Chemicals in Cooked or Heat Processed Foods. The proposed rule acknowledges that chemicals are unavoidably formed during the cooking or heat processing of foods, but can also be reduced using feasible best practices. OEHHA intends to establish levels of chemicals in foods that do not represent an exposure under Prop 65. While the proposed regulation addresses acrylamide only, Section 25505 may be expanded to include additional chemicals in the future. Cardno ChemRisk reviewed the proposed regulation and summarized key points in a recent blog.

BPA Eyewear SUD Blog

OEHHA issued a safe use determination (SUD) for dermal exposure to BPA in eyewear products. The agency described various analytical testing techniques used to estimate exposure potential, as well as reviewed the uncertainties associated with the assessment. Cardno ChemRisk reviewed and summarized the SUD in a recent blog.

September 60-Day Notice Trends

Despite the ongoing pandemic, 60-day notices continue to be filed with the California Office of Attorney General at a similar rate as in July and August. Consistent with months prior, a vast majority of the notices involved one or more phthalate, lead, or acrylamide. The trend of 60-day notices involving acrylamide in food shall be noted as the proposed Section 25505 proceeds through the amendment process, particularly if other chemicals in food come into the spotlight.


Contact Us

For more information regarding Cardno ChemRisk’s Proposition 65 capabilities, please contact Ania Urban, PhD, MPH or Jennifer Bare.
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