Proposition 65 - Substance Exposure During Manufacturing

Question:

My company needs to ensure that a material for an end-user product application is compliant with Proposition 65. My question is, do cured materials have to list all possibly harmful chemicals that are present in the un-cured state, or if there are no longer harmful properties in the cured material, can they be listed as compliant with Proposition 65?

Answer:

Proposition 65 looks at exposure levels of the final product not the product while being created. As long as the final product does not exceed the safe harbor levels for the substance(s) (levels vary by substance and are set by OEHHA) they are not required to provide a warning.

If there are any issues with exposure by employees being in contact with the substances, this should be covered by the California Division of Occupational Health and Safety (Cal/OSHA).


Reference: http://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=HSC&division=20.&title=&part=&chapter=6.6.&article

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