Proposition 65 - Painted Products and Exposure

Question Posed:

If a part with paint contains Proposition 65-listed substances (such as hexavalent chromium), but that is covered up and not exposed to an end-user, would it be considered in scope of Proposition 65?

Answer Provided:

In most cases where the foreseeable product use can result in a risk of exposure to Proposition 65 substances, a warning label would be required so the customer is aware of the carcinogenic and/or reproductive toxicity risks prior to purchase.

If a company can determine that the paint coating will prevent the customer from being exposed to hexavalent chromium contained within the metal part (so long as it is used under standard/foreseeable use parameters), this could provide an adequate basis to forego the application of a warning label.

If you believe one of the parts you procure may contain hexavalent chromium, but have been unable to get confirmation of this from the part supplier, there is a simple swab test that can be used to confirm this. Alternately, you can send the part into a testing laboratory for specific materials analysis.

**Article contents valid as of 2019-03-18

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