Proposition 65 - Trace Lead in Alloys

Question: Some of our faucet products are made of brass. In these cases, a minimal amount of lead is used during the manufacturing process. The California Office of Environmental Health Hazard Assessment (OEHHA) lists safe harbor levels for four lead compounds. What are my requirements where these substances are concerned?

Furthermore, many installation guides with Proposition 65 warnings indicate to wash hands after installation. Would that also apply to faucet usage if lead levels are within/below threshold? Is the primary form of exposure considered oral in this case (breathing and ingesting lead particulates)?

Answer: The entry for “lead” on the OEHHA list is applicable to that used in brass alloy.

If lead exposure is below the risk (15 micrograms per day) and no observable effect (0.5 micrograms per day) levels, then the Proposition 65 warning is not required. Companies need to perform an exposure assessment in order to make this determination. The primary routes of exposure are dependent upon the product and its usage.

For example, if the shower faucet handles are made of brass containing lead, then the exposure could be through dermal absorption or ingestion via cross contamination. If the shower head itself is brass in contact with the water, then all routes of exposure would need to be considered.

Warnings to wash hands after installation are often occupational in nature and would not be applicable to consumer use. Only the safe harbor communication to installation companies is required in this case.

This content is accurate as of May 24, 2019.

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