Scribd
Upload
103 views4 pages

Intertek Proposition 65 Decision Tree

The document discusses California's Proposition 65 and Intertek's services to help companies comply. Proposition 65 requires warnings for significant exposures to chemicals known to cause cancer or birth defects. Intertek offers a compliance strategy including product assessment, testing, exposure analysis, and establishing safe harbor levels to determine if warnings are needed. The goal is to understand Proposition 65 requirements and provide solutions to verify compliance.

Uploaded by

jfffmlfd flkr
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
103 views4 pages

Intertek Proposition 65 Decision Tree

The document discusses California's Proposition 65 and Intertek's services to help companies comply. Proposition 65 requires warnings for significant exposures to chemicals known to cause cancer or birth defects. Intertek offers a compliance strategy including product assessment, testing, exposure analysis, and establishing safe harbor levels to determine if warnings are needed. The goal is to understand Proposition 65 requirements and provide solutions to verify compliance.

Uploaded by

jfffmlfd flkr
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
You are on page 1/ 4

Health, Environmental

& Regulatory Services

Proposition 65
Compliance Strategy
and Assistance
Your Regulatory Expert and Partner

The chemical right-to-know provisions of California’s Proposition 65 legislation, (otherwise known


as “Prop 65”, or the Safe Drinking Water and Toxic Enforcement Act of 1986), requires businesses
to warn Californians when there is significant exposure to a listed chemical present in the products
they purchase, or present in their homes, workplaces, or public spaces. The ‘Prop 65 List’ of
chemicals, which is maintained and updated at least yearly by California’s Environmental Protection
Agency (Cal/EPA), is intended to represent the list of chemicals known to the State of California to
cause cancer or birth defects or other reproductive harm.

The need for a Prop 65 warning is triggered when Step 1: Product Assessment and Risk Analysis
one or more of the listed chemicals is present in
Identify responsibilities associated with the product and
products, homes or workplaces, unless exposure
include a strategy that will assist in meeting the requirements
to the chemical(s) is low enough to pose no
specific to the determined responsibilities.
significant risk of cancer or birth defects or other
reproductive harm. To help businesses identify • Review Prop 65 list of chemicals
safe-haven opportunities where a Prop 65 warning
• Review product information
is not required, Cal/EPA’s Office of Environmental
Health Hazard Assessment (OEHHA) has established • Assess areas of risk for Prop 65 substances
“Safe Harbor Levels” for ~25% of the ~900
• Prepare proposal for client’s Prop 65 positional statement
Prop 65 chemicals. Specified in units of ‘microgram
of chemical per day’ (μg/day), the Safe Harbor • Prepare strategy guide and action plan for compliance
Levels reflect the “No Significant Risk Level” [NSRL]
for cancer-causing chemicals and the “Maximum
Allowable Dose Level” [MADL] for reproductive Step 2: Product Screening and Testing
toxins. For chemicals with no established Safe Based on the product assessment, conduct product screening
Harbor Level, OEHHA allows businesses to establish (XRF) or chemical testing.
their own NSRL /MADL safe harbors, as long as the
approach is scientifically sound and consistent with
OEHHA practices. When exposures are determined Step 3: Exposure Assessment and Safe Harbor Level
to be below the Safe Harbor Levels derived by Development (as necessary)
OEHHA, or below NSRL/MADL values derived by Assess the potential exposure to listed chemicals present in a
businesses, no Prop 65 warning is required. product and to derive NSRL/MADLs, if needed, to determine
To help businesses understand and comply with warning requirements.
Prop 65 requirements, Intertek offers a robust
and reliable portfolio of solutions.
California Proposition 65 Compliance Decision Tree

* It is technically difficult to verify 100% compliance with Prop 65 due to the potential presence of very low
levels (depending on detection limits) of, for example, residual chemicals or heavy metals, but the likelihood of
enforcement action in these scenarios is expected to be low.

Note: Having conducted and documented this due diligence effort, it does not mean that you will not
be targeted by lawyers (the only sure way is to have a Prop 65 warning), but this documentation
would support your efforts if you decide to defend yourself in court or to attempt to negotiate lower
settlements. Intertek is not a law firm but provides expert advice in relation to regulatory compliance
Intertek is a leading quality solutions provider to industries worldwide.
From auditing and inspection, to testing, training, advisory, quality
assurance and certification, Intertek adds value for its customers by
helping improve the quality and safety of their products, assets and
processes. With a network of more than 1,000 laboratories and offices
and over 38,000 people in more than 100 countries, Intertek supports
companies’ success in the global marketplace, by helping customers
to meet end users’ expectations for safety, sustainability, performance,
integrity and desirability in virtually any market worldwide.

For more information,


please contact us:

[email protected]

http://www.intertek.com/prop65/

You might also like