California 65 test standard

    California Proposition 65 (Compulsory Act on Safe Drinking Water and Toxic Substances) was enacted in November 1986.

The purpose of the proposal:

    Protect California citizens and protect California's drinking water resources from known contamination with chemicals that cause cancer, birth defects, or other reproductive toxicities; inform California citizens about chemicals exposed to the items they buy, at home, or at work Or the release of chemicals that enter the environment. The proposal requires the government to publish at least once a year a chemical known to California that causes cancer or reproductive toxicity. More than 800 chemical substances have been announced.

The products covered by the proposal:

    Jewelry, toys, electrical installations, glass-ceramic materials, clothing, accessories, medicines, pesticides, dyes, cosmetics, gifts, manufacturing or construction supplies, by-products of chemical processes such as automobile exhaust, smoke, natural gas burning, etc., covering almost all products And list the exposure scenarios of dangerous goods.

The core requirements of the proposal:

    1) The hazardous substances listed in the proposal are not allowed to be discharged into the reference water.

    2) Provide clear and reasonable warnings (the substances listed must be warned unless the exposure is extremely low and will not pose a risk).

    Warning labels can be affixed to the product, placed in the workplace, at a retail store, or distributed notices, printed in newspapers and magazines, and generally recommended to be posted on the product. The main content of the label is to describe the lead in the product.

    1. California's 65 regulations for 

    “Phosphate-free” means phthalate DEHP (di(2-ethyl)hexyl phthalate), BBP (butyl benzyl phthalate) in a specific product. ), DBP (dibutyl phthalate), DIDP (diisobutyl phthalate), and DnHP (di-n-hexyl phthalate) each contained in an amount of not more than 0.1% (1,000 ppm). “Lead-free” means that in a particular product:

    (i) the lead content of the PVC component is less than 0.02% (200 ppm);

    (ii) Non-PVC parts accessible to lead have a lead content of less than 0.06% (600 ppm).

“Specific products” include:

    (i) "toys" designed for children under 6 years of age or, where appropriate, by children under 6 years of age;

    (ii) "Child Care Products" designed for children under 3 years of age or, where appropriate, for promoting sleep, relaxation, grooming, hygiene, feeding or assisting children under 3 years of age to suck or grind their teeth.

Note: Compliance with the US Consumer Product Safety Improvement Act (CPSIA) does not imply compliance with California Proposition 65 requirements. Proposition 65's requirements for phthalates include DnHP, which is not mentioned in the Consumer Product Safety Improvement Act. In addition, according to Proposition 65, the lead content of PVC parts shall not exceed 0.02% (200ppm), and the Consumer Product Safety Improvement Act, which will come into effect on February 10, 2009, requires a lead content limit of 0.06% (600ppm). ).

California 65 Problem Highlights:

   Q: What are the requirements for the California Proposition 65?

     A: The California 65 Proposal requires the Governor of California to issue a list of chemicals known to the State of California as known for carcinogens and/or reproductive toxicants. The list will be updated annually to identify chemicals that must be regulated by the law. As of February 2010, the list already contains more than 850 chemicals.

     The California Proposition 65 does not prohibit the sale of products containing any level of hazardous substances, but for products containing a listed list of chemicals and their levels of known hazard levels, the proposal requires that the product be labeled with the appropriate label.

     The California 65 Proposal applies to the following areas to control those harmful chemicals:

     • Drinking water discharge

    • exposed to the environment

     • exposed to the work environment

     • Consumer goods

     The California Proposition 65 requires companies that employ 10 or more employees to be “clear and reasonable” in the event that any employee will be exposed to chemicals listed in California under the Act and their weight is at an appreciable level. ("clear and reasonable warning"). The proposal also requires a warning slogan for products that may pose a potential risk to consumers. The warning is designed to allow consumers to make informed decisions about the purchase of products and services; and to allow others who are exposed to harmful chemicals to take actions they deem appropriate to protect themselves from exposure to harmful substances. hurt.

    Q: What is the “60-day violation notice” in the California Proposition 65?

     A: If the customer receives a notice of violation, he should contact his legal team. Clients can turn to a lawyer who is specifically responsible for the California 65 Proposal. If you need legal team help, there are a number of law firms on the market that are responsible for handling the California 65 Proposal. After the customer receives the 60-day notice, they should wait for the formal settlement agreement before updating the plan requirements or determining the solution. Since the relevant restrictions and requirements still have a chance to change before the final settlement agreement is reached, the customer should not stand before taking action to comply with the test guidelines.

    Q: What chemical categories are included in the list?

     A: The California 65 Proposal list contains two types of chemicals: carcinogens (drugs that cause cancer) and reproductive toxicants (substances that cause congenital or other reproductive harm). The list contains a wide range of chemicals, many of which are materials or ingredients for everyday household items such as ceramic containers, alcoholic beverages and aspirin. It also includes industrial chemicals, dyes or solvents used in dry cleaning, manufacturing or construction, such as benzene, cadmium, perchloroethylene and formaldehyde. There are still some by-products of certain combustion processes, such as automobile exhaust, aircraft exhaust, cigarette smoke and burning natural gas. As for lead, which is carcinogenic and reproductively toxic, it has always been one of the chemicals involved in litigation.

   Q: How can chemicals be included in the list?

     A: Chemicals classified as carcinogenic or reproductively toxic by the following US agencies will be included in the list: US Environmental Protection Agency (EPA); US Food and Drug Administration (FDA); National Institute of Occupational Safety and Health (NIOSH); National Toxicology Program (NTP) and International Agency for Research on Cancer (IARC). At the same time, if a US state or federal agency requires a chemical to be warned or classified as a carcinogenic or reproductive toxic substance, the chemical will also fall into the list. In addition, the Governor may appoint two independent teams of scientists and health experts to determine whether the chemical should be included in the list based on scientific evidence that adequately demonstrates carcinogenic and reproductive toxicity chemicals.

    Q: Should the customer test all the chemicals in the list?

     A: Although the safety harbor limits are related to each of the chemicals listed in the California Proposition 65 list, this restriction does not regulate the chemical content of a given product category. Therefore, we do not recommend testing more than 850 chemicals on the list. Bureau Veritas is designed to assist customers with tests that are subject to change, have restrictions and/or labeling requirements, and are specific to a particular product type to facilitate compliance.

    Q: When do you need to mark warnings under the control of the Proposal?

     A: When a company knows or ought to know that anyone has the opportunity to be exposed to a chemical that is defined as dangerous by law, it is required to mark the product on the product as required by the California Proposition 65. Even though the California 65 Proposal refers to a wide range of topics, not all hazardous substances trigger the notification and warning obligations required by the proposal. The warning requirements of the California Proposition 65 do not apply to the following:

     1. Any warning requirement relating to exposure to chemicals is to some extent governed by federal law and its power extends beyond the state government

     2. Any exposure to the chemical within 12 months after the chemical is first added to the list of governors; or

     3. Exposure to any known carcinogen, but “it is still doubtful whether it will cause significant risks if it is exposed to the substance for life,” or “exposure to the known reproductive toxicants in the state, but assume Whether it will not cause significant risks when exposed to one part of the relevant substances, it is still doubtful."

     4. Exposure to chemicals naturally present in food

     However, in the case of the California Proposition 65, the responsibility to verify any of the above exemptions falls on the defence and can be a difficult and expensive process.