Skip to main content
Second Update to California Prop 65 Short-form Warning Proposed Amendment
Compliance & Regulatory NewsEnvironmental Health & Safety

Second Update to California Prop 65 Short-form Warning Proposed Amendment

By  Veronica Marrero, Regulatory Compliance Specialist

Earlier this year, we informed you of an announcement the California Office of Environmental Health Hazard Assessment (OEHHA) made on December 13, 2021 about changes made to the text of the proposed amendment to short-form warnings (Article 6 Clear and Reasonable Warnings of the California Code of Regulations, Title 27). 

On April 5, 2022, OEHHA published a second modification to the text of the proposed amendment.

Below is a summary of the new changes to the proposed amendment:

  • Consumer Product Exposure Warnings – Methods of Transmission (§ 25602):
    • The maximum label size for short-form warnings was that was previously changed from 5 square inches to 12 square inches is now completely removed. There is no longer a maximum label size for short-form warnings; short-form warnings can now be used on labels of any size.
  • Consumer Product Exposure Warnings – Content (§ 25603 (b)) and Food Exposure Warnings – Content (§ 25607.2 (b)):
  • he warning statement content (or wording format) were updated once again. The wording “exposes you to” for the statements listed below has been changed to “can expose you to.” These new wording formats are outlined below.
    • For exposures to listed carcinogens:
      • Can expose you to [name of chemical], a carcinogen
    • For exposures to listed reproductive toxicants:
      • Can expose you to [name of chemical], a reproductive toxicant
    • For exposures to both listed carcinogens and reproductive toxicants:
      • Can expose you to [name of chemical], a carcinogen, and [name of chemical], a reproductive toxicant
    • For exposures to a chemical that is listed as both a carcinogen and a reproductive toxicant:
      • Can expose you to [name of chemical], a carcinogen and reproductive toxicant

Timeline for amended regulation to go be in force is now two years (rather than one year) after the effective date of the amendments [see § 25602(e) and § 25607.2(c)].

This notice by OEHHA initiated a public comment period from December 17, 2021 to January 21, 2022. The public comment forum can be found here.

TotalSDS will consistently monitor for final rulemakings and effective dates to ensure we are maintaining the most up to date criteria in our TotalSDS Authoring software. For more information on how this may affect your company, get in touch.

We're Here to Solve Your Compliance Needs

Schedule a Demo
“

“Just having the peace of mind that the SDSs are secure, we can access them whenever, wherever we need to, and that they are going to be current at all times without me having to spend hours Google searching and making sure that I've got the latest and greatest. TotalSDS™ Manager has been incredibly helpful and efficient, saving me at least 10 hours every month—time that I can now invest in achieving more strategic HR goals, making the software invaluable to our operations.”

Margie SleigherDirector of Human Resources, Caldwell Electrical Contractors
“

“Because we’ve done business together for so many years, I’ve really appreciated having a trusted partner. I’ve been able to rely on TotalSDS’s expertise and say, here's what I want; here’s what I need. Help me get there. ..... Adding the QR code feature, for us, has really transformed the process of quickly getting safety information. Being able to immediately access that critical information in the field has made all the difference. It's just amazing!”

Matt RehlanderCorporate Director of EHS & Risk Management
“

“The level of customer service provided surpasses all of my expectations. TotalSDS is a responsive team of regulatory experts that clearly place their client’s needs at the highest priority. The team responds to us with answers in hours rather than weeks with our old service. The software provides a level of customization and control that was not available with our previous GHS software. Additionally, TotalSDS isn’t afraid to take our feedback into consideration to continue to improve their product. Our organization appreciates the cloud-based service and the unique levels of access for each user.”

Chris GehlyChemical Services Manager
“

“The ease with getting everyone up to speed on the system was impressive. It was a smooth transition. The software is very intuitive. What I appreciate most is the excellent support I receive from the TotalSDS team. Any questions or concerns I have are addressed immediately with a simple phone call.”

Lenny FrancisEHS Specialist
“

“The TotalSDS software system is a good tool for our company to create compliant SDS and labels for multiple countries and languages. We are able to create customized documents catering to each business needs. The software is user-friendly and new users can start generating SDS with minimal training.”

Tammy CardHazard Communication Specialist
“

“The TotalSDS™ platform does everything it says it can do. There are no surprises. What is advertised is exactly what you get. The customer support is outstanding! TotalSDS has been available to help with any kind of regulatory or software question I have, and they are extremely responsive. And more than that, the software capabilities are consistently getting better as they are adding more and more features.”

Greg SwitzerProduct/Formulation Chemist
“

“TotalSDS™ Author has been instrumental in managing our SDS documents efficiently. The flexibility to edit and customize our safety data sheets to meet specific regulatory requirements is invaluable. It’s intuitive, time-saving, and essential for keeping up with the ever-changing regulatory landscape.”

Mark PolaskyChemical Regulatory Compliance Manager