Comment Period - Notice of Modification to Text of Proposed Regulation Title 27, California Code of Regulations Proposed Amendments to Article 6 Clear and Reasonable Warnings – Short Form

While the Society of Glass and Ceramic Decorated Products (SGCDpro) recognizes the agency’s response to company concerns over label size (by increasing the total square inches from 5 to 12), and allowing duplicative language to appear in catalogs and websites, we continue to have concerns about the overall change in language for what appears to be the sake of semantics. The juxtaposition of the words “risk of cancer” and “cancer risk” is a costly exercise which, in our opinion, creates no further clarification. The agency enacted new rules just two years ago and manufacturers and suppliers complied at great expense. The expectation that these entities now replicate this effort and expense, while juggling major changes to our nation’s supply chain, seems punitive and disingenuous. Society members have long respected their (and the Society’s) relationship with public regulators at the local, state, and federal level. Decades ago, SGCDpro led the effort to reduce heavy metals in glass and ceramic decorated products. Our manufacturers and suppliers are dedicated to bringing safe, environmentally friendly products to market.