Comment Period - Notice Second 15-Day Modification to Proposed Amendments to Title 27, California Code Of Regulations - Short Form

Comment by: 
Mukesh Patel, Product Compliance Engineer, MULTIQUIP INC.
Received on: 
04/14/2022 - 8:21am
Comment: 
My concern is that the Prop 65 list of chemicals is dynamic, and chemicals are listed and de-listed therefrom over time. We as manufacturers cannot be aware of all constituent chemicals used in our products, considering the nature of the supply chain of our business. The proposed text now requires the naming of specific chemicals in our short form warning labels, and therefore it places a significant, and an undue burden on our business, requiring us to investigate the supply chain, and match the constituents of the materials used in manufacturing the products and their components, against the dynamic list of Proposition 65 chemicals. There is a significant cost of continually updating labels due to a dynamic list, and requires expert resources to manage it. This is one reason why the State of California gets a bad name, due to overbearing and confusing regulations.