Comment - 22029 - Topic 2 and former rulemaking

I understand that the requirement to identify chemical names in a Prop 65 warning has already been adopted and that businesses have until January 1, 2028, to fully transition to the new warning format. Given that context, I was hoping to better understand the policy rationale behind both requiring chemical identification and expanding the language to reference one or more chemical names. Many companies implemented precautionary warnings primarily to mitigate the risk of opportunistic litigation, even when they could substantiate that exposures were below established safe harbor levels. Because manufacturers often bear significant defense and settlement costs and have limited recourse to recover those costs, how does requiring the identification of one or more chemical names address the underlying issue that contributed to widespread precautionary labeling? Does OEHHA expect that requiring one or more chemical names will meaningfully reduce over-warning and improve consumer understanding, even if the litigation incentives that drove many of those warnings remain largely unchanged?