Comment Submissions - Modification to Proposed Amendments to Regulations Clear and Reasonable Warnings, Safe Harbor Methods and Content California Code of Regulations

"I have had my products tested for Proposition 65 chemicals by reputable and well-known analytical laboratories, and they have consistently been found to be below the required limits or not detected at all. However, attorney groups often proceed with lawsuits based on simplified tests that can have significant errors. These groups then typically demand settlements, which forces manufacturers like me to hire lawyers and scientific experts to defend our case, incurring significant costs in the process. As a result, manufacturers continually suffer losses while the attorneys—both those filing the suits and those defending them—are the ones making money. Consequently, even when chemical levels are well below the required limits, manufacturers feel forced to include warning labels on all products to avoid litigation. Due to the impracticality of creating separate packaging for products sold outside California, these warning labels end up on products sold in other states as well. For consumers in other states who are not familiar with California's laws, products with these warnings may appear extremely hazardous. Ironically, California residents themselves largely ignore these warning labels and do not see them as helpful, contradicting the law’s intent. Instead of protecting manufacturers, this law merely focuses on warning label compliance, which I believe is short-sighted and ultimately results in a system where only the attorneys profit. Consequently, I feel strongly that simply amending the warning label requirements does not address the root of the problem, and California will continue to be a state where lawyers benefit at the expense of manufacturers."