Comment Submissions - Notice of Proposed Rulemaking: Amendments to Article 6, Clear and Reasonable Warnings Short-form Warnings

As a member of the archery industry and broader business community, I respectfully requests that the Proposed Rule making amending the short-form warning requirements under Article 6 be withdrawn. My concerns center around the fact that this proposal significantly modifies the Article 6 warning requirements that went into effect just two years ago. These changes go well beyond “clarification of existing law” and effectively repeal the Short-Form Warning requirements previously developed over an extended period of time with tremendous public input. In addition, these changes will exacerbate frivolous Prop 65 litigation which is significant and growing. Lastly, I believe that this proposal fails to analyze the economic impact of the proposed rule making to businesses and fails to consider reasonable alternatives. I thank you for the opportunity to submit comments regarding the Office of Environmental Health Hazard Assessment’s Notice of Proposed Rule making: Amendments to Article 6, Clear and Reasonable Warnings Short-form Warnings dated January 8, 2021 and again ask that this proposal be withdrawn.