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

The Association of Equipment Manufacturers (AEM) appreciates the opportunity to comment on the proposed amendment to Proposition 65. AEM is the U.S.-based trade association representing the off-road equipment industry. Our over 1,000 member companies are involved in the manufacturer of products and services used world-wide in the agricultural, construction, forestry, mining and utility sectors. We at AEM applaud OEHHA for the new language guidance on the short form. It is concise, to the point, and includes identified chemicals. Because this is so succinct, to the point and will grab people’s attention we are asking to be able to utilize this messaging format on all points of contact including, Internet, Catalog and Labels on articles larger than the 5” size limit. We fully support the initiative to put warnings that have specific chemicals and hazards on them in front of consumers. We think that can be done very effectively by utilizing the language format provided for the new short form label: Warning: Risk of Cancer From (Chemical Name) and Reproductive Harm From (Chemical Name) Exposure – www.P65Warnings.ca.gov. We believe that a consistent application of this Warning format across the Internet, Catalogs and all products / articles would provide the increased awareness prior to purchase that is the ultimate goal of all of us. AEM appreciates your consideration in allowing the proposed Short form message format to be used across all articles regardless of size, the internet, and catalogs as we strive to meet the requirements so the public can understand potential exposure risks prior to purchase.