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

Director Zeise, Dear Director Lauren Zeise The California Office of Environmental Health Hazard Assessment (OEHHA) has proposed significant revisions to Proposition 65’s short-form warning. The changes to the 2018 regulation are significant and will potentially impose substantial costs on companies selling products in California. The changes would restrict use of the short-form warning to product labels that are five square inches or less. It would require identification of at least one chemical associated with the product that is known to cause cancer and/or reproductive toxicity. Companies would be required to use the long-form warning on a website or in a catalog. The new rule will force my company to retool and reprint product labels, revise the website, update catalogs, and instruct distributors and retailers. OEHHA’s Prop 65 regulations are unique in the United States. The agency has created a de facto national standard. OEHHA should be more judicious in creating labeling obligations and legal exposures My company respectfully urges OEHHA to withdraw the proposed rule. Braden Liberg Director, Compliance and Calibration Engineering Edelbrock Group Braden Liberg