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

Director Zeise, My company, Performance Forge, Inc. has relied on OEHHA’s 2018 regulation which provided the option of a short-form warning label. OEHHA is now forcing my company to retool and reprint product labels, revise our website, and re-train all of our customers This change is just going to create more exposure to claims by private enforcers about Prop 65 labeling errors. Not to mention, that this new law does nothing to improve the health and safety of the general public. Prop 65 offers an exemption for companies less than 10 employees. That is meaningless for most companies, including my own. Make the exemption at 100 employees, and it becomes meaningful. It is hard to understand how OEHHA could be threatening to impose unwarranted economic burdens during a pandemic. My company respectfully urges OEHHA to withdraw the proposed rule. Wayne Ramay