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

Director Zeise, The small business I work for 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 the website, update catalogs, and instruct distributors and retailers. The proposed change has not been sufficiently justified and OEHHA has not acknowledged the costs being imposed. It is hard to understand how OEHHA could be threatening to impose unwarranted economic burdens during a pandemic. Prop 65 offers an exemption for companies less than 10 employees. That does nothing for the majority of small businesses in the automotive world who will always require more hands than that for an American manufacturing operation. Why are we trying to hurt American companies (esp manufacturing) in a time where we need them more than ever? James Kovac