(CLOSED) Comments on Original Proposal for Amendments to Regulations Clear and Reasonable Warnings, Safe Harbor Methods and Content California Code of Regulations

As a 10-year veteran of the US Consumer Product Safety Commission and from 22 years of independent consumer product toxicology consulting, I support the OEHHA proposal to identify the name(s) of the substance(s) requiring warning on the short and long forms. The names should be the same as used in the Prop.65 listing. The omission of an identifying name should never have been allowed and is an impediment to obtaining relevant information by the consumer. I support the proposed minimum 6-point type size. This would be consistent with the 16 CFR 1500.122 (c)(2) Table 1 recommendation for a minimum 3/64" for a statement of hazard on the smallest of labels. If 'point' is the desired unit rather than millimeter or inch, define the point as 1/72" (0.3528 mm) which is known as the 'desktop publishing point'.