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

Short-form Prop 65 warnings allow manufacturers and distributors to alert consumers of exposure to any number of chemicals when space limitations do not allow for the full list. It is a standard warning system that serves consumers and manufacturers/distributors well. The proposal to include at least one chemical on a short-form label creates an inconsistent, non-standard warning system without providing benefit to consumers. In fact, it creates an environment of misunderstanding that the product only contains the listed chemical, potentially exposing consumers to other chemicals without their knowledge and opening the door to future lawsuits and regulations updates. The proposed solution to force proof of the warning’s legitimacy creates more problems than benefits, in addition to the extra work and expense for manufacturers and distributors to make these updates.