California Proposition 65 BPA Warning Label Requirement Services

Intertek works with manufacturers to develop programs for compliance with Bisphenol A (BPA) requirements for the Canada, France and U.S. markets, and can also partner with you to develop risk mitigation strategies for the California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Prop 65).

Last year, the California Office of Environmental Health Hazard Assessment (OEHHA) added Bisphenol A (BPA1) to the list of chemicals known to the state of California to cause reproductive toxicity. As a result, the deadline for compliance with warning label requirements is right around the corner – beginning May 11, 2016, companies with 10 or more employees manufacturing, distributing or selling product(s) containing BPA where the exposure to BPA is over the “safe harbor level” will be required to provide a clear and reasonable warning for that product under Prop 65 warning label requirements.


The OEHHA also recently proposed 3 micrograms/day2 as a maximum allowable dosage level (MADL) for dermal exposure from solid materials. If finalized, exposure above this MADL from solid material will require a clear and reasonable warning. Additionally, because OEHHA has not published a safe harbor level for the oral route of exposure, companies will need to derive on oral MADL for BPA to determine whether warnings would be required for their products. The alternative is to remove BPA from any products or use a Prop 65 warning.

BPA is commonly found in polycarbonate, epoxy resins, thermal printing paper and certain other materials. If you use any of these materials, they carry a higher risk of containing BPA and being subject to enforcement if exposure is above the safe harbor level.

Intertek’s global lab network performs risk-based assessments and analytical testing as per international method to parts per billion (ppb) levels. Following analytical testing of products, Intertek can also conduct exposure assessments to evaluate whether Proposition 65 warning is required, as well as to derive an MADL for oral BPA exposure.

Contact Intertek today to discuss your Prop 65 BPA analytical testing or exposure assessment needs.

 

1http://www.oehha.org/prop65/CRNR_notices/list_changes/051115listBPA.html
2http://www.oehha.ca.gov/prop65/CRNR_notices/NPR_BPA_MADL031716.html

 
 

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