Further to our previous blog that discussed OEHHA’s proposed changes to how concentration levels are to be calculated between lots of products from different manufacturing sites and averaging calculations for reproductive toxins, OEHHA has published an update that it will not be proceeding with the proposed changes. This will be a welcomed decision by […]
Proposition 65 Exposure/Averaging Changes – Update Read More »
Proposition 65 Enforcement California Proposition 65 is a unique regulation that brings separate compliance requirements from all other regulations in the US (or abroad) and is enforced through civil litigation (via issuance of a Notice of Violation, or “NOV”). At the beginning of each month we take a quick look at an enforcement summary for
Proposition 65 Enforcement Summary: June 2019 Read More »
Proposition 65 NOV Summary (May) – usual issues with phthalates and heavy metals; – significant uptick in food products being targeted for acrylamide (month over month); – out of the ordinary = leather gloves being targeted for hexavalent chromium (6 NOVs in last 2 months) It’s a shame so many companies get tangled up with
Prop 65 NOV Summary: May 2019 Read More »
The method for calculating consumer exposure to Proposition 65-listed chemicals that are reproductive toxins is undergoing a proposed change in response to a landmark 2015 court case (Environmental Law Foundation [ELF] vs. Beech-Nut Nutrition Corp). In this case the State of California affirmed a lower court’s ruling that food companies may average exposures over time
Proposition 65 Exposure Evaluations and Averaging Read More »
Here is the California Proposition 65 NOV summary for April. Slight uptick from last month overall, but the key takeaway is that food companies need to pay attention regarding acrylamide (double the NOV from last month). Companies also need to watch for more PFOA targets. If you have questions about California Prop 65 compliance, contact
Prop 65 NOV Summary: April 2019 Read More »
Proposition 65 NOV Enforcement Summary for 2018 California Proposition 65 is enforced through civil litigation through the issuance of a Notice of Violation (NOV) by an enforcing party to a company whose product(s) are allegedly not in compliance with this statute. We wrote about the potential costs of receiving an NOV here. Each year the
Prop 65: Annual NOV Summary (2018) Read More »
NOV Summary – Enforcement Trends for March 2019 As mentioned in our previous post, alcohol retailers were especially targeted in the last few months and that trend continued in March. An interesting uptick we noted is food products being targeted for furfuryl alcohol, a chemical naturally produced during cooking (similar to acrylamide). It does not
Prop 65 NOV Summary: March 2019 Read More »
Proposition 65 and the Supplements Industry Dietary supplements are used by millions of consumers every day to assist in improving their health. The vast majority of companies producing supplement products go to great lengths to ensure the products are wholesome and safe. Yet in 2018, the number of companies/products targeted for alleged non-compliance under California
Why are Supplements Frequently Targeted with Costly NOV? Read More »
The usual products/chemicals being targeted last month. One interesting change is the large increase in NOVs issued to online alcohol retailers (39 in just one month). Hesitating to address your Prop 65 compliance can mean being targeted and not having a leg to stand on => very costly mistakes! Reach out to RegTox today to
Prop 65 NOV Summary: February Read More »
A quick summary of the NOVs that were issued in January is found below. The usual targets for phthalates and heavy metals. Acrylamide also continues to be a target in a handful of NOVs. If you have questions or need assistance in determining your Prop 65 compliance, please reach out to our experts. You certainly
Prop 65 NOV Summary: January 2019 Read More »