Proposition 65: OEHHA Proposes Significant Changes to “Short-Form” Warnings – Update from Bergeson & Campbell, P.C.

On January 8, 2021, the California Office of Environmental Health Hazard Assessment (OEHHA) proposed significant revisions to its Proposition 65 (Prop 65) Article 6 “clear and reasonable warnings” regulations for “short-form” warnings.  When OEHHA’s revisions to the warning requirements were issued in 2016 (and in full effect as of August 30, 2018), OEHHA included a short-form warning option as an acceptable alternative to the revised requirements for consumer product exposure warnings.  Many use this option.  Its advantages include shorter language that can fit on a product’s label or packaging and the ability to provide a compliant warning without identifying at least one chemical listed under Prop 65 that triggers the warning, which is otherwise now a requirement for consumer product exposure warnings under OEHHA’s revised regulations. For more information, please read the full memorandum.


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