State Regulatory Support: Proposition 65 Regulation
Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986,
requires California to list chemicals “known to the state” to cause cancer,
birth defects or other reproductive harm. Once a chemical is listed,
businesses must provide “clear and reasonable” warnings to those exposed in
California and are prohibited from discharging it into drinking water,
unless exposures are shown to be “insignificant.” The “significance” of
potential exposures is determined by comparing them to allowable exposure
levels, commonly called Safe Harbor Levels,
or more specifically, No Significant Risk Level (NSRL) for carcinogens, and
the Maximum Allowable Dose Level (MADL) for chemicals causing reproductive
harm.
With more than 20 years of experience dealing with the
intricacies of Proposition 65, TSG’s consultants provide a unique advantage
to companies dealing with a Proposition 65 issue. Our staff is experienced
in all aspects of Proposition 65 including:
▲ Coordinating efforts involving proposed addition of
compounds onto the
Prop 65 list or, once listed, efforts to
remove chemicals from the list
▲ Developing underlying documentation to
support an assessment
▲ Determining Safe Harbor Levels when a default level has not
been
established by California’s Office of
Environmental Health Hazard
Assessment (OEHHA)
▲ Providing guidance on the significance of exposures and follow-up
support,
as necessary
▲ Providing
pre-trial support for Prop
65 litigation
