Rubber Industry

ARPM Rubber Manufacturing Blog

The ARPM Rubber Manufacturing Blog allows members to rapidly communicate with each other. Post both questions and answers to questions that other ARPM members have about any industry topic from material and process issues to R&E Tax Credits and other business issues.

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Rubber Manufacturing Blog / Business / Prop 65 Labeling
Posted:  15 Mar 2018 16:05
Would like to have thoughts on Prop 65 labeling of products. Investigations into Prop 65 have led to the belief that most any product using components derived from a petroleum base is going to be noncompliant to Prop 65 regulations.  Testing would seem to be excessively time consuming and expensive. Would like to have feedback in regard to Prop 65 compliance and product labeling strategies for rubber products.  Thanks!
Posted:  15 Mar 2018 20:21
Without testing, an initial review could include an examination of SDS's from your raw materials components.  If the components contain language regarding to Prop 65 in section 15 of their SDS's, then you should likely have to include such on your SDS and labeling if shipping to California. 
Quick review...

Gregg Reinmann
Posted:  16 Mar 2018 21:40
Gregg, thanks for the reply.  As a chemist, what I am wanting to do is claim that exposure to individual chemicals in a vulcanized rubber product is very remote or nonexistent, and therefore avoid labeling.  I suppose Prop 65 doesn't care about the chemistry, they only want to know if a listed substance is a raw material in the recipe.  Is that how you are seeing it?  Thanks!

Kent Little
Posted:  16 Mar 2018 21:51
Hi Kent,
I understand exactly what you want and desire, and yes, for a finished product, you may have to test to support your document statement decisions.

Proposition 65 requires that the warning be “clear and reasonable,” but it does not state what constitutes a “clear” or “reasonable” warning, and does not state how the warning should be provided.  In the past, California’s Office of Environmental Health Hazard Assessment (“OEHHA”) promulgated regulations specifying rather generic warning language would be deemed “clear and reasonable.”  Those so-called “safe harbor” warnings are, therefore, at the heart of Proposition 65 compliance for many companies. 
For more information go to www.P65Warnings.ca.gov

Gregg Reinmann
Posted:  16 Mar 2018 22:27
Hi Gregg, thanks for the information.  This is a useful website.

Kent Little