On June 28, 2019, the California Office of Environmental Health Hazard Assessment (OEHHA) added PCBTF (p-chlorotrifluorotoluene) to the list of hazardous substances in California Proposition 65 due to its carcinogenicity.

There are now more than 970 substances in California's 65 hazardous substance list, which is updated at least once a year, with four substances added in 2018 and two substances added so far in 2019.

Product Name:p-chloro-α,α,α-trifluorotoluene (para-Chlorobenzotrifluoride, PCBTF)

CAS Number: /

Toxicological properties: carcinogenic

Main uses: Solvents for paints, inks and coatings, as well as industrial intermediates for the production of other chemicals such as herbicides, dyes, pharmaceuticals.

California 65 list updated to nearly 1,000 substances, how to meet California 65 control requirements? Ten questions and ten answers for you!

Product Name: Proposition 65 Abbreviated as CA65

·Chinese name: United States California's proposal to increase concerns about accessible toxic chemicals

·Chinese Explanation: The 1986 Guidelines for Safe Citations of Water and Toxic Substances Prohibitions, the California Safe Drinking Water and Toxic Enforcement Act of 1986. Codified in Chapters 25249.5~25249.13 of the California Health and Safety Code.

· Effective date: November 1986

(1) It is forbidden to cite water pollution:

No person shall, in the course of business, knowingly discharge or release into a water source or release into or to land or land that is likely to contaminate a water source in the course of its operations.

(2) Warning requirements:

Any business (exempt for businesses with no more than 9 employees) must warn the public before "knowing and intending" to expose the population to a listed substance. The OEHHA has issued safe harbor levels (i.e., exposure levels that trigger alert requirements) for some of the substances on the LIST.

When the substance exposure is greater than this level, the company should provide a California 65 alert. Once a chemical substance is listed, manufacturers and distributors are required to complete the warning within one year and stop discharging the chemical into drinking water sources within 20 months. After this date, government or individual law enforcers, including individuals or organizations acting on behalf of the public interest, may file a lawsuit against those who violate the statute.

Warning requirements must be "clear and reasonable" and can take many forms. When a chemical substance is listed, the company must complete the warning requirement within 12 months.

First published in 1987, California's 65 Control List is updated at least annually and includes more than 970 substances.

No, California Proposition 65 does not set limits for listed substances in a class of products, and because the concentration of a substance is not a unique factor in determining whether or not an exposure risk is present, the limit is not sufficient to determine whether a warning is warranted.

Yes, it applies to all consumer products sold in the California market, whether adult or children's.

Yes, but since there are currently nearly 1,000 substances on the list, it is not practical to test them all, and conducting supply chain surveys is an effective means of control. If it is not possible to conduct a supply chain investigation, CTI recommends that companies find corresponding cases based on their own products, investigate the hazardous substance content of their own products, and determine whether they meet the requirements of the hazardous substance limit in litigation. If the limit value in the case is exceeded, it is recommended that the enterprise affix a warning sign. If there are no relevant cases, it is recommended to control substances with a higher risk of litigation.

Lead, cadmium, phthalate is the three types of substances that have been the most litigated in previous cases, in addition, it is recommended that enterprises pay attention to bisphenol A at the same time, although there are few cases of bisphenol A in electronic and electrical products, but the degree of attention is high, and the current few litigation cases are mainly due to the fact that bisphenol A is a substance that has been included in the list of hazardous substances for 15 years.

California 65 does not have such an exemption, and there have been cases of copper alloy products that have been reported in the past to contain high levels of lead, and CTI recommends that companies put a warning label on it.

According to the regulations, the main party responsible for providing warnings on products is the manufacturer, producer, packer, importer, supplier or distributor of the product.

Warning method:

· Detailed warnings identifying the product on the indication label, shelf tag or shelf sign of each product display or placement.

· Detailed warnings displayed by electronic devices shall be automatically displayed before purchase by the purchaser without the purchaser looking for the warning.

· The warning content on the label should include: warning symbol, warning word, "WARNING" and appropriate warning information.

· The short warning on the label should comply with the regulations including: warning symbol, warning word, "WARNING" and appropriate short warning information.

Warnings:

Yes, if the company does not use yellow for other information printed on the label, the company can print the warning symbol in black and white.

If a product contains five chemicals that trigger a warning, and all five substances are carcinogens, the company is only required to list the name of any one of the five substances in the warning.

If exposure to carcinogens and reproductive toxicants is present, the company will need to list one carcinogen and one reproductive toxicity name, but the company may also choose to provide additional substance names in the warning.

If there is a substance that is both carcinogenic and toxic to reproduction, the warning only needs to show the name of the substance, but it needs to reflect both carcinogenicity and reproductive toxicity, and the company can also choose to include more chemical names in the warning.