CA Prop 65

Cal EPA Office of Environmental Health Hazard Assessment 11
Proposition 65 Clear and Reasonable Warnings
Questions and Answers for Businesses Revised - August 2017
If signage at a business or facility is in a language other than English, then an
environmental warning provided by that business or facility must be in that other
language in addition to English.
Q35: How can I access warning content in different languages – Spanish,
Chinese, French, etc.?
OEHHA has provided warnings translations for businesses on the Proposition 65
Warnings Website, including translations in Spanish, Chinese, French, Tagalog, Korean
and Vietnamese.
Q36: Is a product name considered “consumer information”?
No, a product name is not considered “consumer information” for purposes of
determining whether a language needs to be provided in a language other than English.
“Consumer information” includes warnings, directions for use, ingredient lists, and
nutritional information; it does not include the brand name, product name, company
name, location of manufacture, or product advertising (Section 25600.1(c)).
Environmental Exposure Warning Methods
Q37: If a business has determined that occupational exposure warnings are
required, and is providing Proposition 65 occupational warnings that are
compliant with the Article 6 safe harbor methods and content, does a business
also need to provide warnings to visitors for exposures to listed chemicals at the
facility?
If a business has determined that a visitor to the facility can be exposed to a listed
chemical at a level that requires a warning, then an additional Proposition 65 warning
for those exposures may be required. The methods and content for providing safe
harbor environmental warnings are located in Sections 25604 and 25605.
Q38: The “environmental exposure” definition states all exposures that are not
consumer product or occupational exposures are environmental exposures. It is
not clear what type of warning is required when there are combinations of
exposures. Are multiple types of warnings required when multiple types of
exposures are occurring?
Proposition 65 requires warnings for exposures to listed chemicals. When the
regulations were first adopted, exposures were divided into three general categories:
consumer product exposures, occupational exposures and environmental exposures.
These categories have worked well over the years. It is true that in some
circumstances warnings will need to be provided that do not fit neatly into a single
category. In that case, more than one warning may be provided for exposures to a
listed chemical in a given location. As an example, the regulations for amusement park