California’s Prop 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, regulates 970 chemicals that have been determined by the state of California to cause cancer, birth defects or other reproductive harm. Three of the most recent additions to the list are of particular interest to the industry, and PPAI has consulted with UL on how they should be approached in the short term.

Aloe Vera, Non-Decolorized Whole Leaf Extract and Goldenseal Root Powder were added to Prop 65 list in December 2015. As there is no maximum allowable dose level (MADL) or no significant risk levels (NSRL) for aloe, California currently has not established a safe harbor limit. It can be found in dietary supplements, skin products or items like facial tissue. In its review, UL states “Due to the fact that there is no safe harbor limit, it is suggested that labeling products that contain any amount of aloe would be the way to go. When aloe is more of a primary ingredient, it should be easier to identify in those formulated products where ingredients must be disclosed.”

Ethylene Glycol was added to the list in June 2015. There is no MADL or NSRL for ethylene glycol, and its many uses include serving as a reactant in the production of polyester fiber or resins, and as an antifreeze agent, where it can be found in snow globes and hand sanitizing gels. UL states, “The suggestion here is labeling products that contain this ingredient. Again, this would be easier to identify in formulated products where ingredients must be disclosed.”

Styrene was added to the list in April 2016. There is no MADL or NSRL for styrene, and while it is not polystyrene, it is used to make polystyrene. UL states, “It is unclear if there would be any exposure to styrene in finished polystyrene. If possible, the suggestion would be labeling polystyrene…just to be safe.”

The full Prop 65 list can be found here. More information on Prop 65 is available to PPAI members here.