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OEHHA released Notice Second 15-Day Modification of Text for Proposed Amendment: Clear and Reasonable Warnings - Short Form

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As required by Government Code section 11346.8(c), and Title 1, section 44 of the California Code of Regulations, the Office of Environmental Health Hazard Assessment (OEHHA) is providing notice of changes to the proposed regulatory action to amend California Code of Regulations, Title 27, Sections[1] 25601, 25602, 25603, 25607.1, and 25607.2.  Also included in this notice is an addendum to the Initial Statement of Reasons.

Overview of Second Modification:

(*) The label size and package shape limitations on the use of the short-form warning were removed in Section 25602(a)(4). This modification means that the short form can be used on product labels of any size, regardless of package size and shape.

(*) The requirement in Section 25602(a)(4) that the font type size must be the same as the largest type size providing consumer information was removed. The existing provision requiring a minimum of 6-point type size when using short-form warnings remains unchanged.

(*) The proposed amendments were modified in Section 25602(a)(4) to reference the Section 25601(c) to make clear the existing requirement “to render the warning likely to be seen, read, and understood by an ordinary individual under customary conditions of purchase or use”.

(*) The language “exposes you to” in subsections 25603(b) and 25607.2(b) has been changed to “can expose you to” and thus in this regard conforms with the general content language in the general consumer safe harbor warning (Section 25603).

(*) The date that the regulation becomes operative has been modified to be two years rather than one year after the effective date of the amendments in Subsections 25602(e) and 25607.2(c). This allows additional time for business to implement changes to the short form. This is the same time period between the effective and operational dates as the 2016 major changes to the Article 6 safe harbor warning regulations.

(*) Minor changes were made for consistency across sections, and to correct a typographical error in the regulatory text.

Public consultation period: April 5, 2022 - April 20, 2022.

Check here for more information.


Xuechen Wang

Regulatory Manager at Chemycal

Antwerp, Belgium

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