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by Chelsea Lane

The California Office of Administrative Law approved amendments to the California Code of Regulation (CCR) Article 6, Clear and Reasonable Warnings section on August 30, 2016.  The changes to this section will require businesses that sell products in California to provide more detail on their labels.

The following are some general requirements that are to be included on the new labels:

  • Putting the word “WARNING” in all capital letters and in bold print;
  • Including a symbol of a black exclamation point in a yellow equilateral triangle with a bold black outline;
  • Using specific phrases (found in §25603) for carcinogens, reproductive toxicants, reproductive toxicants, and combinations of these;
  • Using phrases which differentiate between food products, alcoholic beverages, consumer products, environmental exposure, and others which are listed in Subarticle 2;
  • Specifying at least one chemical requiring the warning;
  • Including the following URL address for further information:

In addition, several new sections (Sections 25607.5 - 25607.6 and 25607.8 - 25607.31) have been added and include details about more specific instances of exposure such as exposure though dental care, furniture, raw wood, diesel engines, vehicles, enclosed parking facilities and more.  These sections make it clear the generic Proposition 65 label that was once acceptable will need to be replaced with a custom-made warning, dependent on the product’s category.

The new warning requirements will take effect on August 30, 2018.


California Office of Environmental Health Hazard Assessment (OEHHA), Proposition 65, Article 6, full text:

California OEHHA, Side-by-Side Comparison of "current" versus "new" text of Article 6:


September, 23, 2016

European Member States vote to harmonise poison centre submissions for chemical products

EU Member States have voted in favour of the European Commission’s proposals to harmonise how chemical companies will submit product information to poison centres in Europe

EU legislation requires all Member States to set up an appointed body to receive information in the case of poisonings. However, it is up to individual Member States to interpret this law, meaning the demands on companies handling hazardous goods can vary widely across Europe. This often leads to a costly administrative burden for companies, which also risk fines or product removal in cases of noncompliance.

The Commission’s eagerly awaited amendments, which were first published as a draft for consultation in February 2016, include a number of changes intended to harmonise companies’ submissions of chemical information to poison centres. This includes the introduction of a new uniform product identifier on product packaging to make it quicker and easier to identify a product once it is registered with a poison centre. The new regulation will come into force for mixtures intended for consumer use in 2020 and for professional and industrial mixtures as of 2021 and 2024 respectively.

Caroline Raine, principal consultant at the UK’s National Chemical Emergency Centre, said: “The Commission’s amendments will significantly change the requirements for companies’ product submissions to Member State poison centres. The changes will have the potential to accelerate submissions while reducing the huge variation in current poison centre compliance. However, it is important to remember that these changes will not be introduced for a minimum of four years, meaning companies still face the risk of fines or product removal for not complying with the specific legislation in the individual EU countries that they operate in. Over the next few weeks we will be working closely with chemical companies around the world to interpret what these updates mean for their businesses, while supporting them to achieve short term compliance.”

NCEC's regulatory experts support companies across the world in overcoming the complex requirements of poison centre registration. It also provides a poison centre compliance pack covering the various regulatory demands in each country in Europe. Available as both a free download and a more comprehensive report, the pack provides clear, concise and easily applicable information for chemical companies to quickly identify their international obligations and avoid the risk of legal and financial repercussions from non-compliance. Download the poison centre resources at

It is also important for companies selling products globally to understand the wider regulatory requirements for countries in other regions, particularly Asia and South America. NCEC’s global emergency response guide highlights the regulations outside of Europe that require compliance for those transporting or supplying chemicals and is free to download here

For more information on how the new amends will impact your business or the current challenges of EU poison centre product registration, contact Caroline Raine at

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By John J. Kowalski, CHMM

The U.S. Environmental Protection Agency (EPA) has amended the Chemical Data Reporting (CDR) regulations under Section 8(a) of the Toxic Substances Control Act (TSCA) to extend the 2016 submission deadline from September 30, 2016 to October 31, 2016.  Jim Jones, EPA’s Assistant Administrator for Chemical Safety and Pollution Prevention, signed the final rule on September 16, 2016.  It will take effect upon publication in the Federal Register.  In the meantime, a link to a pre-publication version of the rule has been posted on EPA’s Chemical Data Reporting Homepage.