APA - The Engineered Wood Association

Regulatory Updates

Wood Dust and California Proposition 65 Labeling


About California Proposition 65

In 1986, California voters approved Proposition 65, an initiative which requires the State to publish a list of chemicals known to cause health issues such as cancer. This list has grown to include over 800 chemicals since it was first published. The California Office of Environmental Health Hazard Assessment (OEHHA) administers the Proposition 65 program and evaluates scientific information on substances considered for placement on the Proposition 65 list. In December of 2009, Wood Dust was listed as a substance known to cause cancer based on studies of inhaled wood dust. View the list of chemicals covered by Proposition 65.

Warning Required
Proposition 65 also requires businesses to notify Californians via a "clear and reasonable" warning of potential exposure if the product they sell contains these listed chemicals. This warning can be given by a variety of means, such as by labeling a consumer product or packaging, posting signs and/or distributing notices, etc. Guidance on clear and reasonable labeling is published under Title 27, California Code of Regulations, Article 6.

Compliance
Enforcement of Proposition 65 may occur via California Attorney General’s Office, local district or city attorneys or citizens that may file actions against a business that fails to provide a warning that a material contains listed chemicals. Manufacturers of wood products that may generate wood dust when they are sawn or machined are therefore taking actions to fulfill the Proposition 65 requirements of warning their California customers that the wood products may contain or generate wood dust. Since many wood products are sold through distribution and retail outlets, rather than directly to the California public, producers are also communicating the labeling requirements to their distribution customers with the expectation that they will fulfill their proper role of communicating the warning at point of sale. 

Options for Labeling
Wood product manufacturers may use different methods and language in their process of complying with Proposition 65 requirements. These warnings may be communicated through product literature, bundle labeling, signage examples for retail outlets, on bill of sales and other company communications to customers and distributors.  Since the method of compliance to Proposition 65 is a company decision, it is expected that there will be differences in the methods and language used.  Here is one example of labeling language:

WARNING: Drilling, sawing, sanding or machining wood products generates wood dust, a substance known to the State of California to cause cancer.

More about Proposition 65
California's Office of Environmental Health Hazard Assessment (OEHHA) administers the Proposition 65 program. More information is available from the OEHHA website.

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