On Monday, NMMA submitted comments to the California Office of Environmental Health Hazard Assessment (OEHHA) — which recently announced proposed changes to California’s Proposition (Prop.) 65 short-form warning requirements.
If your company is using the short-form warnings to comply with Prop. 65 requirements, these proposed changes will likely affect your Prop. 65 compliance plan and NMMA encourages you to submit comments via Boating United by March 29, 2021.
In its comments, NMMA recommended that OEHHA withdraw its proposed changes to the short-form warning requirements in the absence of reasonable alternatives or a more targeted approach for marine products. California OEHHA’s proposal to the short-form warning requirements changes that would require any company using short-form warnings to revise their Prop 65 compliance plans, including labeling and marketing materials. More information about the proposed changes can be found here.
According to the comments, “Marine manufacturers and businesses have invested significant resources to overhaul their Proposition 65 compliance plans to ensure compliance with the new requirements that took effect only a few years ago in 2018. NMMA supports the continued use of the short-form warning, which currently provides a reasonable warning for recreational marine products that are sold in catalogs, online, and in marine retail stores.”
NMMA said it will continue to monitor the regulatory process and work with coalition partners to further highlight for California policymakers the logistical complexity and financial impact this would have on the marine industry and other industries.