The proposal had contemplated clarifications to when short-form warnings should be used and had aimed to introduce new requirements for information about harmful chemicals. By Michael Romey, Christopher Martinez, and Lucas Quass Several amendments that the California Office of Environmental Health Hazard Assessment (OEHHA) had proposed to rules on short-form product warnings failed to move … Continue Reading
The proposal, which aims to clarify when short-form warnings should be used, would also create new requirements for information about harmful chemicals. By Michael G. Romey, Lucas I. Quass, and Kevin Homrighausen This article has been updated to reflect OEHHA’s decision to extend the public comment period on the Proposed Amendments from January 14, 2022 … Continue Reading
The new amendments seek to clarify the division of responsibility for providing warnings among upstream entities, intermediaries, and retailers. By: Michael G. Romey, Lucas I. Quass, and Kevin A. Homrighausen On April 1, 2020, new amendments to the implementation regulations of California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Prop 65 Regulations) will … Continue Reading
The prospect of facing bicoastal enforcement in two of the largest markets in the US could prove burdensome to businesses. By Kegan A. Brown, Michael G. Romey, James A. Erselius, and Lucas I. Quass On January 21, 2019, New York Governor Andrew M. Cuomo announced a proposal for the Consumer Right to Know Act — … Continue Reading
Online alcohol sellers should ensure compliance with the new Prop 65 warning label requirements. By Michael G. Romey, Lucas I. Quass, and James A. Erselius On August 30, 2018, new regulations governing the implementation of California’s Safe Drinking Water and Toxic Enforcement Act of 1986 (Prop 65) went into effect. The new regulations apply to … Continue Reading
Companies may need to carefully consider practical business concerns to comply with the updated Prop 65 regulations, effective August 30. By Michael G. Romey, Lucas I. Quass, and James A. Erselius New regulations governing the implementation of the Safe Drinking Water and Toxic Enforcement Act of 1986 (Prop 65) will go into effect on August … Continue Reading
Upcoming regulation will change substantive components of Prop 65 warnings. By Michael G. Romey and Lucas I. Quass As discussed in Part 1 of Latham’s previous posts, California’s Office of Environmental Health Hazard Assessment (OEHHA) will modify how the department implements the Safe Drinking Water and Toxic Enforcement Act of 1986, commonly known as Proposition … Continue Reading
Upstream entities will need to shoulder more responsibility in the warning process after August 30th. By Michael G. Romey and Lucas I. Quass As discussed in Latham’s previous post, August 30, 2018 will mark a significant change in the enforcement of the Safe Drinking Water and Toxic Enforcement Act of 1986, also known as Proposition … Continue Reading
Upcoming regulation will require online and catalog retailers to implement product warnings. By: Michael G. Romey and Lucas I. Quass Enforcement of the Safe Drinking Water and Toxic Enforcement Act of 1986, commonly known as Proposition 65 (Prop 65), will change significantly on August 30, 2018. Two years earlier, on August 30, 2016, California’s Office … Continue Reading