Stainless Steel and CA Prop. 65
Stainless Steel and CA Prop. 65
(OP)
Back in the 80's when prop. 65 passed in CA, my company did not want to take any risks and we placed a cancer warning label on all of our products. Now, we've run out of space on the packaging for our stainless steel/carbon steel products and they've asked the materials engineers to assess these products for adherence to Prop 65. Both Nickel and Hexavalent chromium are present on the list of unsafe chemicals. The law states that "you should determine whether the manufacture or use of the product is likely to expose individuals to listed chemicals." Personally I think it's ridiculous that we need to put this label on each box of bolts that we manufacture. Does anyone have any experience with this, the internet has not been too helpful. It's my understanding that in normal every day handling of a stainless steel bolt, a person should not come into contact with nickel or hexavalent chromium. The chromium (III) oxide layer should protect leaching of these chemicals. I would also have to look at whether these chemicals could be leached into the water supply...
Any thoughts?
Any thoughts?





RE: Stainless Steel and CA Prop. 65
Regards,
Mike
RE: Stainless Steel and CA Prop. 65
RE: Stainless Steel and CA Prop. 65
http://www.gadsl.org/
and General Motors standard GMW3059 Restricted and Reportable Substances for Parts:
http://www.allisontransmission.com/servlet/Downloa...
Nickel is classified as Declarable when present above 0.1 %. Hexavalent chromium has a more complex set of limits, but you likely do not have a leachable form on the surface of stainless steel so you probably can drop that from the lable. Review the test methods identified in these documents - you may need to conduct the testing once on your products to confirm compliance.
RE: Stainless Steel and CA Prop. 65
Regardless, I doubt stainless steel bolts would be high on anyone's list of targeted products. Proposition 65 is enforced by "bounty hunters", for example any Calif. citizen can bring a lawsuit if they can demonstrate exposure to a listed chemical from a consumer product. So there is no guarantee under any circumstance that you will not be sued, anyone can sue, but by doing some level of analysis, you can much more easily fend off a potential lawsuit.
For more certainty, one could conduct an exposure evaluation, if the exposure is below the NSRL or 1x10-5 risk, then no warning is required. An exposure evaluation is somewhat costly (a few thousand $ up to perhaps $10K), but it would likely apply to all products handled similarly to a bolt, so most all nuts, washers, hangers, etc. would be covered by the same analysis.
Hope that helps.
RE: Stainless Steel and CA Prop. 65
RE: Stainless Steel and CA Prop. 65
RE: Stainless Steel and CA Prop. 65
Feel free.
RE: Stainless Steel and CA Prop. 65
RE: Stainless Steel and CA Prop. 65