Dennis Raglin was quoted in a Chemical Watch article titled “California Agency Confirms BPS Prop 65 Warnings Needed for Packaging and Labels.” The article discusses recent confirmation that shipping labels, product stickers, and other items accompanying consumer goods are subject to Proposition 65 warning requirements for bisphenol S.
Raglin said that while it is too soon to say for certain, OEHHA’s letter could lead to more NOVs related to BPS in product stickers and labels. "Whether this ‘letter’ has the force and effect of an actual regulation is debatable," he said. "The effect, however, will be the same, as this alerts plaintiffs’ lawyers of targets beyond receipt paper."
Raglin suggested that companies examine their supply chains for the presence of BPS in other items listed in OEHHA’s letter, as well as in receipt paper. "Best practice — at least as far as California goes — is to ensure 200 parts per million or less BPS," he said, noting that under 200ppm paper is generally considered BPS-free.
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