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Posted on behalf of Kailie Briza and Melinda Hoang.

On June 15, 2018, California’s Office of Environmental Health Hazard Assessment (OEHHA) proposed a regulation to exempt coffee products from carrying cancer warnings under Proposition 65 in the state of California (OEHHA 2018). As discussed in a previous blog, acrylamide is formed during the roasting and brewing process of coffee and was added to the Proposition 65 list of chemicals known to the State of California to cause cancer in 1990, after studies in laboratory rats and mice indicated that the chemical caused cancer (OEHHA 1990). Proposition 65 is a right-to-know law, requiring businesses to provide warnings when they knowingly cause exposures to chemicals that the state of California has listed as causing cancer or reproductive toxicity (OEHHA 2018). However, Proposition 65 does not require cancer warnings on products containing chemicals listed on Proposition 65, if the potential exposure through the product does not pose a significant cancer risk (OEHHA 2018).

In its proposed regulation, OEHHA determined that drinking coffee does not have a significant cancer risk associated with consumption (OEHHA 2018). However, it did not specifically address the potential health risks associated with the acrylamide content found in coffee. OEHHA noted that exposures to “chemicals [found] in coffee listed [on Prop 65] on or before 3/15[/2019] as known to cause cancer, that are created by and inherent in roasting coffee beans or brewing coffee, do not pose a significant cancer risk” (OEHHA 2018). OEHHA based its regulation on extensive scientific evidence that shows drinking coffee does not increase the risk of cancer, and may even reduce the risk of certain types of cancers (OEHHA 2018). On June 3, 2019, OEHHA confirmed on Twitter that its draft Proposition 65 regulation regarding carcinogens in coffee, including acrylamide, had been approved and finalized, and will become effective on October 1, 2019 (OEHHA 2018). A formal notice has yet to be published on OEHHA’s website.

The U.S. Food and Drug Administration (FDA) previously released a statement agreeing with OEHHA’s proposed regulation in 2018, suggesting that adding a warning label to coffee products would confuse consumers more than advise them, because the scientific literature supports that coffee consumption does not pose a significant risk of cancer (FDA 2018). Specifically, in 2016, the IARC re-evaluated coffee and concluded there was “no conclusive evidence for a carcinogenic effect of drinking coffee” (IARC 2016: p. 1-2). However, the IARC bulletin did not specifically indicate that acrylamide exposure from the consumption of coffee was non-carcinogenic. The bulletin concluded by stating that there was “inadequate evidence” to support carcinogenicity for drinking coffee overall (IARC 2016: p. 2). According to the IARC website, it indicated that acrylamide is classified as a Group 2A – probable carcinogen (IARC 2019).

Cardno ChemRisk assesses human exposure to many different chemicals that pose a potential health risk in consumer and personal care products. Our health scientists conduct in-depth exposure assessments and identify the health risks associated with various chemicals. To learn more about our capabilities or if you have any questions regarding this topic, please contact Jennifer Bare.