Cardno ChemRisk Proposition 65 Newsletter: September

Cardno ChemRisk offers scientific consulting services, specializing in using risk assessment methods to characterize and provide improved understanding of exposures involving chemicals in a range of products and scenarios. You can find a full list of our services and example projects on our Proposition 65 (Prop 65) qualification sheet.

 Cardno ChemRisk Welcomes Dr. Annette Santamaria, PhD, MPH, DABT

Cardno ChemRisk is pleased to welcome Dr. Annette Santamaria, PhD, MPH, DABT to our Houston office. Dr. Santamaria is a board-certified toxicologist with more than 30 years of multidisciplinary consulting experience critically evaluating and integrating information from toxicological, epidemiological, and clinical studies to provide scientific interpretation and recommendations. In particular, Dr. Santamaria has performed numerous consumer product safety assessments in accordance with Proposition 65 and other US, European and Canadian product regulations as well as addressed product liability and regulatory matters regarding exposure to compounds in consumer products. For more information about Dr. Santamaria’s background and research, please find her profile here on our website.

 Updates Regarding Consumer Product Warnings for Glyphosate

On July 23, 2021, the Office of Environmental Health Hazard  Assessment (OEHHA) proposed adopting new safe harbor warning language tailored for exposure to glyphosate in consumer products. OEHHA currently lists glyphosate as cancer-causing based on IARC’s prior determination as “probably carcinogenic to humans” and has derived an NSRL of 1,100 µg/day. The proposed regulation allows for the use of the words “Notice” or “Attention” on product labels substituted for the use of the word “Warning,” which conforms with the safe harbor warning content for other pesticides.  An additional proposed option for tailored warning language includes reference to the “variety of factors” which may affect an individual’s risk for cancer, including exposure level and duration of exposure as well as reference to methods for reducing exposure (Figure 1 below). The public comment period on the proposed rulemaking will close on October 7, 2021.

Figure 1. OEHHA's Proposed Language for Tailored Glyphosate Product Warnings


Cardno ChemRisk Service Spotlight: Food Safety Services

Many consumer products are subject to scrutiny under Prop 65 depending upon their chemical constituents, which may also require a warning label. However, a variety of toxicological and exposure-specific considerations as part of a risk assessment may justify labeling exemptions and provide manufacturers with a more holistic understanding of any potential risks associated with use of their products by a consumer. While Prop 65 is a hazard-based regulation, risk assessment may help consumer product manufacturers proactively identify potential chemical constituents of concern, anticipate any risks that may be associated with use, and inform their approach to compliance with Prop 65 regulatory statutes.

Cardno ChemRisk scientists have extensive experience in assisting clients with food safety services and risk assessments. Particularly, Cardno ChemRisk scientists are well equipped to assist clients through all phases of exposure and risk assessment, from product testing to risk communication to end users.  Our experts have assisted clients with assessing risk associated with a variety of products, compounds and exposure pathways for Prop 65 compliance. We’ve addressed issues such as phthalates in processed cheese, dioxane in wine, mercury in corn syrup, benzene in beverages, chromium in drinking water, and microbial agents in dietary supplements. With involvement in regulatory panels, leading industry discussions, and preparing regulatory guidelines, our scientists are well-equipped to respond to food safety crises.  For inquiries or more information about such risk assessment capabilities, please contact Ms. Neva Jacobs , MSPH, CIH, and Dr. Christopher Bates, PhD, DABT.

 60 Day Notices for PFASs

An increasing number of consumer products have been issued 60-day notices for PFASs under Prop 65. Such chemicals have been detected in numerous cosmetic products such as mascaras, foundations, and lipsticks. While this issue was addressed through the introduction of the “No PFAS in Cosmetics Act” to the U.S. Senate in June of 2021, the Toxic-Free Cosmetic Act will additionally take effect in January of 2025. For more information about PFAS in cosmetic products, please explore this blog written by scientists Kathleen Chen and Eric Russman. To understand our experience and capabilities within our consumer products focus area, please visit our website or reach out to Dr. Ernest Fung and Dr. Marisa Kreider.

 Balancing Safety and Efficacy with THC

As cannabis use and manufacturing has become more widespread with legalization, government agencies continue to develop new health and safety policies. Back in March of 2021, OEHHA proposed adopting tailored safe harbor warnings for cannabis and THC smoke exposures. Such exposures result from products that are intended to be smoked, vaped, dabbed, ingested, applied dermally, or result from permitted smoking, vaping or dabbing areas. This proposition aims to provide businesses with combined warnings for both cannabis and THC.  More recently, governments have also started imposing caps on the concentration of THC in flower and concentrate products, as well. For more information on such regulatory updates, visit our July blog post written by Cardno ChemRisk scientists Dr. Heidi O'Neill and Alex Hazell. For further inquiries about our cannabis practice and capabilities within this industry, please contact Elise de Gandiaga or Dr. Heidi O'Neill.

 Cardno ChemRisk Scientists Publish a Derived Prop 65 NSRL for 2-nitropropane

The Journal of Applied Toxicology published a recent Cardno ChemRisk research article proposing no significant risk levels for 2-nitropropane and a screening safety assessment for 2-nitropropane in spray products. Cardno ChemRisk scientists Lindsey Garnick, Dr. Andy Maier, and Melissa Vincent performed this study focusing on the inhalation exposures to 2-nitropropane. To learn more about this specific study, please visit this blog.

Meet the authors:


Claire Mathis, MPH

 Catie Park


Please visit the Proposition 65 section of our website to learn more about our services!

For more information regarding Cardno ChemRisk’s Proposition 65 capabilities, please contact Ania Urban, PhD, MPH or Claire Mathis, MPH.