Prop 65 And FBA FAQs BY MARY DRAIN
Board Converting NEWS INTERNET DIRECTORY
What do I need to know about Prop 65 (the CA Safe Drink- ing Water and Toxic Enforcement Act of 1986)? The answer to this, one of many frequently asked technical questions (FAQs) on the Fibre Box Association (FBA) website, is pro- vided below and digitally to FBA members. FBA’s FAQs are a collection of questions and answers, researched and written by FBA’s environmental, safety & health and tech- nical experts on a variety of technical questions important to the corrugated industry. Proposition 65 is a California state law under the Safe Drinking Water and Toxic Enforcement Act of 1986. It was developed to protect California’s drinking water sources from contamination by the approximately 900 chemicals currently named in the law, and to inform citizens about ex- posures to these chemicals. The list is required by law to be updated at least annually. The law prohibits discharg- ing known carcinogens or reproductive toxins into poten- tial drinking water sources. The statute also prohibits ex- posing any person to these substances without providing a warning. The CA Office of Environmental Health Hazard Assess- ment (OEHHA) developed safe harbor levels for almost 300 of the listed chemicals. Exposure levels and discharg- es to drinking water sources that are below the safe har- bor levels are exempt from the requirements of Proposi- tion 65; there can be no liability for failure to provide a warning. Safe harbor levels are No Significant Risk Levels (NSRLs) for carcinogens and/or Maximum Allowable Dose Levels (MADLs) for reproductive toxins. NSRL means ex- posure to the safe harbor amount of the chemical in a product would result in no more than one cancer case in every 100,000 individuals exposed to the chemical over a lifetime, 70 years. MADLs are 1000 times less than the lev- el at which a chemical would have no observable effect. For chemicals without a safe harbor level, manufactur- ers who do not wish to provide warnings must establish the NSRL and/or MADL. However, if a plaintiff can demon- strate exposure to any amount of a listed chemical from a product with no warning, the burden falls on the manufac- turer to prove the validity of the safe harbor level(s), and that the amount of exposure is less. For details, see the mysterious world of Prop 65, part 8: Acceptable risk levels. Advanced compliance by keeping up with chemicals listed and added to Proposition 65 and their presence in the materials and chemicals in your products can be the key to avoiding a lawsuit or legal fees and settlement payments for non-compliance. Ensure Safety Data Sheets (SDSs) and other HazCom/GHS (Globally Harmonized Sys- tem) documentation is current and compliant, as well as assessing or reviewing product exposure levels for listed chemicals. CONTINUED ON PAGE 36
OHIO BLOW PIPE/ADVANCED AIRSYSTEMS www.obpairsystems.com For 85 years the Ohio Blow Pipe company and its whol- ly owned subsidiary, Advanced Airsystems, have provided the corrugated and folding carton industries with systems and products to process scrap. We engineer, fabricate, in- stall, service, provide system audits, and offer a wide range of scrap systems, dust collection systems and products to include cyclones, under roof AIR-SCREEN™ systems, pit belt systems, CLEANAIR dust collectors, Mist-Clone™ dust control systems for vacuum feeds, material handling fans, ductwork, switch valves, airveyors, balers, shredders and OM Partners makes paper makers and packaging compa- nies more profitable and more efficient by optimizing their operations. By utilizing mathematical solvers and advanced technology, corrugated producers remark that their corru- gators and converting equipment run faster with less waste and higher on time delivery achievement within weeks after implementation. The OMP System consists of a comprehen- sive and fully integrated set of modules for order promising, forecasting, capacity planning, stock management, corru- gator optimization, production scheduling, transport plan- ning and automatic data collection. dust briquetters. OM PARTNERS www.ompartners.com/corrugated
PAPER AND DUST PROS, INC. www.paperanddustpros.com
We custom design, install and service air conveyed scrap and dust collection systems. Our unique APS® is smaller, lighter, and more reliable than current cyclones. Contact us to learn how the APS® System can enhance your operation.
PROFERO SYSTEMS, INC. www.ProferoSystems.com
Profero Systems the leader in double facer heating and traction section conversions along with other performance enhancing products. Featuring products from Contact Bars and Compensating Rolls to New Glue Machines and Double Facers.
GF PUHL www.gfpuhl.com
GF PUHL designs, manufactures and installs air conveyed scrap & dust collection systems for the packaging and cor- rugated industries. With 36 years of experience, USA and International. Re-manufactured balers, filters, blowers and shredders available.
August 31, 2020
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