California’s Proposition 65 has had far-reaching effects on a wide range of consumer products. Proposition 65 includes a list of over 900 chemicals, and a Proposition 65 complaint may be filed without any consideration of the amount of chemical in the product, or the degree of exposure from the product. Gradient has extensive experience with all aspects of Proposition 65 – from design of product testing to performing risk assessments and deriving Safe Harbor Levels. Our expertise in chemical exposure and risk assessment is often used to evaluate unique product exposures under Proposition 65.
Example Publication:
Boomhower, SR; Chien, J; Mattuck, R; Beck, BD. 2024. “Evaluating the potential for reproductive effects from intermittent lead exposures using blood lead modeling under Proposition 65.” Toxicologist 198(S1):119. Abstract 3054. Presented at the Society of Toxicology (SOT) 63rd Annual Meeting and ToxExpo, Salt Lake City, UT, March 10-14.
Evaluation of Food Products
In a Proposition 65 case, Gradient used blood lead modeling to quantify the impact of intermittent consumption of low levels of lead in juice and packaged fruit. The results were compared to the impact from the allowable lead intake under Proposition 65.
Evaluation of Coffee Consumption and Cancer
In a Proposition 65 case, Gradient provided technical analysis regarding the potential for coffee to cause cancer. We reviewed the epidemiological literature addressing coffee consumption and several types of cancer, focusing on meta-analyses of appropriate studies.
Chemical Exposures from Composite Wood Products
In a Proposition 65 case, Gradient used blood lead modeling to quantify the impact of intermittent consumption of low levels of lead in juice. Gradient compared several methods used for testing chemical emissions from composite-wood products, evaluating each method’s ability to address realistic exposure scenarios. We used emissions estimates and a US EPA indoor-air model to characterize the levels of consumer exposure from typical product use and determine compliance with Proposition 65 warning requirements.
Regulatory Comment for Nickel
Gradient evaluated the association between nickel exposure and reproductive and developmental effects, in response to the California Office of Environmental Health Hazard Assessment (CalOEHHA) consideration of listing nickel under Proposition 65.
