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Navigating California’s Proposition 65

​By Michael Sullivan

Little did Carla and Richard Kagel know when they met as undergraduate students that they would partner to create K Prime, Inc., one of California’s top chemical testing laboratories. The husband and wife pair shared their experiences helping clients navigate California’s Proposition 65 regulations at Product Stewardship 2018.

The couple provided a thorough review of how Proposition 65’s list of restricted substances—currently numbering nearly 1,000—is administered and what substances have been the focus of the majority of recent notices of violation. They addressed how most companies come to receive notices and how California’s limits differ from other jurisdictions.

These limits mean that manufacturers and testing laboratories have to create usage scenarios instead of just focusing on the chemical composition of products. Richard provided several details about how K Prime formulates their usage scenarios. He also shed light on the lengthy process to receive a safe use certification for products from the California Attorney General.

Major takeaways included the need to balance cost and risk and to develop reliable and legally defensible data in response. Carla and Richard also advocated that companies implement process controls and verify their standards were being met to head off potential notices.

The capacity ballroom prompted a joke from Richard that “Chemists don’t talk in front of large groups of people very often.” After the session’s formal question and answer period, the Kagels found themselves at the center of a knot of attendees with further queries.​

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