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California has listed vinylidene chloride under Proposition 65. The provision for clear and reasonable warnings will become effective on December 29, 2018.

SAFEGUARDS | Consumer Products NO. 013/18

Test tubes

California has listed vinylidene chloride under Proposition 65. The provision for clear and reasonable warnings will become effective on December 29, 2018.

California Proposition 65 (Prop 65 [1]) is the ‘Safe Drinking Water and Toxic Enforcement Act of 1986’, a ballot initiative passed overwhelmingly by California residents in November 1986. It requires the state to publish a list of chemicals [2] that are known to cause cancer, birth defects or reproductive harm. The list was first published in 1987 and has evolved to more than 800 chemicals.

On December 29, 2017, the Office of Environmental Health Hazard Assessment (OEHHA) announced [3] the inclusion of vinylidene chloride (1,1-dichloroethylene) in the list of chemicals under Prop 65. The listing of vinylidene chloride as a chemical known to cause cancer places two important provisions for companies doing business in California. These are:

  • Providing a clear and reasonable warning before knowingly and intentionally exposing anyone to this chemical. Businesses have 12 months to comply with this requirement

  • Prohibiting from knowingly discharging this chemical into sources of drinking water. Businesses have 20 months to comply with this requirement

Businesses with less than 10 employees and government agencies are exempt from these two provisions. Businesses are also exempt from these provisions if the exposures create no significant risk of cancer.

The provision for a clear and reasonable warning will become effective on December 29, 2018.

Highlights of the new listing of vinylidene chloride are summarized in Table 1.

Substance (CAS)
Date Listed
Toxicity
Effective Date
Vinylidene Chloride
(75-35-4)

December 29, 2017
Cancer
  • December 29, 2018 for a clear and reasonable warning
  • August 29, 2019 for prohibition from discharging into sources of drinking water

Table 1.

Vinylidene chloride has a variety of applications, including the manufacture of adhesives and polyvinylidene chloride copolymers. These chloride copolymers can be used in the manufacture of food packaging such as cling films and wraps, flame retardant coatings for fiber and carpet backings and piping, and coating for steel pipes.

The use of vinylidene chloride copolymers is regulated by the US FDA. For example, vinylidene chloride/methyl acrylate copolymers are specifically regulated under 21 CFR 177.1990 [4].

Throughout a global network of laboratories, SGS can offer comprehensive testing, product assessments and consultancy services related to California Proposition 65 to assist risk management in your supply chain for consumer goods such as DIY products, electrical and electronics, hardgoods, juvenile products, textiles and toys. For further information, please visit our website.

Next step:

Stakeholders are advised to ensure that their products comply with the requirements for vinylidene chloride under Prop 65.

For enquiries, please contact:

Hingwo Tsang
Global Information and Innovation Manager
t: +852 2774 7420

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