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Newly Listed Compounds: California Proposition 65 Legislation

Over the last six months or so, the California Office of Environmental Health Hazard Assessment (OEHHA) has been active in identifying and listing several new compounds to the Proposition 65 list. These compounds, their listing dates and their associated uses are summarized below.

Prop 65 Newly Listed Compounds

Date Listed: Sept. 13, 2019
Chemical: 2-Amino-4-chlorophenol
CAS No.: 95-85-2
Source: Hair dye, to color the hair
Type of Toxicity: Cancer
Safe Harbor (µg/day): N/A

Date Listed: June 28, 2019
Chemical: p-chlorobenzo-trifluoride
CAS No.: 98-56-6
Source: Solvent used in paints, inks and coatings and as an industrial intermediate in the production of other chemicals (e.g. dyes, herbicides, pharmaceuticals)
Type of Toxicity: Cancer
Safe Harbor (µg/day): 23 (proposed 18-Oct)

Date Listed: Sept. 13, 2019
Chemical: 2-Chloronitro-benzene
CAS No.: 88-73-3
Source: Intermediate in the synthesis of colorants (e.g. Fast Yellow G Base, Fast Red BB Base, Orange GC Base)
Type of Toxicity: Cancer
Safe Harbor (µg/day): N/A

Date Listed: Sept. 13, 2019
Chemical: 1,4-Dichloro-2-nitrobenzene
CAS No.: 89-61-2
Source: Used in the manufacture of dyestuff intermediates and as an intermediate for pigments, pesticides and UV absorbents in closed systems
Type of Toxicity: Cancer
Safe Harbor (µg/day): N/A

Date Listed: Sept. 13, 2019
Chemical: 2,4-Dichloro-1-nitrobenzene
CAS No.: 611-06-3
Source: Used as a chemical intermediate for the synthesis of chlormethoxyfen
Type of Toxicity: Cancer
Safe Harbor (µg/day): N/A

Date Listed: Sept. 13, 2019
Chemical: p-nitroanisole
CAS No.: 100-17-4
Source: Used in the manufacture of synthetic dyes used for cosmetics and other consumer products
Type of Toxicity: Cancer
Safe Harbor (µg/day): N/A

OEHHA has also been active in proposals and withdrawals of regulatory updates. Recent notable updates include:

(4-Oct-2019) Modification of text to the proposed amendment to 27 CCR 25600.2, consumer product exposure warnings

This modification includes clarification to 25600.2(b) and (c) to include notifications to a business to which a manufacturer, producer, distributor, etc. sells as opposed to the former language that specified direct notification to a retail seller that may not be applicable for upstream suppliers. In part 25600.2(h)(i), the modification specifies that agreements of liability may also be made between these parties as opposed to only the retail seller as was originally specified.

In addition, clarification of the acknowledgement of receipt of such notices was also modified (25600.2 (c)(1)& (2) so that authorized agents or legal agents to which the product is sold may acknowledge receipt.

(2-May-2019) Proposition 65 definition of nickel (soluble compound)

Soluble nickel compounds were listed for Proposition 65 on October 26t 2018 for developmental toxicity and male reproductive toxicity. This listing then introduces exposures via the skin and by ingestion to be in scope of Proposition 65 that were formerly considered out of scope where “nickel compounds” were historically of concern for inhalation exposure (e.g. cancer) only. Metallic nickel alloys were also interpreted through OEHHA guidance to be out of scope. The definition of soluble nickel compounds as those with solubility > 0.1 mol/L @ 20° C provides the guidance necessary for determination of applicability of the Proposition 65 listing.

Should any of these regulatory updates or newly listed compounds resonate with your product(s), feel free to reach out to NSF at We have internal and experienced analytical and risk assessment staff to support your Proposition 65 needs.

References used:

For the new chemicals the Prop 65 List:

For the regulatory updates:

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