Encyclopedia Brown and the Case of the Missing Prop 65 Statement

I received a call the other day from one of our customers. He was agitated, perturbed, incensed…he was not a happy camper. The conversation went something like this:

Unhappy Camper: “Hey, Regulatory Goober!”

Me: “Uh, that’s ‘Guru.’”

Unhappy Camper: “Whatever. Hey, that last Safety Data Sheet (SDS) I asked for and you sent me… it didn’t have a Proposition 65 (Prop 65) statement on it!”

I dug up the e-mail chain in question, reviewed the SDS, and said:

Me: “Yup. You’re right. It ain’t there.” (My powers of perception are top-notch.)

Unhappy Camper: “But the last material we bought from you had Prop 65 on the SDS!”

Me: “Ah…that’s because the producer doesn’t have to put this information in the document.”

Unhappy Camper: “Wait… what?!? I don’t understand.”

You see, the Global Harmonized System (GHS) dictates what’s included on a Safety Data Sheet. It specifies that an SDS must be a 16-section document, containing specific information. Every country that has adopted GHS has made minor tweaks to this information, adding certain verbiage here or not adopting a pictogram for a particular potential danger there. (In other words, so much for “global” and “harmonized” – but that’s a blog rant for another day.)

The producer of a resin has to include this basic information in its SDS. However, it can elect to add more than what is required – and often, this includes a Prop 65 declaration in Section 15, “Regulatory Information.” More often than not, this is provided as a courtesy; a Prop 65 declaration is not required per the GHS rules. Also, since items are added to (and, less frequently, removed from) the Prop 65 list, it can be difficult for a producer to constantly issue an updated SDS just because Prop 65 changed.

Finally, the SDS is not – and was never designed to be – the one-stop shop for all things regulatory. Producers have other documents that serve these purposes and should be considered the definitive source for this information. If an SDS does include things like Prop 65 or any other regulatory statement, that’s at the discretion of the producer.

If you request an SDS, that’s what you will receive, without expectation that any additional items will be covered. However, if you request a Prop 65 statement, there’s a decent chance you may receive the SDS with guidance to refer to Section 15.

In the end, I was able to send our customer the documents he needed, and – at least until the next e-mail arrived or my phone would ring – balance and harmony was restored to the universe. All in all, it was a pleasurable 26 seconds.

 – Authored by Christopher Thelen, Regulatory Specialist

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