California Prop 65 Applies New Limits on 4,4’-MDA in Nylon Cooking Utensils

Proposition 65 is the ‘Safe Drinking Water and Toxic Enforcement Act of 1986,’ a ballot initiative passed overwhelmingly by California residents in 1986.

California Prop 65 Protecting Consumers for Over 28 Years

Since its enactment (1), there have been numerous lawsuits that resulted in the reduction of carcinogenic and reproductive chemicals by reformulations of consumer products containing such chemicals.

Prop 65 is now more than 28 years old and has been effective in reducing exposures to toxic chemicals. Of the 850 or so listed chemicals, consumer products containing lead, phthalates and flame retardants (2) have been consistently targeted over the years.

New 4,4’-MDA Limits Apply to Cooking Utensils

On January 1, 1988, 4,4’-methylenedianiline (4,4’-MDA) (http://oehha.ca.gov/prop65/prop65_list/files/P65single03272015.pdf) was listed as a chemical known to the state of California to cause cancer. Since January 1, 1989, businesses have been required to provide a ‘clear and reasonable warning’ (3) (Prop 65 warning label) before knowingly and intentionally exposing anyone to 4,4’-MDA. Even though the chemical has been listed for more than 25 years, until recently there had been no enforcement action for this listed chemical under Prop 65 in consumer products.

Since the beginning of 2015, two Prop 65 settlements have been reached for the reformulation of 4,4’-MDA in nylon cooking utensils. The parties in each of the 2 settlements agreed to reformulate 4,4’-MDA content to no more than 200 ppm.

Settlement on 4,4’-MDA CAS# 101-77-9

- Product: Nylon cooking utensils

- Method: EN 14362 or equivalent / GCMS

- Reformulation: below or equal to 200 ppm

References:

1) OEHHA, California Proposition 65 (http://oehha.ca.gov/prop65.html)

2) SGS SafeGuardS bulletin # 213/14 – December 2014 (http://newsletter.sgs.com/eNewsletterPro/uploadedimages/000006/sgs-safeguards-21314-cp-65-reformulation-chemicals-consumer-products-a4-en-14.pdf)

3) OEHHA, Proposition 658 in Plain Language! (http://oehha.ca.gov/prop65/background/p65plain.html)

About SGS Hardgoods Safety Services

Throughout its global network of laboratories, SGS is able to provide a range of services, including analytical testing and consultancy, for 4,4’-MDA in food contact nylon products (http://www.sgs.com/en/Consumer-Goods-Retail/Hardgoods/Home-Furnishings-and-Houseware/Testing/Food-Contact-Tests.aspx) for California and international markets.

Please do not hesitate to contact an SGS expert for further information.

Contact details:

SGS Consumer Testing Services

HingWo Tsang
Global Toys and Juvenile Products Information and Innovation Manager
SGS Hong Kong Limited
1/F On Wui Centre
25 Lok Yip Road
Fanling, N.T., Hong Kong, China

t: +852 2774 7420
Email: [email protected]
Website: www.sgs.com/hardgoods

SGS is the world’s leading inspection, verification, testing and certification company. SGS is recognized as the global benchmark for quality and integrity. With more than 80,000 employees, SGS operates a network of over 1,650 offices and laboratories around the world.