The Cleaning Product Right To Know Act Of 2017: California's Newest Warning Requirements
In the fall of last year, California Governor Jerry Brown signed the Cleaning Product Right to Know Act of 2017 (the "CPRTKA"), adding provisions to the California Health and Safety Code commencing at § 108950 related to consumer safety, and to the California Labor Code at § 6398.5 related to worker safety.
The CPRTKA requires a manufacturer of a "designated product" sold in California to disclose on the product labeland post on the product's web sitea list of all intentionally added ingredients contained in any product included on a "designated list," and a list of all fragrance allergens included on specified regulations when present in the product at a concentration at or above 0.01 percent (100 ppm).
The CPRTKA requires employers to maintain a safety data sheet, and to ensure that those safety data sheets are available to an employee pursuant to the Occupational Safety and Health Standards Board. If any of the designated products are used in the workplace, the employer must make available certain information included in the online disclosures related to the chemicals in those designated products.
Although the title of the Act references "cleaning products," it specifically addresses fragrance ingredients. In addition, the law's definition of "designated product" applies to a much broader list of products, including air care products, automotive products, general cleaning products, and floor polish or floor maintenance products used primarily for janitorial, domestic, or institutional cleaning purposes. The CPRTKA also specifically identifies products not subject to the Act.
To protect confidential business information, the CPRTKA does not require a manufacturer to disclose how a product is manufactured or the weight or amount of an intentionally added ingredient, including a fragrance ingredient, or a...
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