Home Cosmetic Science Talk Formulating Prop 65 in CA

  • Prop 65 in CA

    Posted by Chemist5000 on July 9, 2018 at 4:48 pm

    Just trying to prepare for the future… I know that Lipowax P ( Cetearyl Alcohol (and) Polysorbate 60) is suppose to contain Prop 65 components.  What would be a decent replacement that wouldn’t flag Prop 65.  It is being used in an OTC cream.

    Chemist5000 replied 6 years, 2 months ago 3 Members · 10 Replies
  • 10 Replies
  • Gunther

    Member
    July 9, 2018 at 8:17 pm

    Cetearyl alcohol and Polysorbate 60 ain’t in Prop 65 list
    https://oehha.ca.gov/media/downloads/proposition-65//p65list052518.pdf

  • Chemist5000

    Member
    July 10, 2018 at 3:12 pm

    I got a letter from the vendor confirming the material may contain trace quantities of Prop 65 chemicals.  

    @Gunther
    Can you offer an alternative?

  • Microformulation

    Member
    July 10, 2018 at 3:32 pm
    Polysorbate 60 is an ethoxylated compound which in the past did contain concerning levels of 1,4 Dioxane, a compound we now classify as a carcinogen. However, if you consult with a regulatory person, Prop 65 has a low permissible of 1,4 Dioxane. (Remember, it is the dose that makes the poison). New processing of these materials has greatly reduced the levels. If you look at a CofA for these materials, they quantify the level of 1,4 Dioxane with it generally being in the parts per million.
    I have some experience in this. Several clients over the years have called in a tizzy. In the end, we simply had to provide documentation showing the 1,4 Dioxane levels were below the permissible thresholds.
  • Chemist5000

    Member
    July 11, 2018 at 3:33 pm

    @Microformulation
    Thank you for the information.  I hope you don’t mind me picking your brain a little more about the subject.  I was trying to find out the permissible thresholds were.  I have been told that even at “trace” ppm amounts you would still have to put the warning label on your products.  I haven’t been able to confirm this. So is there a limit before you have to add the warning label?

  • Microformulation

    Member
    July 11, 2018 at 3:42 pm
    @Chemist5000 I am going to give you a better answer. The State of California has a number I call with questions and I have to admit that they are helpful. I found it with a few simple google searches but I don’t have it in front of me right now.
    Honestly dealing with VOC Testing was more of a burden than Prop 65.
  • Microformulation

    Member
    July 11, 2018 at 3:43 pm
    Questions about Proposition 65? Check our Frequently asked Questions page or contact the Proposition 65 office: (916) 445-6900 or email P65.Questions@oehha.ca.gov (link sends e-mail).

  • Chemist5000

    Member
    July 11, 2018 at 4:08 pm

    @Microformulation
    Thank you for the information. I do appreciate this!!!

  • Chemist5000

    Member
    July 11, 2018 at 4:50 pm

    @Microformulation
    I sent an email and got the most bland of replies in 3 paragraphs.. they tell me to examine Article 7 and Article 8 of Title 27, California Code of Regulations for safe harbors.  Since my questioned is based on concentration they really stayed away from any sort of ranges.   :s :s :s :/ :/  

  • Microformulation

    Member
    July 11, 2018 at 4:52 pm

    I disregarded the emails and called. Once you get through the phone maze, you will get someone who will help. A real person.

  • Chemist5000

    Member
    September 14, 2018 at 5:43 pm

    @Microformulation

    how do you explain that at trace amounts well below 1 PPM of Prop 65 chemicals (0.005 PPM perhaps) do not present a significant exposure or health risk to a regulatory person?

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