California Proposition 65 Law – Compliance Reminder
As a business residing in the state of California and/or doing business with anyone residing within the State of
California, you need to understand that Proposition 65 (California’s “Safe Drinking Water and Toxic Enforcement
Act of 1986) makes it unlawful for a business with ten or more employees to expose a person in California to any of
850 different chemicals without giving “clear and reasonable warning.” For a complete listing of all of these
chemicals, please go to: http://oehha.ca.gov/prop65.html.
According to Proposition 65 and enforceable as of December 20, 2014, one of the raw materials commonly used in
the formulation of Disposable Vinyl Gloves (DINP) is on the list of chemicals known by the State of California to
“cause cancer or birth defects or other reproductive harm”.
While it had been our custom along with most other disposable glove manufacturers to use DINP in the production
of our Disposable Vinyl Gloves, we changed our formulations back in early Q3 2014 to produce DINP Free
Disposable Vinyl Gloves and all of the product we have brought into our stocks since the beginning of November of
2014 is in fact DINP Free.
While this is a great step on the path to our collective compliance with Prop 65 as it relates to Disposable Vinyl
Gloves, we must yet take another step to help you be in compliance as you ship our products to your customers on
and after December 20, 2014. In that you are required to comply with Prop 65 by either shipping DINP free
product beginning on 12/20 OR Appropriately Labeling any product you ship that still contains DINP, we want to
offer some guidance on what you need to do.
As we provide council, please take note of the attached list of items you need to concern yourself with in
connection to Vinyl Disposable Gloves and the 12/20 date (Attachment A).
In order to be most safe, we suggest that you treat all Impact Vinyl Disposable Gloves in your current inventory as
non-compliant with Prop 65 and therefor, affix a “Safe Harbor” label to each box within each case and to each
outer carton so that you will be in full compliance with Prop 65 for shipments to your California Customers on and
after 12/20/14.
Regarding these products on Attachment A, there are two ways to reach compliance with this law:
1. Begin giving warning to your customers on and after December 20, 2014 by applying a “Safe Harbor
Warning Label” to existing stock that contains DINP material for any affected item you ship.
Example of acceptable Label verbiage:
“WARNING: THIS PRODUCT CONTAINS A CHEMICAL KNOWN TO THE STATE OF CALIFORNIA TO CAUSE CANCER
AND REPRODUCTIVE OR DEVELOPMENTAL HARM.”
Impact Products will provide no charge labels for your existing inventory along with a label guide on where to place
the label. Please contact your Impact Customer Service Representative at 1-800-333-1541 with the quantity of
labels you would need in order to bring your existing inventory into compliance.
2. Ship Only DINP free materials.
Effective December 20, 2014 all disposable vinyl gloves shipped from Impact will be compliant with California
Prop. 65 Law by virtue of either proper Safe Harbor Labeling or by being DINP Free.
To order your Safe Harbor Labels, please contact Impact Customer Service at (800) 333-1541 or by email at
custserv@impact-products.com.
For more information on Prop 65: http://oehha.ca.gov/prop65.html
For more information regarding anything you have read to this point, please contact your Impact Sales Manager or
Todd Frendt (Impact Director of Quality) at tfrendt@impact-products.com.
As always, we thank you for your business and look forward to working thru all of this with you to the desired
outcome.
Sincerely,
Duane M. Carey, VP Sales
Attachment A: Affected Impact Stock Keeping Units
Attachment B: Prop 65 Plain Language PDF