California Prop 65

What is California State Proposition 65?

California Prop 65, purebond, hardwood plywoodAccording to the Office of Environmental Health Hazard Assessment, Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, was enacted as a ballet initiative in November 1986. The Proposition was intended by its authors to protect California citizens and the State’s drinking water sources from chemicals known to cause cancer, birth defects or other reproductive harm, and to inform citizens about exposures to such chemicals. Proposition 65 requires the Governor to publish, at least annually, a list of chemicals known to the state to cause cancer or reproductive toxicity. On December 18, 2009, wood dust was added to the list of substances “known to the State of California to cause cancer.” Once a substance is listed, businesses have 12 months to comply with the warning requirements. According to California Health and Safety Code Section 25249.6, as of December 18, 2010, no person in the course of doing business shall knowingly and intentionally expose an individual to wood dust without first providing a clear and reasonable warning. The warning requirement applies to any person employing ten or more employees who manufactures, produces, sells, distributes, or otherwise transfers a wood product into the stream of commerce in California. For more information on Proposition 65, go to https://www.osha.gov/SLTC/etools/eyeandface/ppe/selection.html.

Why is the wood products industry concerned with California State Proposition 65?

Starting December 18, 2010, California Proposition 65 now requires manufacturers, distributors, and sellers of wood products in California to provide the following clear and reasonable warning about wood dust to California consumers. The warning states: “WARNING: Drilling, sawing, sanding, or machining wood products generates wood dust, a substance known to the State of California to cause cancer. Avoid inhaling wood dust or use a dust mask or other safeguards for personal protection.”
The objective of Proposition 65′s wood dust warning requirements is to see that the wood dust warning is transmitted to the end user of the product that might be cut, drilled, sanded or otherwise machined in some manner. Retailers should display this warning at the point of sale, checkout counter and/or where the wood products are displayed so that it is likely to be seen and read by the purchaser of the wood products. For your convenience a warning sign with approved statement is available for download here in Acrobat PDF format. In addition, retailers should include this warning on invoices or shipping papers so that customers who order wood products by phone, by fax, by email or over the internet are provided this warning in appropriate manner as required by Proposition 65. Distributors who do not sell wood products directly to the public should provide a copy of these warning signs along with a letter to all of their retail customers in California to inform them of their duties under Proposition 65, and must make reasonable efforts to ensure that retailers are properly posting the warning sign. For more information on impacts of Prop 65 to industry, check this link from the Hardwood Plywood and Veneer Association.

How does wood dust affect personal health?

OSHA, Occupational Safety and Health Administration, says “Wood dust becomes a potential health problem when wood particles from processes such as sanding and cutting become airborne. Breathing these particles may cause allergic respiratory symptoms, mucosal and non-allergic respiratory symptoms, and cancer.” NIOSH, the National Institute For Safety and Health, states “Workers exposed to wood dusts have experienced a variety of adverse health effects such as eye and skin irritation, allergy, reduced lung function, asthma, and nasal cancer. Therefore, the National Institute for Occupational Safety and Health* (NIOSH) recommends limiting wood dust exposures to prevent these health problems.”

Personal Protection Information

Employers should institute a complete respiratory protection program that, at a minimum, complies with the requirements of OSHA’s Respiratory Protection Standard [29 CFR 1910.134]. Such a program must include respirator selection, an evaluation of the worker’s ability to perform the work while wearing a respirator, the regular training of personnel, respirator fit testing, periodic workplace monitoring, and regular respirator maintenance, inspection, and cleaning. The implementation of an adequate respiratory protection program (including selection of the correct respirator) requires that a knowledgeable person be in charge of the program and that the program be evaluated regularly. For additional information on the selection and use of respirators and on the medical screening of respirator users, consult the latest edition of the NIOSH Respirator Decision Logic [NIOSH 1987b] and the NIOSH Guide to Industrial Respiratory Protection [NIOSH 1987a].

Personal Protective Equipment

Workers should use appropriate personal protective clothing and equipment that must be carefully selected, used, and maintained to be effective in preventing skin contact with wood dust. The selection of the appropriate personal protective equipment (PPE) (e.g., gloves, sleeves, encapsulating suits) should be based on the extent of the worker’s potential exposure to wood dust. OSHA offers extensive recommendations on PPE for wood dust.

Wood Dust – Explosive Danger

Wood dust also poses a danger to personal health beyond ingestion or inhalation. Accumulation of wood dust can create conditions where a wood dust explosion could occur. Woodworkers, both recreational and professional, should employ appropriate dust control measures to control air concentrations of free floating dust in the shop as well as preventing accumulation of wood dust on horizontal surfaces in the shop which could contribute to secondary explosive potential. Columbia includes additional references on wood dust safety above to further inform our customers of consequences of uncontrolled wood dust in the workplace.