California Code of Regulations  22 CCR 12601, which gives instructions on Clear 
and Reasonable Warnings required by Prop 65, can be found at 
http://www.oehha.org/prop65/pdf.zip/12601.pdf. Three types of exposure to 
listed chemicals, which would require warning, are defined in the regulations. 
They are described as consumer exposure, occupational exposure, and 
environmental exposure.
However, after careful reading, it is still unclear whether producers of 
electronic equipment that contain solder are required to label their product 
with a hazardous chemical warning. For manufacturers of such products, it would 
seem that consumer or environmental exposure would be unlikely. But would the 
servicing of a electronic device constitute occupational exposure since service 
personnel could potentially come in contact with the solder side of printed 
circuit boards. This would seem to constitute knowingly and intentionally 
exposing an individual to a hazardous chemical.

Is anyone in the electronics industry now providing Prop 65 labeling on end 
products or replacement circuit boards that are shipped to  California?


Chuck Freeman
Compliance Department
Datasouth Computer Corp


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