Increased Surveillance of Chromium VI Under California Proposition 65 Regulations

Increased Surveillance of Chromium VI Under California Proposition 65 Regulations

There have recently been six new 60-day notices issued to brands and retailers under US State Regulation California Proposition 65 with respect to Chromium VI violations in leather gloves.

Chromium VI has been listed under California Proposition 65 since 1987 due to its carcinogenic properties however, until recently, there have been no settlements in footwear or accessories relating to Chromium VI non-compliances. In recent months, we have seen six 60-day notices issued for leather gloves retailed in California which raises the question: is chromium VI a new target for ‘Prop 65 plaintiffs’?

 

What is a 60-Day Notice Under California Proposition 65?

A 60-day violation notice is a legal document that is served to the retailer, brand, or manufacturer who has allegedly violated the necessary warning requirements under California Proposition 65. Typically, a 60-day violation notice results in settlement negotiations. Once a settlement is reached, a mandated reformulation or defined limit may be given.

 

What is Chromium VI?

Chromium III tanned leather can form traces of chromium VI under certain environmental conditions. The conversion from Chromium III to Chromium VI is an oxidation process and can be facilitated by the factors like heat, UV radiation, changes in pH, presence of unsaturated organic compounds (e.g. natural fats), oxidizing agents and many other factors. Often several of these factors need to be present at the same time.

The formation of Chromium VI from Chromium III can be slow which means that articles not containing Chromium VI directly after production of the leather may develop some Chromium VI during transport and storage, especially where there is a propensity for Chromium VI to form due to the conditions outlined.

Under well-managed production conditions, chrome-tanned leather should pose a low risk of containing Chromium VI. Poor process control, poor quality chrome powder and adverse storage conditions can, however, cause the formation of the harmful hexavalent form of chromium.

 

Minimising Your Chromium VI Risk

Eurofins | BLC are market leaders when it comes to understanding Chromium VI formation and have extensive knowledge and experience in helping minimise the risk of formation within the leather supply chain. Below is just an example of the many ways in which our team of chemical and regulatory experts can support you:

 

Understanding how Chromium VI is formed, regulatory status and test methods.
 

A comprehensive document designed for tanneries to understand and manage risk.
 

A suite of analytical Chromium VI testing covering both standard and ageing analyses.
 

An excel-based tool to map an individual tanneries risk around Chromium VI formation.
 

  • Testing Calculator

An excel-based tool that will calculate the recommended frequency for testing under a due diligence programme.
 

An on-site audit of the tannery to identify risk and areas for improvement.
 

  • Desk-Based Chromium VI Audits

A desk-based Chromium VI audit following full disclosure of a tanneries manufacturing process.
 

The Eurofins | BLC 6-2-3 solution is designed for use as a preventative measure in processing or as a remediation solution.

 

Contact us to discuss how you can reduce the risk of chromium VI in leather

At Eurofins | BLC, we advise retailers and manufacturers to gain third party assurance that their products do not contain harmful levels of chromium VI through testing, auditing, training, and using our Tannery Risk Profiler. You can discuss any concerns regarding chromium VI risks and legislation such as California Proposition 65 with one of our chemical and regulatory experts, as well as request a product demonstration by emailing info@blcleathertech.com, calling +44 (0)1604 679999 or completing the web contact form below. 

27 August 2019

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