California’s BPA Threshold

BPA has officially been assigned a maximum daily threshold limit by the California Office of Environmental Health Hazard Assessment (OEHHA). In policy and compliance terms, this means OEHHA has officially announced a proposal to adopt a Proposition 65 Maximum Allowable Dose Level (MADL).

The MADL for exposures to bisphenol A (BPA) is set at 290 micrograms per day.

The notorious B.P.A. BPA is being considered for Prop 65 listing due its being “known to cause reproductive toxicity.” (In the event that BPA does not wind up listed, OEHHA will not proceed with the adoption of this Maximum Allowable Dose Level (MADL)).

OEHHA says it is proposing the MADL of 290 micrograms per day at this time to assist the public in assessing the potential impact of the listing.

Here’s some context. In a 2011 study reported by Fox News, people who ate one serving of canned soup every day for five days had BPA levels of 20.8 micrograms per liter of urine. Compare this to the control group, who ate fresh soup for those five days and had just 1.1 micrograms per liter.

The difference in BPA levels represents a 1,221 % increase in humans— from just one serving of canned soup per day. There are other canned consumable goods people eat every day. BPA shows up in food from restaurants, in prepared and frozen foods, and in places you might not expect, like some paints, packaging and of course, plastic bottles. A person’s daily total exposure is the thing of concern here.

BPA and worker safety. The levels of BPA seen in the study participants were “among the most extreme reported in a nonoccupational setting,” the researchers wrote in their report.

This is a reminder that while consumers should watch their BPA exposures, folks in occupational settings should really watch theirs.

Packagers, technical supervisors, laboratory technicians and maintenance workers in BPA manufacturing facilities and facilities using BPA to manufacture, say, epoxy resin are examples of occupational environments where male workers in one Kaiser study showed four times as many endocrine-disruption related conditions. Male hormonal disruptions result in conditions such as, well, you know. And if you don’t know, read the study.

However, California Proposition 65 exists primarily to protect citizens of California, not so much as a worker safety measure. So news surrounding this BPA moment will focus on can linings and cash register receipts and other such areas where average citizens are exposed.

Feedback from industry. In legalese, setting a maximum threshold for exposure to BPA would happen via amendment of Section 25805(b) of Title 27 of the California Code of Regulations.

Any written comments concerning this proposed action, regardless of the form or method of transmission, must be received by OEHHA by 5:00 p.m. on March 11, 2013. All comments will be posted on the OEHHA website at the close of the public comment period, so don’t say anything your company won’t stand behind later.

Feedback from the public. Just because it’s usually industry who comments on these matters doesn’t mean the public shouldn’t (or, necessarily, should). Comment periods are open. If you have some knowledge of BPA and related issues and you have an opinion on the proposed threshold, you should email comments to: P65Public.Comments@oehha.ca.gov — they’ve asked that folks please include “BPA MADL” in the subject line.

The most recent Cal Prop 65 list can be found here: http://oehha.ca.gov/prop65/prop65_list/files/P65single010413.pdf

About Kal

Kal Kawar, CIH, PE, has a bachelor's in chemical engineering and a master's in industrial hygiene. His professional experience includes serving as staff industrial hygienist for IBM's New York semiconductor manufacturing facility, and as industrial hygienist for IBM’s US headquarters. Now executive vice president of Actio, Kal taps more than 20 years' worth of chemical engineering, industrial hygiene, and environmental engineering experience. His far-reaching expertise with global regulatory challenges created by EPA, TSCA, REACH, RoHS, WEEE – and hundreds of others – aid in developing Actio software solutions for MSDS management, raw material disclosure compliance, and product stewardship in a supply chain.
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