proposition 65...thoughts?

[smallworld]

With No ‘Safe Harbor’ Protection, Optical Companies Eye Approaching Proposition 65 Enforcement Deadline


By Staff
Friday, February 5, 2016 12:21 AM

ALEXANDRIA, Va.—With a May deadline looming, eyewear companies are taking steps to comply with a California rule that requires them to warn consumers and workers in the state if they come into contact with a product containing Bisphenol A (BpA), a chemical used in polycarbonate lenses and frames that has been linked to health problems.

As VMail previously reported, in 2015 the State of California "relisted" BpA on its Proposition 65 list of substances known to the state to cause cancer, birth defects or reproductive toxicity. Companies have until May 11, 2016—one year after BpA was added to the Prop 65 list—to label products containing BpA and place signs in workplaces notifying workers if materials they may come into contact with contain the chemical.

Until recently, California’s Office of Environmental Health Hazard Assessment (OEHHA) said it would publish a "safe harbor" list for products using BpA. The list would determine whether or not chemical exposures above the safe harbor level would trigger a Prop 65 warning label on its products packaging, or if a sign was needed at the workplace.

However, The Vision Council reported this week that OEHHA has declined to publish the safe harbor list, in effect requiring all companies selling or manufacturing products with BpA to list its presence or be subject to possible legal action after the May 11 deadline.

The Vision Council has published information about Prop 65 compliance, including a webinar, on its website. Click here for a PDF of the webinar slides. - See more at: http://www.visionmonday.com/latest-n....4IIuT6Hd.dpuf

[rbaker]

Proposition 65

Chemical Delisted Effective April 19, 2013 As Known To The State Of California To Cause Reproductive Toxicity: Bisphenol A (BPA)
[04/19/13]

Effective April 19, 2013, the Office of Environmental Health Hazard Assessment (OEHHA) is removing bisphenol A (BPA) (CAS No. 80-05-7) from the list of chemicals known to the State to cause cancer or reproductive toxicity for purposes of Proposition 65.¹ The chemical was added to the list on April 11, 2013 based on reproductive endpoints (developmental toxicity).

[Lelarep]

Also, the alternatives to BPA suck just as much, so there is no way to win.

[Quince]

Taken from: Prop 65 and BpA in VISION EASE polycarbonate lenses

"In 2013, the Prop 65 Maximum Allowable Dose Level (MADL), or “safe harbor” level, for BpA exposure wasset to 290 micrograms a day. Based on our research, to reach that level, an individual would have to fullyingest all of the BpA found in one 6-gram polycarbonate lens every three days.

In addition to this, in June of 2014, the Food and Drug Administration (“FDA”) re-published their earlier findingsthat the No Observed Adverse Effect Level (NOAEL) for BpA is 5mg/kg/day; oral exposure. In other words, aperson of 150 lbs. would need to fully ingest over 300 eyeglass lenses per day to exceed this FDA indicatedlevel.

The office governing Prop 65 recently proposed adding a safe harbor limit as part of the BpA listing. Theproposal, posted on March 17, aims to establish 3 micrograms per day as the MADL for dermal exposure toBpA. We are monitoring this proposal, which is open for public comment through May 16, 2016."


The warning had me worried; the science has me laughing!

-kk

[shanbaum]

Lest the information posted here mislead anyone, anyone delivering eyeglasses with polycarbonate lenses into California at wholesale or retail needs to familiarize himself with the proper actions to take from May 11, 2016, onwards, with regard to Proposition 65.

[drk]

SHANBAUM!?

I thought you'd been colonizing Mars or something! Nice to see you.

[shanbaum]

Thanks! Conference on Europa...

[Uncle Fester]

SHANBAUM!?

I thought you'd been colonizing Mars or something! Nice to see you.

I believe the Shan-ban-Man has been very busy working on lab software for Ocuoco. We use their EMR program and an updated version can't come out soon enough for me!!!

http://www.ocuco.com/products.html

Now back to prop 65...

[Dr. Bill Stacy]

Got some questions from Silhouette yesterday on the effect of prop 65 on me. In the process of answering, I found that the law only applies to people/firms with 10 or more employees are subject to the rules. That should eliminate concern for most of us, but for those above that threshold, it sounds like poly may be on the way out, and it isn't ingesting lenses that is of concern, it's physical (dermal) contact with the material that's of concern. I say good riddance to the material if the health threat pans out. Meanwhile, get ready for lots of manufacturer and lab warnings plastered on your poly lens orders.

[rbaker]

California leads the way!

We should also be concerned with the inhalation of polycarbonate particles in the edging process along with the inhalation of the volatile chemicals present in all polymers.

Practice safe eye care. Return back to glass lenses.

[Dr. Bill Stacy]

California leads the way!

We should also be concerned with the inhalation of polycarbonate particles in the edging process along with the inhalation of the volatile chemicals present in all polymers.

Practice safe eye care. Return back to glass lenses.

That's right. I have always been concerned about the breathing in an optical lab. I don't know if the CDC has followed optical workers' health specifically, but some of the smells generated don't seem to me to be friendly. I put an oversized blower in my finishing lab, and it's not enough. I really need a hood with powerful suction to minimize the exposure. It's either that or hand out gas masks.

[Dr. Bill Stacy]

As for glass lenses, as in politics, you can't go back. You can never go back to the bad old days of shattered lenses and lynchings. California leads the way into the future, for sure.

[SeaU2020]

I just received a Safilo Jimmy Choo frame with a prop 65 warning on it yesterday. Am I I legally obligated to keep it on display like that?

[CME4SPECS]

Are you saying that you are not required to notify your patients, if you do not have 10 employees?

Got some questions from Silhouette yesterday on the effect of prop 65 on me. In the process of answering, I found that the law only applies to people/firms with 10 or more employees are subject to the rules. That should eliminate concern for most of us, but for those above that threshold, it sounds like poly may be on the way out, and it isn't ingesting lenses that is of concern, it's physical (dermal) contact with the material that's of concern. I say good riddance to the material if the health threat pans out. Meanwhile, get ready for lots of manufacturer and lab warnings plastered on your poly lens orders.

[optical24/7]

Got some questions from Silhouette yesterday on the effect of prop 65 on me. In the process of answering, I found that the law only applies to people/firms with 10 or more employees are subject to the rules. That should eliminate concern for most of us, but for those above that threshold, it sounds like poly may be on the way out, and it isn't ingesting lenses that is of concern, it's physical (dermal) contact with the material that's of concern. I say good riddance to the material if the health threat pans out. Meanwhile, get ready for lots of manufacturer and lab warnings plastered on your poly lens orders.

Looking at this overview of the law (http://www.thevisioncouncil.org/site...e-12172015.pdf ) it appears you will have to notify the purchasing public of it's hazard & dispose of your swarf only with a solid waste facility.

[Jarhead Daddy]

Living causes dying.

[Uncle Fester]

That's right. I have always been concerned about the breathing in an optical lab. I don't know if the CDC has followed optical workers' health specifically, but some of the smells generated don't seem to me to be friendly. I put an oversized blower in my finishing lab, and it's not enough. I really need a hood with powerful suction to minimize the exposure. It's either that or hand out gas masks.

There are some old threads about why high index stinks when edging.

I believe that's the sulfur added to the resin to boost index of refraction in the lens.

If that was hazardous you couldn't see Old Faithful up close.

[Chris Ryser]

....................., it sounds like poly may be on the way out, and it isn't ingesting lenses that is of concern, it's physical (dermal) contact with the material that's of concern. I say good riddance to the material if the health threat pans out. Meanwhile, get ready for lots of manufacturer and lab warnings plastered on your poly lens orders.

When this hits the media and the public, you will have 60 Minutes and similar producing TV and Radio shows discussing the optical retail again.

Poly lenses are hard coated on both surfaces, front and back, so the only dermal contact or leaching anything bad, would be from the unprotected edges.

A few years ago I developed an easy to apply silicon coating that cures in air, at room temperature. It was designed against allergies originating by frames, Just wipe it on and wait a couple of hours and you have a total seal and no leaching of anything. Problem solved for your patients and your sales.

By going this way, all you would have to worry, is your own poly dust in your lab, which can be solved with a good exhaust hood.

Check it out at : ============>
http://optochemicals.com/total_seal2.htm

[Lelarep]

Sounds like another example of nonsense instead of common sense or science.

[Chris Ryser]

Sounds like another example of nonsense instead of common sense or science.

If you sell me a pair of Polycarbonate lenses and I get some cancer that could be related, or initiated by Bisphenol A, would my friendly trial lawyer not suggest to give it a shot with a 2 million $ lawsuit against the manufacturer of the glasses (optician or optometrist) that could have initiated the disease ?

Remember when McDonalds got sued for millions a few years back, for selling coffee that was too hot ?

[Dr. Bill Stacy]

There are some old threads about why high index stinks when edging.

I believe that's the sulfur added to the resin to boost index of refraction in the lens.

If that was hazardous you couldn't see Old Faithful up close.

I'm very familiar with the smell of sulfur, and while too much time hanging around old faithful could be hazardous to your health, I doubt what 1.67 is putting out is sulfur, although that's probably in the mix. I'd say it smells something like popcorn burning, and definitely has an organic bite to it. I'm putting an industrial hood on my bucket list.

[Dr. Bill Stacy]

When this hits the media and the public, you will have 60 Minutes and similar producing TV and Radio shows discussing the optical retail again.

Poly lenses are hard coated on both surfaces, front and back, so the only dermal contact or leaching anything bad, would be from the unprotected edges.

A few years ago I developed an easy to apply silicon coating that cures in air, at room temperature. It was designed against allergies originating by frames, Just wipe it on and wait a couple of hours and you have a total seal and no leaching of anything. Problem solved for your patients and your sales.

By going this way, all you would have to worry, is your own poly dust in your lab, which can be solved with a good exhaust hood.

Check it out at : ============>
http://optochemicals.com/total_seal2.htm

Most of my lenses are AR coated with hydrophobic top coat. I think smearing silicone on top of that stack would mess up the lens.

[RT]

If you sell me a pair of Polycarbonate lenses and I get some cancer that could be related, or initiated by Bisphenol A, would my friendly trial lawyer not suggest to give it a shot with a 2 million $ lawsuit against the manufacturer of the glasses (optician or optometrist) that could have initiated the disease ?

Bisphenol A is not known to the State of California to cause cancer. BpA is listed on Prop 65 for birth defects or other reproductive harm.

You can view the full list of Prop 65 chemicals here. http://oehha.ca.gov/prop65/prop65_list/Newlist.html

[smallworld]

I actually did some research on this chemical ten years ago and I couldn't find anything in our industry discussing it. There has been research over the years of birth defects connected to workers in companies that make polycarbonate windshields and other products.

[Chris Ryser]

Most of my lenses are AR coated with hydrophobic top coat. I think smearing silicone on top of that stack would mess up the lens.

Bill you missed the point............the surfaces are sealed and will never leak anything. It is the edge that is bare and unprotected and should be sealed.