Clearing Up Errors on Aloe Vera and Prop 65

Lauren Zeise
Lauren Zeise, Ph.D., is the Acting Director of the Office of Environmental Health Hazard Assessment.

Tom Scott’s recent piece, “Feel the Burn: Aloe Vera Added to Prop. 65 List” (2/11/16) contained some serious factual deficiencies. The  article only cited the Office of Environmental Health Hazard Assessment’s original proposal to add Aloe vera  to the Proposition 65 list, but failed to explain what we actually did.  We added “Aloe vera, non-decolorized whole leaf extract” to the Proposition 65 list as a carcinogen, effective December 4, 2015.  The listing was based on an International Agency for Research on Cancer (IARC) identification and required by California law and regulations. While the title of the listing may seem unwieldy, it is specific for a reason—to reduce confusion and clarify the scope of business warning obligations. It refers to an unprocessed form of Aloe vera that is not typically used in consumer products. The processed form of Aloe vera typically used in consumer products is not covered by the listing. Consequently, these products would not require a Proposition 65 warning and would not be subject to public or private enforcement actions.

Our decision to limit the listing to the unprocessed form of Aloe vera came after considering business comments that argued IARC only identified the unprocessed form of Aloe vera as a carcinogen. We agreed with those comments (which, along with our response to them, are publicly available on our website) and appreciate that the business groups brought this matter to our attention.  Conversely, the business community is appreciative that we carefully considered their comments and saw merit in them.

We believe that our actions in this instance exemplify our commitment to both fulfill our obligations to implement Proposition 65 and consider stakeholder comments and concerns during the listing process. We are concerned that the article’s criticism could leave readers misinformed about that commitment.

In addition, although the requirement for Proposition 65 warnings to name chemicals from a list of 12 was part of our previous proposed regulatory action,  our current proposal does not contain this requirement and would instead require “safe harbor” warnings to contain the name of at least one chemical of the business’ choosing for which a warning is being provided. The current proposal is posted here.

Lauren Zeise, Ph.D., is the Acting Director of the Office of Environmental Health Hazard Assessment.

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