Mitigating DEA in comsumer products

1. Evaluate current Optimize
Addressing DEA for CA Prop 65 compliance
requires active ongoing management of raw material (RM) quality
Measure raw materials (RMs)
RM Int Std
Measure raw materials (RMs)
RM Int Std
Evaluate current Optimize
Sum of RMs in product = 235 ppm DEA Sum of RMs in product = 51 ppm DEA
Measure finished product
product Int Std
Measure finished product
product Int Std
ppb levels
accurately
measured*
product Int Std product Int Std
Finished product = 240 ppm DEA Finished product = 50 ppm DEA
Mass balance and level control achievedMass balance and level control achieved
Measure exposure
(or presume 100%)
Measure exposure
(or presume 100%)
DEA at/above NSRL DEA below NSRL
(w/ safety margin)
Label carcinogenic or
reformulate or leave market
(w/ safety margin)
No change on label
Complete defense package
Maintainable: ongoing RM measurement
Opportunity to optimize cost
This level of control and certainty can be achieved for any product
*In this example, a fourth RM (buffer/chelator)
contributes DEA, but is not shown because its
contribution is <0.1% of the total
This level of control and certainty can be achieved for any product