Perfluoroalkyl and polyfluoroalkyl substances (PFAs) continue to
garner national attention as emerging chemicals of concern. On
November 10, 2017, two prominent forms of
PFAs—perfluorooctanoic acid (PFOA) and perfluorooctane
sulfonate (PFOS)—were listed by the State of California as
known to cause reproductive toxicity. Pursuant to the California
Safe Drinking Water and Toxic Enforcement Act of 1986, commonly
known as Proposition 65, companies must now comply with the
"clear and reasonable warning" requirement for all
products that expose people to significant levels of PFOA or
PFOS.
Under Proposition 65, the State of California is required to
list chemicals that are known to cause cancer and/or reproductive
harm. Perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate
(PFOS) were formally added to the list of chemicals known to the
state to cause reproductive toxicity on November 10, 2017, using
the authoritative body listing mechanism. The California Office
