After significant industry speculation over what consumer products would be the first targets for Proposition 65 BPA enforcement, the Center for Environmental Health issued the first BPA 60-day notice of violation on June 14, 2016, a little over a month after BPA’s listing anniversary date. The notice is not for canned food; it is not for sunglasses. The inaugural notice is for a thermal-printed receipt provided to the Center for Environmental Health after (presumably) purchasing food at a Del Taco.
Thermal printing is widely used to print receipts because these printers are both fast and do not require ink. These printers work by heating specially prepared receipt paper in a precise fashion to produce both images and characters. Some advocacy groups had previously taken-up the issue of BPA in thermal receipt paper, and there are receipt papers on the market that are specifically marketed as being BPA free. We don’t know whether this signifies the start of a trend for thermal receipt paper claims, but we will continue to watch for more notices.
We will also be watching how this initial notice plays out – typically, exposure analyses for lead and phthalates have focused on the hand-to-mouth exposure pathway. With a proposed safe harbor level of 3 µg/day for BPA, we are interested to see whether dermal exposure alone is enough to cause a significant exposure.