Please explain California Heavy Metals Test (CAM 17) in great detail.
What happens when some of the heavy metals in the product are over the
California set limits? How is California test related to the Federal
test? Please answer this question from a standpoint of the companies
who intend to sell products in California.
Please ask for clarification if my question is not clear. Thanks. |
Request for Question Clarification by
pafalafa-ga
on
31 Jan 2004 07:25 PST
Hello arshm-ga,
I just want to make sure we're on the same page, here. My
understanding of the CAM 17 protocol is that it is generally
applicable to WASTE streams, not products. That is, if any of the CAM
17 metals are present in wastewater, or soil from a hazwaste site, or
so on, then that could be a problem.
I have not heard of specific limits for CAM 17 metals in products.
However, the presence of one or more of the metals in a product may
make a customer think twice about using it, if he/she is concerned the
metals will wind up in a waste stream.
Am I on the right track here? Or have you been told there are
specific limits for heavy metals in a product that you handle? The
more you can tell me, the better I can understand your situation, and
perhaps provide an answer to your challening question.
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Clarification of Question by
arshm-ga
on
31 Jan 2004 08:47 PST
You are on the right track and are asking the right clarifications.
You are correct that CAM17 is generally applicable to WASTE streams,
not products. But the real question is if a product, e.g. fertilizer,
that shows one heavy metal reading above the CAM17 limit, what impact
does that have on the supplier of fertilizer? Can the supplier still
sell the product in California? What disclosure does this supplier
have to provide to the customers?
I found below link and am thinking about calling the office,
http://ccr.oal.ca.gov/cgi-bin/om_isapi.dll?clientID=165555&infobase=ccrsal&softpage=Browse_Frame_Pg42
If you would like to pursue this, can you verify your findings with
above California office? I will add a good tip if your findings are
good and verifiable. Let me know. Thanks.
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Clarification of Question by
arshm-ga
on
31 Jan 2004 10:16 PST
Just to clarify, This question is intended for fact finding.
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Request for Question Clarification by
pafalafa-ga
on
31 Jan 2004 13:16 PST
It would seem to me that the Proposition 65 list of chemicals would be
much more relative to your interests that CAM 17.
Prop 65 mandated a list of chemicals that can only be included in
products sold in California if the product is clearly labelled as
containing a carcinogenic chemical. Furthermore, the Safe Drinking
Water and Toxic Enforcement Act of 1986 -- the law that brought Prop
65 into being -- has since been amended to include several other
prohibitions, such as:
25249.5. Prohibition On Contaminating Drinking Water With Chemicals
Known to Cause Cancer or Reproductive Toxicity. No person in the
course of doing business shall knowingly discharge or release a
chemical known to the state to cause cancer or reproductive toxicity
into water or onto or into land where such chemical passes or probably
will pass into any source of drinking water, notwithstanding any other
provision or authorization of law except as provided in Section
25249.9.
25249.6. Required Warning Before Exposure To Chemicals Known to Cause
Cancer Or Reproductive Toxicity. No person in the course of doing
business shall knowingly and intentionally expose any individual to a
chemical known to the state to cause cancer or reproductive toxicity
without first giving clear and reasonable warning to such individual,
except as provided in Section 25249.10.
==========
You can see additional information on all this at:
http://www.oehha.ca.gov/prop65/law/P65law72003.html
So, if a product like fertilizer contained any of the listed
chemicals, it would presumably be subject to the listing provisions
and other restrictions of this law (I'm not aware of any exemption for
fertilizers, but this is worth checking into).
The chemicals list itself can be found here:
http://www.oehha.ca.gov/prop65/CRNR_notices/list_changes/pdf/111403lsta.pdf
and certainly contains some metals, along with many other chemicals.
Is this helping? Or am I only confusing matters?
pafalafa-ga
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Clarification of Question by
arshm-ga
on
31 Jan 2004 15:09 PST
pafalafa-ga,
Thanks for taking the effort to understand my question.
The issue is not whether certain chemicals can be found in the
product, rather it is for the 17 heavy metals that are always found in
this type of product; if one of the heavy metals has a higher reading
than the California limit (We use CAM 17 as the benchmark since
California has the strictest standards). For example, CAM 17 has a
limit on Barium, say 9,000 mg per kilogram. Now what if the new
product has 9,500 mg of Barium in each kilogram?
Does this clarification help? I think you were on the right track with
your first comment. Thanks.
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Clarification of Question by
arshm-ga
on
31 Jan 2004 19:15 PST
You are correct in your first comment when you said that CAM 17
applies to the waste. According to California Code of Regulations (or
California Administrative Manual) Title 22 Environment Health,
"Any waste is a hazardous waste which contains a substance listed in
subsection (b), (which lists 17 heavy metals):
at a concentration in milligrams per kilogram in the waste which
exceeds its listed total threshold limit concentration..."
So I guess it's up to end users to choose or not to choose the product
when there's one or more heavy metals in the product have higher
readings. And it seems this is the end user's responsibility to make
sure their waste is properly handled to meet the state regulations.
Do you have any thing to add?
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Request for Question Clarification by
pafalafa-ga
on
31 Jan 2004 20:07 PST
Hello again,
I'm glad you were able to confirm my earlier observation that CAM 17
is applicable to waste rather than to commercial products.
I hope you will also take steps to confirm my comments about
Proposition 65. This is the law (not the ONLY one, but the key law in
California) that applies to toxics in PRODUCTS like fertilizer.
For instance, have a look at this MSDS from a fertilizer company:
http://www.milorganite.org/regulations/msds.pdf
which says, in part:
"(California Only-Proposition 65 Warning:)
This product contains detectable quantities of chemicals known cause
cancer, birth defects or other reproductive harm. This notice in no
way implies that we have any evidence or experience to indicate that
any genuine hazard of cancer, birth defects, or reproductive harm
results from the normal, proper handling described on our labels and
related literature.?
==========
The presence of heavy metals in your fertilizer product may well
require a similar statement. I urge you to make sure you are in
compliance with Prop 65 before marketing a product in California.
Things can get quite messy, otherwise.
Let me know if there's any specific information you're still in need
of at this point, and I'll see if I can provide it as an answer to
your question.
Best of luck.
pafalafa-ga
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Clarification of Question by
arshm-ga
on
01 Feb 2004 11:49 PST
I will respond to your comment late this week. Thanks.
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Clarification of Question by
arshm-ga
on
04 Feb 2004 08:48 PST
pafalafa,
Thanks for your reseach so far.
Can you locate a lab that will do radiation test (alpha) for
commercial products? This $60 is yours if you find one. Thanks.
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Request for Question Clarification by
pafalafa-ga
on
04 Feb 2004 13:27 PST
Hello again,
I have a bit of experience with laboratory testing, and what a lab can
test for depends an awful lot on the specifics of your situation --
the type of material to be tested, the number of tests, the metric
desired, and so on.
I think this lab will probably meet your needs, but you'll have to
contact them directly to have the necessary conversations before you
can be sure:
http://www.eberlineservices.com/
Eberline Services' Analytical Group offers the capabilities of the
nation's largest radiochemistry laboratory network and a track record
of reliability earned through more than 50 years of radiochemistry
experience. The laboratory network offers comprehensive radiochemical
analyses, including environmental radiochemistry, radiological
bioassay analysis, nuclear utility waste characterization, ambient and
workplace air analysis, and biota analysis. Our laboratories can
provide legally defensible data in virtually any hard copy and
electronic format required.
-----
They have laboratories around the country, including one in California:
2030 Wright Ave.
P.O. Box 4040
Richmond, CA 94804-3823
800/841-5487 Toll free
510/235-2633
510/235-0438 Fax
===================
Give them a call and let me know how it works out. In the mean time,
I'll be looking for other labs that offer similar services.
Good luck.
pafalafa-ga
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