Evaluate current Optimize

Addressing DEA for CA Prop 65 compliancerequires 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