California Cleaning Product Right to Know Act — coalition co-sponsor post-passage summary letter (SB 258, 2017)

Overview

This is a one-page post-passage summary letter circulated by Women’s Voices for the Earth (WVE) and Breast Cancer Prevention Partners (BCPP) following Governor Edmund G. Brown Jr.’s 15 October 2017 signature of California SB 258, the Cleaning Product Right to Know Act of 2017. The letter is the campaign’s brief post-signature communication: it announces passage, identifies the four co-sponsor organisations and the broader supporter coalition, lists three statutory elements considered most consequential by the co-sponsors, and points readers to BCPP and WVE for follow-up. The letter is signed by Jamie (WVE) and by Nancy & Janet (BCPP). NRDC and EWG are identified in the letter body as co-sponsors but do not sign the letter.

The letter is a separate document from the pre-passage BCPP/EWG/NRDC/WVE factsheet held elsewhere in the same source-retrieval-corruption corpus folder. The factsheet was a two-page advocacy document distributed during the legislative campaign before passage; the present letter is a one-page communication distributed after Governor Brown’s signature. The two documents differ in one substantive numeric detail: the pre-passage factsheet states that the SB 258 confidential-business-information (CBI) carve-out references 22 authoritative lists of chemicals of concern, whereas the present post-passage letter states that the carve-out references 23 hazard lists. The post-passage figure is the binding one — by the time the letter was written, the final enrolled statute had been signed and its hazard-list count was fixed — but the discrepancy with the pre-passage factsheet is documented here for traceability and is left for downstream regulation-page work (Cal. Health & Safety Code §§ 108950–108997 implementation analysis) to resolve against the binding statutory text and the California Department of Toxic Substances Control’s (DTSC’s) implementing materials.

Heavy-metal relevance is indirect and operates via the same mechanism documented on the sibling pages: the SB 258 CBI carve-out, by referencing the 23 hazard lists, sweeps in heavy metals to the extent they appear on any of those lists (CA Prop 65, CA MCLs, IRIS, IARC, NTP, ATSDR, US EPA PBTs, OEHHA Non-Cancer Hazards, and the additional DTSC-curated lists under the Safer Consumer Products Regulations chemical inventory, plus the European Union list of fragrance allergens). The letter does not enumerate the 23 lists, does not name any specific heavy metal, and does not propose any quantitative threshold for any chemical in any product matrix. It is held in the Heavy Metal Index corpus as a regulatory-context citation for the SB 258 framework — a post-passage record of the co-sponsors’ framing of the enacted bill — and not as a primary source for heavy-metal exposure values.

Key numbers

The letter reports no contamination measurements and no heavy-metal data. The reportable quantitative content is summarised below.

Statutory thresholds described (page 1)

The 100 ppm fragrance-disclosure threshold is the first quantitative threshold present in the SB 258 documentary record in the HMI corpus (the sibling pre-passage factsheet does not state a numeric threshold). The threshold is the disclosure trigger for fragrance ingredients generally; it does not apply to fragrance ingredients that appear on any of the 23 hazard lists, which must be disclosed at any level under the carve-out. The letter does not specify whether the 100 ppm threshold is mass/mass, mass/volume, or another basis; the binding statutory text at Cal. Health & Safety Code §§ 108950–108997 carries the operative basis definition.

Statutory provisions described (page 1)

Coalition composition (described in narrative)

The letter identifies WVE, BCPP, NRDC, and EWG as the four co-sponsors of the bill. It identifies a broader supporter coalition of advocacy organisations and labour groups, and a separate corporate-supporter group described as “international cleaning product manufacturers and their trade associations” comprising several large consumer-cleaning multinationals, a fragrance house, and a major trade association. The corporate-supporter and consumer-brand-supporter enumerations from the letter body are not reproduced on this source page per the Part 12 brand firewall (strict reading); the PDF in the archived source file carries the names if downstream regulation-page work needs the enumeration.

Methods (brief)

Not applicable. This is a one-page coalition post-passage summary letter, not an experimental study, surveillance dataset, or regulatory text. There is no sampling, no analytical instrumentation, no measurement of any kind. The “method” content of the letter is its summary of the enacted bill’s three highlighted statutory elements (label disclosure, the 100 ppm fragrance threshold tied to the 23 hazard lists, and the hazard-list-tied CBI restriction) and its identification of contact points at WVE and BCPP for follow-up.

Bill provenance. SB 258 was introduced by California Senator Ricardo Lara on 2 February 2017; passed the State Senate and the State Assembly during the 2017 session; and was signed into law by Governor Edmund G. Brown Jr. on 15 October 2017 as Chapter 830, Statutes of 2017. The statutory text is codified at Cal. Health & Safety Code Division 104, Part 3, Chapter 13 (§§ 108950–108997). The letter is internally consistent with a mid-to-late October 2017 distribution date (“Last weekend Governor Jerry Brown signed SB 258”); the letter PDF itself carries no explicit date and no header date stamp.

Speciation. Not applicable. No heavy metals named.

Basis. Not applicable. No concentration values for any chemical in any matrix. The 100 ppm fragrance threshold is the only numeric concentration in the document and applies generically to fragrance ingredients without a basis qualifier.

Implications

• The letter is the post-passage co-sponsor record for California SB 258. Together with the sibling pre-passage coalition factsheet, it brackets the legislative-advocacy cycle for the Cleaning Product Right to Know Act: factsheet during the campaign, summary letter after signature. Both are held in the Heavy Metal Index corpus as regulatory-context citations for the SB 258 framework.
• The letter is the first document in the SB 258 corpus to carry a numeric statutory threshold — the 100 ppm fragrance-disclosure trigger, modulo the hazard-list-tied carve-out. The hazard-list carve-out is the mechanism by which the disclosure framework reaches heavy metals: where a heavy metal is named (as element or compound) on any of the 23 hazard lists, a California-sold cleaning product containing that heavy metal cannot withhold its presence as CBI, regardless of concentration.
• The 22-versus-23 hazard-list discrepancy between the pre-passage factsheet and the post-passage letter is recorded here for downstream traceability. The post-passage figure (23) is the binding count; the discrepancy is treated as a pre-passage drafting artefact. The authoritative enumeration of the 23 hazard lists lives in DTSC’s implementing materials and in the final statutory text at Cal. Health & Safety Code §§ 108950–108997, not in either coalition document.
• The SB 258 framework, in combination with the New York DEC disclosure framework under ECL Article 35 and 6 NYCRR Part 659.6, comprises the two US state-level mandatory cleaning-product ingredient-disclosure regimes documented in the Heavy Metal Index corpus. The two frameworks differ structurally: SB 258 operates via a hazard-list-tied CBI carve-out with a 100 ppm general fragrance-disclosure trigger; the NY DEC framework operates via an ingredient-classification taxonomy (intentionally added / fragrance / nonfunctional byproduct / nonfunctional contaminant) with a five-step threshold hierarchy for the contaminant class.

Limitations

• No original measurements and no heavy-metal data. The letter reports no contamination values, no analytical methods, no detection frequencies, no heavy-metal concentrations or thresholds. The corpus value is regulatory-context only.
• One-page coalition communication, not regulatory text. The letter is the co-sponsors’ brief post-passage communication, not the binding statutory text. The three statutory elements it describes are paraphrases of the enacted bill rather than the operative codification. Wiki sessions needing the binding statutory text should consult Cal. Health & Safety Code §§ 108950–108997 directly.
• Heavy-metal applicability is indirect. The letter does not name any heavy metal. Heavy-metal capture by SB 258 is mediated by the 23 hazard lists; the letter describes the existence of the 23-list mechanism but does not enumerate the lists or identify which contain heavy metals.
• 23 lists not enumerated. The letter states that the CBI carve-out references “23 hazard lists” but does not provide the enumeration. The authoritative enumeration is in DTSC’s Safer Consumer Products Regulations implementing materials; that material is not part of the present source page.
• 22-versus-23 discrepancy with pre-passage factsheet. The pre-passage coalition factsheet states 22 lists; the post-passage letter states 23 lists. The post-passage count is the binding one but the discrepancy is unresolved at the coalition-document layer and would need DTSC-implementing-material review to confirm.
• Coalition advocacy posture, not independent analysis. The letter was prepared by two of the four bill co-sponsors. Evidence-tier C is appropriate to reflect the document’s coalition-communication posture; the underlying statutory text and DTSC implementing materials are the authoritative regulatory anchors.
• No publication date in document body. The letter PDF carries no explicit publication date. The 2017 year is set on the basis of the internal reference “Last weekend Governor Jerry Brown signed SB 258” (Governor Brown signed the bill on 15 October 2017), placing distribution in mid-to-late October 2017.
• No URL on the letter itself. The letter does not carry a stable web URL. The PDF was acquired through the source-retrieval Agent fetch pipeline; access_url is null. Provenance is via the PDF in the archived source file and the SHA-256 hash.

Provenance

• Source PDF: the archived source file
• SHA-256: 40dfc72df0d727ad7377eb5521beeafb8429fd50fe8a51c90f33fe66d409357e
• File size: 353 KB; document body is a single page of letter content. Total 1 page.
• Publishers (signatories): Women’s Voices for the Earth (WVE; signed by Jamie) and Breast Cancer Prevention Partners (BCPP; signed by Nancy & Janet). Identified co-sponsors (named in body, not signatories): Natural Resources Defense Council (NRDC) and Environmental Working Group (EWG).
• Document title (header): “California Cleaning Product Right to Know Act.”
• Authorising bill: California SB 258 (Sen. Ricardo Lara, 2017–2018 legislative session); chaptered as Chapter 830, Statutes of 2017; codified at Cal. Health & Safety Code Division 104, Part 3, Chapter 13 (§§ 108950–108997).
• Implementing agency: California Department of Toxic Substances Control (DTSC) — identification and maintenance of the 23 hazard lists referenced by the CBI carve-out.
• Companion documents in the same source-retrieval-corruption folder: California_SB258_Factsheet_2017.pdf (the pre-passage two-page advocacy factsheet, processed separately as SB 258 (Lara): The Cleaning Product Right to Know Act of 2017 — factsheet); the sibling NY DEC cleansing-product disclosure BMP; EPA Safer Choice Standard 2024 and Master Criteria; the four Green Seal standards (GS-37 2024, GS-37 2009 comparison, GS-52 2022, GS-8 2022); the four EU Ecolabel documents (Factsheet, User Manual, JRC TR2/AHWG2 revision, EEB 30-year briefing); the Bello et al. 2009 occupational-exposure study; the David Suzuki Foundation toxic-cleaners web copy; two NIOSH HHE hospital-cleaning reports; and the WECF Women and Chemicals 2016 report.
• Sibling US state framework in HMI corpus: Cleansing Product Information Disclosure Program — Recommended Best Management Practices.
• DOI: none assigned (NGO coalition communication, not a journal article).
• License: coalition-authored communication distributed publicly; treated by HMI as redistributable regulatory-context reference material.
• Access date: 2026-06-09.
• Acquisition path: included in the source-retrieval Agent Download Corruption Issue folder the archived source file, alongside the sibling pre-passage factsheet and the larger SB 258 / NY DEC / EPA / Green Seal / EU Ecolabel regulatory-context cluster.

Related evidence

• EPA's Safer Choice and Design for the Environment (DfE) Standard (August 2024)
• EPA's Safer Choice Program — Master Criteria for Safer Ingredients (Version 2.1, October 2024)
• The dirt on toxic chemicals in household cleaning products
• Other household specialty cleaners (by functional use-case)

Update history

The five most recent substantive edits to this page, classified major (evidence or structure moved), correction (a published value or statement was wrong and has been fixed), or minor (narrative rewritten without changing the underlying evidence). Each description is derived from what the edit did to this page; the linked commit is the authoritative record, routine regeneration passes are excluded, and the full version history lives in git.