Prop 65 Chemical Disclosure Compliance Audit

Inspection template for auditing products and components for California Proposition 65 listed chemicals, verifying warning adequacy, and confirming supplier documentation and exposure assessment records.

Inspection Scope and Product Identification

• Product or component scope is clearly identified
  Record the product name, SKU, component part number, lot/date code, and supplier if applicable.
• Inspection basis documented
  Identify the trigger for this audit.
• Current product BOM or material declaration available
  Verify that the bill of materials, material declaration, or equivalent component breakdown is available for review.
• Applicable market and distribution channels identified
  Select the channels where the product is sold or distributed.

Prop 65 Chemical Screening

• Current Prop 65 listed chemical screening completed
  Confirm the product or component was screened against the current Proposition 65 chemical list.
• Listed chemicals identified and documented
  Select any listed chemicals confirmed in the product, component, or packaging.
• Supplier declarations support chemical screening
  Verify supplier declarations, composition statements, or certificates of conformity support the screening result.
• Test reports or analytical results available when needed
  Confirm laboratory reports, XRF screening, or other analytical evidence is available when declarations alone are insufficient.
• Chemical screening review date
  Record the date and time the screening review was completed.

Exposure Assessment and Warning Determination

• Exposure assessment completed for relevant routes
  Verify exposure assessment addresses ingestion, inhalation, and dermal exposure as applicable to the product and use conditions.
• Safe harbor or internal threshold comparison documented
  Confirm the measured or estimated exposure was compared to the applicable safe harbor level or internal compliance threshold.
• Warning determination documented
  Select the compliance outcome based on the exposure assessment.
• Exposure assessment reviewer identified
  Enter the name or role of the person who approved the exposure assessment.
• Exposure assessment supporting documents attached
  Select all supporting documents available for the assessment.

Consumer Warning Label Review

• Warning statement present when required
  Confirm the required warning is present on the product, packaging, signage, or digital listing as applicable.
• Warning wording is adequate and legible
  Verify the warning text is clear, readable, and consistent with the applicable Proposition 65 warning format used by the business.
• Warning placement matches sales channel
  Select where the warning is displayed.
• Warning evidence captured
  Attach a photo or screenshot showing the warning as displayed to the consumer.

Supplier Documentation and Traceability

• Supplier declaration is current and signed
  Confirm the supplier declaration or equivalent compliance statement is current, traceable to the material revision, and signed or otherwise authenticated.
• Document revision control maintained
  Verify the latest revision of the declaration, test report, or specification is on file and obsolete versions are controlled.
• Traceability to supplier lot or batch available
  Confirm the reviewed material can be traced to a supplier lot, batch, or production date code.
• Records retention status verified
  Confirm compliance records are retained according to company policy and are readily retrievable for audit or enforcement review.

Corrective Actions and Sign-Off

• Non-conformances documented with corrective actions
  List each deficiency, affected product or component, owner, due date, and containment action.
• Follow-up verification scheduled
  Record the planned date and time for recheck or closure verification.
• Inspector signature
  Inspector attestation that the audit was completed accurately.
• Management review approval
  Supervisor or compliance manager approval of findings and corrective actions.