Regulatory News

California – OEHHA Interpretive Guideline for Soy Sauce

May. 24 2021

Recently, California’s Office of Environmental Health Hazard Assessment (OEHHA) issued an interpretive guideline, advising that companies are not required to provide a Proposition 65 warning for exposure to sulfur dioxide (SO2) in soy sauce. According to OEHHA, "SO2 is often used in food to preserve the color and flavor of many foods and to act as an antimicrobial agent.”  

Sulfur dioxide was listed as a reproductive toxin under California Proposition 65 in 2011.  OEHHA has set a maximum allowable dose level (MADL) of 10,000 micrograms per day for SO2.  OEHHA has advised that the MADL is based on inhalation of SO2 and there are no studies on oral exposure.   Further, the guideline states: "However, based on review of relevant information, OEHHA has concluded that exposure to SO2 by the oral route is expected to pose no more risk, and may pose less risk, than exposure to the equivalent amount by the inhalation route."  The calculated worst case daily exposure of 26 micrograms from consumption of sulfur dioxide in soy sauce is far less than the MADL of 10,000 micrograms. Therefore, no warning would be required for these exposures."  

According to the guideline: “The analysis in this Interpretive Guidance applies only to the specific compound SO2, and does not apply to sulfites, bisulfites and metabisulfites. These chemicals are not listed under Proposition 65 and are therefore not subject to the law’s warning requirement. As stated previously, only a small percentage of the total sulfite that is “free SO2” in the soy sauce is molecular SO2.” 

It should also be noted that the guideline was issued even though there have not been any known 60-day notices filed for SO2 in soy sauce.  

Guideline Conclusion:
“OEHHA concludes that consumption by the average consumer of soy sauce will not result in an exposure to SO2 exceeding the MADL. Therefore, a warning is not required under Proposition 65 for exposure to SO2 from consumption of soy sauce.”
How Does this Impact You? Contact Us to Discuss 
By monitoring Proposition 65 actions and settlements, Bureau Veritas helps retailers and manufacturers take a proactive and comprehensive approach to compliance. We assist our clients in determining if listed Prop 65 chemicals are present in their products; identifying exposure routes and assessing the risk levels in items. We then help our clients to build in the appropriate requirements into their testing and quality assurance program on an ongoing basis. 

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