California's Office of Environmental Health Hazard Assessment (OEHHA) has proposed two new Proposition 65 No Significant Risk Levels (NSRLs), and the Prop 65 NSRLs for 1-bromopropane and DEA carry different rules that are easy to misread. The proposed safe harbor is 54 micrograms per day for 1-bromopropane (1-BP) and, after a June 2026 revision, 5.8 micrograms per day for diethanolamine (DEA) by the dermal route only. Both remain proposed, not adopted, as of August 2026. This guide explains what the levels mean, who is affected, and how to prepare without treating an unadopted rule as binding.

Book a compliance risk assessment to understand where 1-BP and DEA exposures sit across your products and suppliers before this rule finalizes.

Key Takeaways

📌 OEHHA has proposed Prop 65 NSRLs of 54 µg/day for 1-bromopropane and 5.8 µg/day for diethanolamine (dermal), both pending as of August 2026.

⚠️ The 1-BP level applies across all exposure routes, while the DEA level covers dermal exposure only, leaving oral and inhalation DEA exposures with no safe harbor.

⏳ The comment period closed July 2, 2026, but no Final Statement of Reasons or adoption notice has published, so neither level is yet enforceable as a safe harbor.

🏭 Electronics, metal-finishing, adhesive, and industrial or institutional cleaning manufacturers face the most direct exposure through vapor degreasing and dermal DEA contact.

📌 A June 2026 federal injunction in PCPC v. Bonta bars DEA cancer-warning enforcement for cosmetics, shifting the DEA safe harbor's practical relevance toward non-cosmetic products.

📄 Companies should track adoption through OEHHA's notices index and prepare BOM-level substance screening rather than assuming a fixed effective date.

🤖 A centralized compliance data backbone lets teams screen 1-BP and DEA exposures continuously and update thresholds the moment the rule is adopted.

What Are the Proposed Prop 65 NSRLs for 1-Bromopropane and DEA?

An NSRL is a "safe harbor" level under Proposition 65. If exposure stays at or below the adopted level, no cancer warning is required. OEHHA proposed these two levels to give businesses clearer guidance for Proposition 65 compliance decisions that are usually made at the label or SKU level.

Both figures are proposed values, and adoption has not occurred. You can confirm the current status directly on the OEHHA proposed rulemaking page. Treat these numbers as planning inputs for chemical and hazmat compliance, not as active thresholds.

Framework and Legal Scope

Proposition 65, the Safe Drinking Water and Toxic Enforcement Act of 1986, requires a warning before a business knowingly exposes a person to a listed chemical. Under Title 27, California Code of Regulations, section 25705(b)(1), an adopted NSRL sets the daily exposure below which no cancer warning is required, based on a lifetime excess cancer risk of no more than 1 in 100,000.

DEA has been listed as a Prop 65 carcinogen since 2012, and 1-BP has been listed as a carcinogen since 2016. Neither chemical is new to the list. What is new is the proposed safe harbor, which would give businesses a defined level to screen against. For context on how listings and warning duties evolve, see Certivo's California Proposition 65 compliance 2026 guide.

The Route-Scope Difference That Changes Screening

This is the most operationally important point in the entire rulemaking, and it is easy to get wrong.

1-Bromopropane applies across all routes

The proposed 1-BP level carries no route qualifier in the regulatory text. It would therefore function as a single general threshold across dermal, oral, and inhalation exposures, even though OEHHA derived it from an inhalation unit risk based on female mouse lung tumors. In practice, you screen 1-BP against 54 µg/day as an all-routes figure once adopted, not as an inhalation-only number.

DEA applies to dermal exposure only

The DEA level is expressly dermal only. OEHHA's notice states the level does not apply to non-dermal routes. That means oral and inhalation DEA exposures would gain no safe harbor from this rulemaking, and businesses with those exposures must still derive their own level. Effective BOM substance and threshold management has to encode this asymmetry, or a screening tool will produce false confidence on DEA.

Route scope comparison for proposed Prop 65 NSRLs 1-bromopropane and DEA

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What Changed in June 2026

The DEA level was lowered, and 1-BP was left unchanged

On June 10, 2026, OEHHA issued a 15-day Notice of Modification lowering the proposed DEA dermal level from 6.4 to 5.8 µg/day, driven by a revised dermal absorption factor and an updated cancer slope factor. The notice added supporting documents to the record and expressly left the 1-BP level unchanged. You can review the modification in the OEHHA Notice of Modification. The comment period was later extended to July 2, 2026 at the request of the Personal Care Products Council.

A federal injunction reshaped where the DEA level matters

Separately, a federal court entered a permanent injunction in PCPC v. Bonta on June 24, 2026, barring enforcement of the DEA cancer warning for cosmetics and personal care products on First Amendment grounds. The injunction does not cover DEA in other product types. The practical result is that the proposed DEA dermal safe harbor now matters most for non-cosmetic dermal exposures such as industrial, institutional, and cleaning products, which remain fully enforceable. This is a good example of why regulatory intelligence and horizon scanning has to track litigation, not only rulemaking.

Industries and Product Categories Affected

📌 Electronics and metal-finishing manufacturers using 1-BP in vapor degreasing and precision cleaning face the primary supply-chain-relevant 1-BP exposure. EPA's TSCA risk evaluation attributes a large share of 1-BP volume to vapor degreasing of optics, electronics, plastics, and metals, which is why the electronics manufacturing and semiconductor and high-tech sectors should prioritize this substance.

📌 Adhesive and aerosol-spray formulators, dry cleaners, and asphalt producers using 1-BP as a solvent fall within scope through the same all-routes threshold.

📌 Chemical intermediate manufacturers producing pharmaceuticals, insecticides, quaternary ammonium compounds, and flavors or fragrances use 1-BP as an intermediate. See Certivo's chemical manufacturing view for sector context.

📌 Industrial, institutional, and cleaning product manufacturers with dermal DEA exposures represent the category where the DEA dermal level retains practical value, given the cosmetics injunction.

Reporting and Documentation Challenges

The hard part is not the two numbers. It is knowing which finished products contain 1-BP or DEA, at what exposure, through which route, across a multi-tier supply chain. Most compliance teams cannot answer "which SKUs contain this substance" quickly because the data lives in scattered supplier declarations and spreadsheets.

Three challenges recur:

⚠️ Substance presence is often hidden. DEA frequently appears as a contaminant or impurity in triethanolamine rather than as a declared ingredient, so a simple ingredient search misses it.

📊 Route matters for screening. A single threshold cannot be applied blindly, because DEA has a dermal-only level while 1-BP is all-routes. Screening logic must carry route context.

🔗 Supplier data is inconsistent. Validating declarations against the correct substance, CAS, and exposure route at scale requires automated supplier data collection rather than email chases.

This is where specialized substance reporting and AI document parsing and certificate validation reduce manual load, by extracting substance and CAS data from supplier documents and flagging gaps at intake instead of during an audit.

Struggling to see which products carry 1-BP or DEA exposure? Request a compliance review to map substance presence at the BOM level.

Compliance Risks and Enforcement Exposure

Even with a proposed safe harbor pending, the underlying warning duty for listed 1-BP and DEA is already in effect. Risk categories to weigh:

• Private enforcer notices. DEA has drawn significant Prop 65 enforcement historically. Outside cosmetics, that exposure continues, and the injunction does not shield non-cosmetic products.

• Documentation gaps. Regulatory inspections and customer audits both ask for point-in-time evidence of what a product contained and what exposure assessment supported a no-warning decision. Weak records turn a routine inquiry into a scramble.

• Version confusion. Applying the wrong proposed value, or treating a dermal-only level as general, creates defensible-position risk.

No software makes a company "audit-proof." The realistic objective is audit-ready: reducing surprises and shortening response time. Continuous audit-ready documentation with time-stamped declarations and historic state tracking lets you show who submitted evidence, when, and under what authority, across internal audits, customer (OEM) audits, regulatory inspections, and certification audits such as ISO 9001 or ISO 14001.

Prop 65 substance screening workflow for 1-bromopropane and DEA compliance

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Rulemaking Timeline and Adoption Outlook

Based on currently available regulatory guidance, adoption timing is not fixed. The prudent posture is to re-check the OEHHA notices index and the adopted NSRL and MADL safe-harbor table periodically rather than assuming an effective date.

Strategic Compliance Preparation Checklist

✅ 1. Identify exposure now. Map which products and processes involve 1-BP or DEA, prioritizing solvent and degreasing steps and the suppliers behind them.

✅ 2. Encode route logic. Screen 1-BP as an all-routes figure and DEA as dermal-only, so your screening does not overstate DEA coverage.

✅ 3. Do not treat DEA dermal as a general safe harbor. Oral and inhalation DEA exposures still require a self-derived level.

✅ 4. Re-scope DEA toward non-cosmetic products. With cosmetics enforcement enjoined, focus DEA dermal analysis on industrial, institutional, and cleaning products.

✅ 5. Strengthen supplier declarations. Use supplier and contractor management to collect and validate substance data with supplier risk scoring.

✅ 6. Use official docket identifiers. Reference CRNR file Z2025-0812-06 and OEHHA docket 21723 in customer-facing material.

✅ 7. Track adoption. Assign ownership for monitoring OEHHA's notices index so the moment the rule finalizes, thresholds update.

How AI-Native Compliance Automation Helps

Substance-specific rules like this one expose the limits of spreadsheet-based compliance. A single proposed level with a route qualifier can quietly break a manual screening process. AI-native compliance automation addresses that in four ways.

First, a centralized compliance data backbone links substance declarations to specific products and bills of material, so "which SKUs contain DEA or 1-BP" becomes a query, not a project. This is the foundation of materials and environmental compliance at scale.

Second, CORA-powered regulatory intelligence tracks changes to the rulemaking, the modification, and the related injunction, so your team is alerted before positions shift rather than after. That is regulatory horizon scanning applied to a live, moving target.

Third, CORA-enabled analysis parses supplier certificates and material declarations to extract substance and CAS data automatically, applying the correct route-specific threshold and flagging gaps. This is where AI-native compliance automation replaces manual document review.

Fourth, time-stamped, versioned records support continuous audit readiness across multi-tier supply chains, giving compliance, quality, and procurement one source of truth. For a broader view, see Certivo's Prop 65 supply chain disruption guide.

Executive Conclusion

The proposed Prop 65 NSRLs for 1-bromopropane and DEA are narrow on paper but sharp in practice. One is an all-routes level, one is dermal-only, one figure moved and one did not, and a parallel injunction has rerouted where the DEA level actually matters. None of it is binding yet, which makes disciplined tracking and clean substance data the real deliverables. Manufacturers that can screen exposures at the BOM level and update thresholds instantly on adoption will absorb this rule without disruption. Those relying on spreadsheets will not know their exposure until an enforcer or auditor asks.

Speak with a compliance specialist to see how Certivo maps 1-BP and DEA exposure across your product portfolio and keeps you ready the day this rule is adopted.