CPSC Staff’s Strong Sensitizer Guidance Document For a product containing a strong sensitizer

For a product containing a strong sensitizer to be considered a hazardous substance and to require cautionary labeling under the FHSA, the product must be capable of causing substantial personal injury or substantial illness during, or as a result of, customary or reasonably foreseeable handling or use, including reasonably foreseeable ingestion by children. This requires consideration of the route and the level of exposure that can be expected to be presented by the strong sensitizer as it exists in the particular substance. Therefore, determining whether a cautionary label is required must occur on a product-by-product basis, and it is not based solely on the presence of a strong sensitizer in a product.