While 11 states have passed bans on the chemical Bisphenol A (BPA) in certain children’s food and drink containers, and bills have been introduced in Congress to do the same nationally, California has enacted legislation that specifically impacts eyecare professionals. BPA is used as a starting material in the manufacture of polycarbonate, which is well known for its use composing eyeglass lenses.

On June 17, 2016, California established the maximum allowable dose level of BPA on its Proposition 65 list of substances known to the state to cause cancer, birth defects or reproductive toxicity. The California regulation for the maximum allowable dose level to the chemical BPA is 3 micrograms per day from dermal exposure from solid materials. Enforcement of the BPA regulation originally went into effect in California on May 11, 2016, and the maximum allowable dose level, also referred to as a “safe harbor,” becomes effective October 1, 2016.

The amount of BPA in polycarbonate is information that is proprietary to each manufacturer of eyeglass lens materials, and even with knowledge of how much is in a particular brand of material, there is no direct correlation to the amount that would be transferred by exposure to the skin. That information would be determined by a toxicologist.

According to The Vision Council, “The safe harbor exempts products from the Proposition 65 warning requirements where exposure to BpA from those products is less than 3 micrograms per day. The safe harbor is limited to 3 micrograms per day based on dermal exposure and does not cover other potential means of exposure such as ingestion or inhalation.”

While The Vision Council continues to work on this issue on behalf of its members, it has also established resources for eyecare professionals to use to investigate this further. Those interested in conducting dermal exposure testing to determine whether their products are in the safe harbor may contact Michael Vitale, technical director at The Vision Council, for names of labs doing such testing.” He can be reached at 703.548.2684 or by email at

For optical retailers in California, the simple fact that polycarbonate lenses contain BPA requires that they post warning signs. For wholesale optical laboratories in California, because the grinding of dry polycarbonate presents the additional risk of inhalation, occupational warning signs are required to be posted on the premises.

Often, as goes California eventually goes the rest of the country. How this plays out there could have an impact beyond the state’s borders. While The Vision Council is keeping a close eye on this legislation, it’s important for all eyecare professionals to do the same.

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