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The California Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA) is the lead agency for the implementation of the Safe Drinking Water and Toxic Enforcement Act of 1986 (Health and Safety Code section 25249.5 et seq., Proposition 65). OEHHA is proposing to include “areca nut” and “betel quid without tobacco” on the list of chemicals known to the state to cause cancer, for the purposes of Proposition 65. A ‘betel quid’ (synonymous with ‘pan’ or ‘paan’) generally contains betel leaf, areca nut and slaked lime, and may contain tobacco. Areca nut is the seed of the fruit of the oriental palm Areca catechu.

Health and Safety Code section 25249.8(a) requires that certain substances identified by the International Agency for Research on Cancer (IARC) or the National Toxicology Program (NTP), as described in Labor Code section 6382(b)(1) and (d), be included on the Proposition 65 list. Labor Code section 6382(b)(1) references substances identified as human or animal carcinogens by IARC, and Labor Code section 6382(d) references substances identified as carcinogens or potential carcinogens by IARC or NTP.

In 2004, IARC issued the monograph Betel-quid and Areca-nut Chewing and Some Areca-nut-derived Nitrosamines (Volume 85) in its series IARC Monographs on the Evaluation of Carcinogenic Risks to Humans. In this monograph, IARC concluded “Areca nut is carcinogenic to humans (Group 1).” In the same monograph, IARC concluded “Betel quid without tobacco is carcinogenic to humans (Group 1).” Betel quid with tobacco was previously classified by IARC as “carcinogenic to humans (Group 1)” and was listed under Proposition 65 on January 1, 1990; IARC reiterated that identification in the 2004 monograph.

Pursuant to state law, IARC’s identification of “areca nut” as carcinogenic to humans means that “areca nut” must be included on the Proposition 65 list (Labor Code sections 6382(b)(1) and (d)). Pursuant to state law, IARC’s designation of “betel quid without tobacco” as carcinogenic to humans means that “betel quid without tobacco” must be included on the Proposition 65 list (Labor Code sections 6382(b)(1) and (d)). Therefore, OEHHA proposes to add “areca nut” and “betel quid without tobacco” to the Proposition 65 list of chemicals known to cause cancer. Anyone wishing to provide comments as to whether “areca nut” and “betel quid without tobacco” meet the requirements for listing as causing cancer specified in Health and Safety Code section 25249.8(a), by reference to Labor Code sections 6382(b)(1) and (d), should send written comments in triplicate, along with any supporting documentations, by mail or by fax to:

Ms. Cynthia Oshita
Office of Environmental Health Hazard Assessment
Street Address: 1001 I Street
Sacramento, California 95814
Mailing Address: P.O. Box 4010
Sacramento, California 95812-4010
Fax No.: (916) 323-8803
Telephone: (916) 445-6900

Comments may also be delivered in person or by courier to the above address. It is requested, but not required, that written comments and supporting documentation be transmitted via email addressed to: coshita@oehha.ca.gov. In order to be considered, comments must be postmarked (if sent by mail) or received at OEHHA (if hand-delivered, sent by FAX, or transmitted electronically) by 5:00 p.m. on November 21, 2005.

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