Washington, DC – NPA has submitted comments to California Office of Environmental Health Hazard Assessment (OEHHA) on Naturally Occurring Concentrations of Arsenic in Rice and Lead in Some Foods. NPA supports the exclusion of chemical amounts in the naturally occurring exemption that have been shown to occur naturally in foods if it could be demonstrated their presence was not due to “human activity”. NPA pointed out several scientific errors and poor assumptions in how OEHHA is proposing to calculate the fraction of contaminants attributable to naturally occurring sources. NPA again urged OEHHA to work with FDA to ensure warnings and exposure limits are based upon general principles of regulatory toxicology as well as federal and state regulatory authorities for food. NPA pointed out that California’s limits from exposure for common contaminants like lead, cadmium, arsenic and mercury, are typically lower than the FDA’s provisional total tolerability intake levels established for contaminants in food. NPA supports Governor Brown’s May 7, 2013 press release promising reforms to “revamp Proposition 65 by ending frivolous ‘shake-down’ lawsuits, improving how the public is warned about dangerous chemicals and strengthening the scientific basis for warning levels.” NPA believes that the proposed draft regulation would not serve to decrease frivolous lawsuits by professional plaintiff bounty hunters and may serve to increase them for conventional farms.