RVIA Economic Impact Study

The Recreation Vehicle Industry Association commissioned an Economic Impact Study on the RV industry, released on June 7, 2016. The study found that the RV industry contributes about $49.7 billion in economic output or 0.28 percent of the Gross Domestic Product. Through its production and distribution linkages, the industry impacts firms in 426 of the 440 sectors of the United States economy.

Nationwide, the industry is responsible for 216,170 jobs, both directly and inderectly, creating an economic impact of $37.5 billion. The full study results, along with each individual state and congressional district's economic impact is available on the website by clicking here .

Does Prop 65 Put Unnecessary Burden on Manufacturers, Suppliers?

Thu Aug 9, 2018
Author: Jessica Machetta

While the implementation of Proposition 65, a labeling and signage rule, might have been well intentioned, some are saying it's just another byproduct of a litigious society that is costing manufacturers and suppliers time and money.

Proposition 65 requires certain businesses to post clear warnings at entrances and labels on products that may expose consumers to certain chemicals.

New regulations for Prop 65 were adopted by the California legislature in 2016, so while companies have had a two-year phase-in period, some are finding themselves scrambling to meet the Aug. 30, 2018 deadline.

Lance Campers, which is based in California, is already compliant with the new regulations. However, Jan Kurahara, general counsel for Lance Campers, points out the new requirements don't just apply to California companies, but any company that sells products in California.

"So it applies to most of the RV industry," he says.

Sam Delson, who is with the California EPA's Office of Environmental Health Hazard Assessment (OEHHA), says, "We're seeing a surge in inquiries in the last couple of months, and we're pleased to see that businesses are seeking to comply, and they're reaching out to us for information."

Delson says the new regulation also covers alternative warnings, such as internet warnings.

"For example, right now we're dealing with rental car companies looking for alternative warnings," he says.

While previous warnings were fairly generic, Delson says, new safe harbor warnings will name at least one specific chemical that could lead to cancer or reproductive health problems and birth defects. The new warnings must also post the URL to the list of potentially hazardous chemicals that customers or users may encounter.

"It's been said the ideal number of warnings is zero because ideally there would not be any hazardous chemicals," Delson says. "Anything companies can do to make their products safer, we applaud."

Prop 65 doesn't ban, or restrict the manufacture of certain products, Delson says.

"It's essentially a right-to-know law," he says. "Consumers are free to consider or ignore the warnings, but it helps them make informed decisions."

"It's very burdensome for manufacturers to even understand what the proposition requires," Kurahara says. "The real value of the new prop 65 is almost zero. People ignore the warnings because they see them over and over and over. It won't take long before people start to ignore these as well. You're not going to *not* go into a building because there's a warning posted at the entrance."

As for the two chemicals on the list that can be found in Lance Campers facilities, Kurahara says, they are wood dust and carbon monoxide.

"Wood dust. Look at what it takes to put an item on that list," he says. "It takes almost nothing. There are some on the list that make sense, but if it's a serious issue, the EPA comes in or county health and shuts the place down."

Delson says the California EPA's role is to compile the list of chemicals and develop regulations on them related to the implementation of the law.

"We have no role in enforcement. It's a self-enforcement law," Delson says. "Most Prop 65 enforcement comes from private parties, which can file a notice alleging a violation. They have to file a 60-day notice with attorney general saying they believe that a certain product is causing significant exposure."

The OEHHA is also providing resources for companies to make sure their warning signs and labels are up to the most current requirements. A government website has been set up that addresses several FAQs and has a searchable database for substances or chemicals that could be harmful.

For instance, type in "wood dust," and it provides this information: Wood dust is on the Proposition 65 list because it can cause cancer. Exposure to wood dust on a recurring basis can cause cancers of the nose, throat and sinuses. Proposition 65 requires businesses to determine if they must provide a warning about exposures to listed chemicals.

And it's not just manufacturers that will need to be compliant, dealers with service bays fall under the Service Stations and Vehicle Repair Facilities category.

Delson says businesses with fewer than ten employees are exempt from the law and encourages company leaders with any questions to contact the OEHHA.