Date: Jan 11, 2018
The Vermont Department of Health (VDH) has proposed revisions to its rules under the state's Chemical Disclosure Program. Crucially, the rule would offer relief to manufacturers by replacing the current annual reporting requirement with a two-year window.
The Toxic Substances in Children's Products Rule took effect on December 10, 2015, and follows from the state's 2014 green chemistry bill, VT S. 239. Under the Rule, companies selling children's products in Vermont must disclose the presence of any of 66 chemicals:
The Rule's reporting obligations affect companies that sell children's products in the state, but unlike other green chemistry laws in states like Washington, require individual product-level reports. In 2016, amendments to the Rule were made that changed the reporting requirements from July 1, 2016, and biennially thereafter to a first reporting on January 1, 2017, and second reporting on August 31, 2018, and biennially thereafter. Vermont also launched an online reporting system to allow manufacturers to report chemical disclosures online, and issued an updated Guidance for Manufacturers: Chemical Disclosure Program.
Under the proposed amendments, the rule would:
The VDH is holding a public workshop to discuss proposed amendments to the Chemicals of High Concern in Children's Products rule, available here. The workshop will be held on January 22, 2018, from 8:30 a.m. to 10:00 a.m. at the Department of Health, 108 Cherry Street, Burlington, Vermont, Conference Room 2B (2nd floor). Participants may call in to 1-877-273-4202 (PIN 2403926#).
© 2019 Keller and Heckman LLP. All rights reserved