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On October 30, 2019, the US state of Vermont’s Department of Health (DOH) proposed a revision to its disclosure program relating to the presence of formaldehyde in children’s products.

The proposal relates to a bill signed into law in 2014 – Act 188 codified as V.S.A. Title 18: Chapter 38A ‘Chemicals of High Concern to Children’. This requires the manufacturers of children’s products, or a trade association representing those manufacturers, to report the presence of chemicals of high concern to children (CHCCs). This must happen if the CHCC is in an accessible component of a children’s product, and is either:

  • Intentionally added and is greater than the practical quantification limit (PQL), or
  • A contaminant that is equal to or greater than 100 ppm

The October 2019 proposal (Number 19PO74) aims to expand the definition of formaldehyde to include ‘formaldehyde donors’. These are substances that are intentionally added to a product so that, when they degrade, they will release formaldehyde as a preservative.

The Chemicals of High Concern to Children act’s current list of CHCC contains 86 entries and, from August 31, 2020, reporting will be revised to annually.

The DOH is currently accepting comments on its proposal until December 11, 2019.

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