On October 5, 2016, the US state of Washington’s Department of Ecology (DOE) issued proposals to amend the reporting rules for, and make additions and subtractions from, the list of Chemicals of High Concern to Children (CHCC). This is the first step in an extended regulatory process. The final proposed language is expected in January, and an additional public comment period will follow. The DOE is running a lengthy period of consultation to accept public comments and hold hearings to discuss the proposed rule and list updates.
Proposed changes to the reporting rule include:
• Removal of the staged starting time and tier system for reporting - all children’s products are covered by the requirement and all sizes of business must report
• The reporting date is changed to January 1, beginning in 2018 when all reports are due for products sold in Washington in all of calendar 2017
• New language states clearly that the internal components of a children’s product do not need to be reported
• The proposed language changes the title, and much of the text of section 173-334-100, so that the due date and period covered by each report is communicated more clearly
• Adding new definitions of “De minimis level” and “Internal Component”
• New language to refer to the online reporting database that is used for reporting
• Minor grammatical changes to the rule and chemical list
Washington State DOE is also proposing the inclusion of a further 18 chemicals and removal of two chemicals from the list of CHCCs. For the most current list of the chemicals Washington State proposes to include and remove from the list of CHCCs, please refer to the Washington State rulemaking website.
The original CHCC list contained 66 substances and was created following the enactment of the Children’s Safe Products Act (CSPA), by Washington State in 2008. The law requires manufacturers to report if certain classes of children’s product intentionally contain any of the proscribed chemicals or if the product contains the chemical as a contaminant at levels over 100ppm. Since the list was created, Washington State has regularly promulgated rules and published guidance documents to clarify the responsibilities of retailers and manufacturers, and clarify the reporting process.
The current consultation period for changes to the reporting rule and list of CHCCs, will close on November 5, 2016.
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