For everyone concerned about the expanding burden of green chemistry reporting, here’s something that will really make your hair – and bankbook – stand on end: Vermont is proposing to implement the green chemistry law adopted last year by mandating SKU-level reporting. Yes, you read that correctly. (Read the proposed rule here.) The impact is potentially enormous. While Vermont’s green chemistry law (Act 188) was adopted with a promise to “harmonize” with other state laws, Vermont’s Department of Health is proposing to go beyond the Washington State’s – and all other jurisdiction’s – requirements. Without clearly identifying thresholds for reporting or allowing for an exemption where a manufacturing control program is in place. Without the phase-in approach to reporting adopted in Washington. Without accommodating trade secrets. At $200 per report.
Businesses, large and small, making children’s products that are affected by this proposal should make their views known to the state. Comments are due this Friday, and can be sent via e-mail to AHS.VDHRules@state.vt.us (more details here).