Washington: all-sided Implementation on CHCCs reporting under CSPA

Nguồn: 中鼎检测 Ngày: 2016-01-05 Duyệt qua: 11362

Manufacturers of children's products in Washington are required to notify the department of ecology when a chemical of high concern to children (CHCC) is present in their products based on their size and the category of children's products within the deadline of the first annual notice, according to Children's Safe Product Act (CSPA) published in Washington in 2008. A CHCC in children's products shall be reported only if:

1. A CHCC is intentionally added to a product and it occurs above the practical quantification limit (PQL); or

2. A CHCC is a contaminant that occurs at more than 100 mg/kg.

It is time for all manufacturers of “Tier 1" children's product to fulfill their report duty right now. The deadline of the first annual notice for "tiny" manufacturers will last to August 31, 2016.

Since Children's Safe Product Act enforcement is strengthen in Washington recently and Vermont and Oregon states have passed bills early this year to follow the step of Washington State. CTT reminds all manufacturers of children's products to pay attention to CHCCs in their products.
Table 1: CSPA- Deadline for the first annual notice

Manufacturer categories (annual aggregate gross sales of manufacturer of children's products based on the manufacturer's most recent tax year filing, both within and outside of Washington )	Children’s product
	Tier 1	Tier 2	Tier 3	Tier 4
Largest (>1, 000, 000, 000 $)	31/08/2012	27/02/2013	31/08/2013	case-by-case
Larger (>250, 000, 000 $~1, 000, 000, 000 $)	27/02/2013	31/08/2013	31/08/2014	case-by-case
Medium (>100, 000, 000 $~250, 000, 000 $)	31/08/2013	31/08/2014	31/08/2015	case-by-case
Small (>5, 000, 000 $~100, 000, 000 $)	31/08/2014	31/08/2015	31/08/2016	case-by-case
Smaller (>100, 000 $~5, 000, 000 $)	31/08/2015	31/08/2016	31/08/2017	case-by-case
Tiny (<100, 000 $)	31/08/2016	31/08/2017	31/08/2018	case-by-case

Tier 1 - Children's products intended to be put into a child's mouth (e.g., children's products used for feeding, sucking, some toys) or applied to the child's body (e.g., children's products used as lotions, shampoos, creams), or any mouthable children's product intended for children who are age three or under.

Tier 2 - Children's products intended to be in prolonged (more than one hour) direct contact with a child's skin (e.g., clothes, jewelry, bedding).

Tier 3 - Children's products intended for short (less than one hour) periods of direct contact with child's skin (e.g., many toys).

Tier 4 - Children's product components that during reasonably foreseeable use and abuse of the product would not come into direct contact with the child's skin or mouth (e.g., inaccessible internal components for all children's products).

Reporting for Tier 4 components will not be required, except by amendment of CSPA, based on a case-by-case evaluation by the department of ecology.