As we reported earlier in November 20161, the Department of Ecology (DOE) in the US Washington State initiated an amendment to the Children's Safe Product Act (CSPA). Further amendment is proposed to the inclusion and removal of Chemicals of High Concern (CHCC). The total number of CHCCs may change from 66 to 84. The DOE is reviewing public comments and the final rule is expected to be published by 1 September 2017.
The revision of CHCC list2 may add 21 substances. That includes 15 flame retardants, 2 bisphenol compounds, 3 phthalates and one perfluorinated compound. Six out of fifteen of the flame retardants may be identified as CHCC in response to the enacted House Bill 25453. Moreover, three substances may be removed. They are phthalic anhydride, molybdenum and D4. The table A shows the list potential CHCCs to be added or removed.
DOE also proposes to include adding the definition of "internal components”. It has been clarified that no reporting is required for children's product components that would not come into direct contact with the child's skin or mouth, during the reasonably foreseeable use and abuse of the product. Moreover, the obsolete phase-in requirements will be removed. Once the amendment is published officially, manufacturers of children's products are obligated to notify the DOE if their products contain any of the CHCCs in an amount above a de minimis level by 31 January 2019.
Table A. List of newly included and removed substances in the list of CHCC.
Proposed new CHCC
Tris(4-tert-butylphenyl) phosphate (TBPP)
Triphenyl phosphate (TPP)
Tris (2,3-dibromopropyl) phosphate (TDBPP)
Tri-n-butyl phosphate (TNBP)
Ethylhexyl diphenyl phosphate (EHDPP)
Tricresyl phosphate (TCP)
Tris (1-chloro-2-propyl) phosphate (TCPP)
Bis (2-ethylhexyl) tetrabromophthalate (TBPH)
Bis (chloromethyl)propane-1,3 -diyl tetrakis-(2- chloroethyl) bis(phosphate)(V6)