Development of a High-Priority Chemicals Data System

Oregon, Vermont, and Washington all have regulations that require companies to report the chemicals they use to manufacture children’s products. These states needed a single tool that would simultaneously support each state’s unique reporting requirements while leveraging regulatory similarities across the three states to reduce the manufacturers’ reporting burden and the states’ administrative burden. ERG was selected to develop this system. 

Working collaboratively with the Northeast Waste Management Officials Association (NEWMOA) and the three states, ERG developed a single unified system—the High Priority Chemicals Data System (HPCDS)—that manufacturers can use to submit the required chemical use reporting data to all three states. The HPCDS consolidates commonalities across the three states’ reporting requirements while also successfully accommodating differences and unique requirements. For example, two states have payment requirements with different third-party vendors; each of the three states has a different reporting deadline; two states require annual reporting and one state requires biennial reporting; and two states require retrospective reporting while one state requires prospective reporting. The HPCDS significantly improves efficiencies for all stakeholders. Manufacturers can now use a single portal to fulfill their reporting obligations; administrators can now review and approve manufacturer data submissions in a single location; and the public can now use a single search tool to access reporting data submitted to all three states.