On September 27, the Rhode Island Department of Environmental Management (DEM) issued a proposed rulemaking to amend the state’s current consumer products regulation. Overall, the proposed new volatile organic compound (VOC) limits are consistent with the current OTC Model Rule and the final regulations promoted by Connecticut, Delaware, Maryland and New Hampshire.

On October 8, HCPA filed preliminary comments with the DEM to express our members’ concerns about the proposed January 1, 2019 effective date. HCPA expressed that many of our member companies manufacture and/or distribute products on a regional basis would likely need additional time to: (1) reformulate products to comply with the new VOC limits, conduct stability and efficacy testing, and make changes to product labels; and/or (2) make necessary changes in product distribution channels to ensure that compliant products are supplied to retailers in the state. As a result, HCPA respectfully urged the DEM to establish a compliance date of January 1, 2020 for the final regulation to suit the needs of our members.

HCPA is pleased to report that the DEM responded that the effective date will be changed to January 1, 2020 in the final regulation.

The HCPA Air Quality Committee will continue to participate as an active stakeholder in this rulemaking process by filing detailed written comments on other key provisions of the proposed regulation by the October 27 deadline.

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