Laura Murphy, Assistant Attorney General and director of the office's Environmental Protection Unit, told the committee the office is requesting modest, mostly technical amendments to Vermont's PFAS product-ban statutes to fix inconsistencies created during last year's codification and amendments.
"We are here to walk through a few revisions to Vermont's PFAS product bans law... housekeeping revisions," Murphy said, asking the committee to make definitions and enforcement authority consistent across food packaging, consumer products, cosmetics/menstrual products and firefighting-agent sections.
What the AG proposed:
- Intentionally-added definition: The office recommends applying the newer, broader definition of "intentionally added" (which captures chemicals added during manufacture and precursor breakdown products) to food packaging and cosmetic/menstrual sections with a uniform phase-in date (suggested July 1, 2027) to match consumer-product timing.
- Certificates of compliance: The AG asked to add the certificate-of-compliance authority to the cosmetic/menstrual and food-packaging sections so the office can request written verification from manufacturers and use civil-investigative tools if needed.
- Manufacturer definition: The AG recommended adding an explicit definition of "manufacturer" to the food-packaging section to match the other product sections for clarity.
- Resale/reuse language: For consistency, staff proposed using the same resale/reuse exception language adopted last year for consumer products in the food-packaging section so second-hand sales or reused containers are not inadvertently swept into a prohibition intended for new products.
Committee members asked how certificates of compliance would be verified and whether testing or investigative demands would be used; Murphy said the office has consumer-protection tools (civil investigative demands, testing and enforcement authority) and would not simply accept a manufacturer's attestation without verification if evidence warranted enforcement.
No opponents were identified at the hearing; AG staff said these are housekeeping items rather than new bans. The committee requested the text of the proposed amendments and indicated it would consider them in forthcoming meetings.