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Law Educator, Esq.
Law Educator, Esq., Attorney
Category: Legal
Satisfied Customers: 110561
Experience:  JA Mentor -Attorney Labor/employment, corporate, sports law, admiralty/maritime and civil rights law
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We manufacture a repair patch with a rubber-based adhesive.

Customer Question

We manufacture a repair patch with a rubber-based adhesive. It is not regulated, a MSDS is not required by OSHA, and it does not have a health or safety risk. The test reports show halides (bromide, chloride and fluoride) and sulfate are below required levels of <3 and <1.
One vendor, out of several thousand, is saying we need to register our product and formulations in WERCSmart because they consider it a "chemical-containing product under the adhesive category". I don't think we need to and do not want to show how we manufacture this product.
How can I respond that will explain to them that we do not need to register?
Submitted: 2 months ago.
Category: Legal
Expert:  Law Educator, Esq. replied 2 months ago.
Thank you for your question. I look forward to working with you to provide you the information you are seeking for educational purposes only.
I do not see how you have to register when they are below the required levels. There is no law saying you must register your product either. As you do not need to actually register with WERCSmart, no law requires it and you can explain to them that there is no law requiring registration, just that simple. You do not owe them much of an explanation really. It is tough to tell you what else to tell them because there is no such law and it would be easier if there were a law addressing this to describe to them

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