Yikes! Household Hazardous Materials (HHM) permit?

[soaring1]

I am from Iowa.

I received in the mail today a large card from the DNR (Department of Natural Resources) reminding me of a (HHM) retailer permit requirement.

Iowa law requires all retailers who sell (HHM's) to purchase a permit. (Chapter 455F Section 7 Code of Iowa).

retail locations are $25.00. Manufacturers/distributors with independent agents are $25 for the first $3 million.

www.iowadnr.gov/Environmental-Protection/Household-Hazardous-Materials/HHM-Retailer-Permits

safesmartsolutions.org to check out a list.


Why in the world am I getting this notice. Any thoughts or suggestions would be greatly appreciated.

I make cold process soap. I live in the country so don't have access to city sewer. I don't sell on line, don't have a web sight, I have a facebook page which I am lucky to even have time to post anything. I sell just local at farmers market and a couple of boutiques on consignment..

 

[Obsidian]

I would call the number provided and ask why you received the permit info and if soap is considered a hhm.

By chance do you list lye on your labels? Could be someone saw that and doesn't understand that the lye is used up in the finished product.

If that's the case, maybe you could change your lable to have what's in the finished product instead of what goes in the pot. That way it wouldn't "contain" hazardous lye.

 

[LilyJo]

Do you by any chance sell candles?

Only ask as they mention the GHS which includes allergen warnings as being part of the HMM.

 

[DeeAnna]

How much sodium hydroxide (caustic soda) are you buying and from whom? I suspect that's what triggered the notice.

 

[soaring1]

Obsidian,
On my old labels, I did put the lye as an ingredient. On my new labels, I have just what the finished ingredients are. Thought! 2 weeks ago, I took a suitcase full of odds and ends soap bars where just a few were left of this and that with my old labels up to the VA in Marshalltown for a social worker to distribute. Received a text message from the social worker the other day stating my soap was good quality and who she passed them out to had a smile on their face and have come back with positive responses to her.

LillyJo,
I don't sell candles.

DeeAnne,
Hoping you would respond. I had ordered 16 lbs of lye from BA this summer when it was on sale to use during the winter to make soap for the farmers market next season. Not sure how to proceed on this or to just ignore it. I am not huge in sales, enough to pay for my supplies and enjoyment and go under sole proprietor. The post card referenced a Manufacturers/distributors with independent agents are $25 for the first 3 million in sales had to have a permit. Wow. Not me. I will attach a pic of the card. I have GMP, MSDS sheets, SM3 program in effect, have my own soap room but to me I am just a drop in the bucket so to speak. Ignore or not?

Thank you to everyone who responded. Still shaking my head over this.

 

[cmzaha]

Personally I would call, but to me it looks like a permit for retailing the lye itself, not necessarily a finished product. I had to fill out a form at the chem company I purchase 50# bags from and list my company name and resale license.

 

[Obsidian]

The post card referenced a Manufacturers/distributors with independent agents are $25 for the first 3 million in sales had to have a permit. Wow. Not me. I will attach a pic of the card. I have GMP, MSDS sheets, SM3 program in effect, have my own soap room but to me I am just a drop in the bucket so to speak. Ignore or not?

Thank you to everyone who responded. Still shaking my head over this.

but that is you. You are a manufacturer and you make under 3 million in sales. I would absolutely not ignore it, if you do you could get fined and its not worth it seeing as the permit is only $25.
All it will take is a phone call to clear it up and if it turns out you need the permit, get it. Dealing with red tape and stupid regulations is part of selling any product.

 

[DeeAnna]

I'm with the others. You have ended up on this HHM list for whatever reason, but the bottom line is you're on the list. It might be a good idea to call the DNR to learn why you're on the list -- and if there's a misunderstanding, then try to clear it up. But I would not ignore this and hope it goes away. The consequences of blowing the DNR off are likely to be painful. Best to deal with it up front and move on.

 

[soaring1]

Curiosity got to me so I called the Iowa DNR, Customer Service said that a mass mailing went out for the HHM home business this week. They are being flooded by phone calls. Customer service said "I take it you don't sell hazardous materials". I said if you consider bath soap hazardous. The lady to talk to was not available when customer service transferred me, so I left a name and number to be called back on this. Will call back after the weekend if I don't hear back today. I imagine as soap makers we can eventually all look at fees and red tape, which is ok for the safety of the public.

 

[cmzaha]

If you read on page 2 section 6 you will see soap is not a HHM. HHM permits are for retailers of hazardous materials. You probably had to sign or e-sign a form when you first purchased lye from the company you purchase from is how they found you. Beside hazardous lye is used in the drug making industry so it is definetly controlled. https://tax.iowa.gov/sites/files/idr/forms1/78005_0.pdf If it were me I would download the app fill it out so you show you are exempt and keep copies. Do not send a check...

 

[soaring1]

If you read on page 2 section 6 you will see soap is not a HHM. HHM permits are for retailers of hazardous materials. You probably had to sign or e-sign a form when you first purchased lye from the company you purchase from is how they found you. Beside hazardous lye is used in the drug making industry so it is definetly controlled. https://tax.iowa.gov/sites/files/idr/forms1/78005_0.pdf If it were me I would download the app fill it out so you show you are exempt and keep copies. Do not send a check...

I do have this with the Iowa Department of Revenue. Got it back in 2014. May be because I just put crafts as the activity instead of bar soap and metal designs as I also make copper designs.

I have all my paperwork together so it is easy access.

 

[TBandCW]

Don't panic! I'd suggest you write a letter explaining what you do, etc. and don't feel this applies to you. Keep a copy and send return receipt request. Put the ball in their court. I've had govt letters from Calif, asking for this and that and I know they don't apply to me as I live in Nevada. I have a sellers permit for Calif they probably sent it to everyone.

 

[soaring1]

Update.

Talked with the DNR this afternoon. She stated I didn't need a permit. She would take my name off of the list. If I put together a kit to make soap with hazardous materials or if I sold Essential Oils which are flammable, then I would need a permit. I told her I wouldn't even think of doing the above as certification and special insurance would be needed.