The U.S. Environmental Protection Agency (EPA) is on the move, issuing strong final standards requiring facilities that produce polyvinyl chloride and copolymers (PVC) to reduce harmful air emissions.
Now, a year ago in April (2011) it seems we had this same news about EPA and PVCs. In fact, EPA had a 74-day public comment period and held two public hearings on the proposal before issuing this final rule. So, this is the final phase of EPA’s draft-policy process, so either speak now or forever hold your peace.
EPA says that the final standards — announced yesterday, February 14, 2012 — will reduce emissions of air toxics, such as dioxin and vinyl chloride. Facilities will have the flexibility to choose the most practical and cost-effective control technology or technique to reduce the emissions. Facilities will be required to monitor emissions at certain points in the PVC production process to ensure these standards are met. Multimedia enforcement is expected.
Currently, there are 17 PVC production facilities throughout the United States, with a majority of these facilities located in Louisiana and Texas. All existing and any new PVC production facilities are covered by the final rule.
PVC production facilities manufacture PVC resins that are used to make a large number of commercial and industrial products at other manufacturing facilities. These products include latex paints, coatings, adhesives, clear plastics, rigid plastics, and flooring.
Polyvinyl chloride, commonly abbreviated PVC, is the third most widely produced plastic, after polyethylene and polypropylene. It’s durable, cheap, and easily worked. PVC production is expected to exceed 40 million tonnes by 2016. It can be made softer and more flexible by the addition of plasticizers, the most widely used being phthalates. In this form, it is used in clothing and upholstery, electrical cable insulation, inflatable products and many applications in which it replaces rubber.
The US Environmental Protection Agency’s program that reviews, recognizes and labels (effectively certifying) best-in-class wet chemical-based formulations and products is known as the Design for Environment or DfE Program. See bottom of this post for an overview of DfE*.
So how does a product qualify for a DfE label? By being made of the safest known ingredients.
If you’d like a DfE label for your product, EPA reviews your formula. They’re looking at each ingredient in a formulation in its distinct functional class, whether surfactant, solvent, etc.
Reviewing your ingredients for DfE label. The reviewers then compare toxicity and environmental fate profiles to identify safest known ingredients for man, beast and world. The safest ones get the DfE label. Sounds simple enough, right? Truth is, many get snagged on the chemical disclosure part of the process, either because of reluctance to disclose chemicals or — surprisingly often — due to lack of organized data on the ingredients in formulas.
As an industry example, EPA’s DfE Program entered into a voluntary partnership with representatives of the electronics industry to evaluate the environmental impacts of tin-lead and lead-free solders. The idea was to address the information gap on the environmental impacts of leaded and lead-free solders. The list of EPA’s lead-free solder partners includes Hewlett-Packard, IBM, Intel and Cookson Electronics.
This type of partnership can work across industries.
Know your DfE entity. For background and context, review EPA documents on the subject such as “When you see the DfE label on a product, what does it mean?” If you’re a cleaning product manufacturer, read over “Standard for Safer Cleaning Products (SSCP)” (PDF) (31pp, 177K) and the Standards for Safer Ingredients to get a sense of program goals, framework, criteria, and to determine if your product may qualify to bear the DfE label. For manufacturers of other products, read DfE’s “Discriminating and Protective Approach to Product Review and Recognition” (PDF) (12pp, 160K) which includes the DfE criteria in matrix format.
(Note, with respect to Step 3, that DfE has not yet developed a component class screen for active ingredients in pesticide products.)
Profile formulation ingredients for DfE. Applications for partnership must include a full disclosure of all ingredients and ingredient profiles.
A profile is a compilation of all hazard information available on a chemical and includes:
human health and environmental toxicology
To be able to work with all of the companies that request partnership, DfE retains third-party profilers. Qualified third-party profilers have the expertise and objectivity needed to ensure a quality review, with high confidence in the accuracy and reliability of the profile information. NSF, International and ToxServices, LLC are qualified third-party profilers for DfE.
Assessing ingredients and identifying safer alternatives. After third-party profiling, DfE assesses potential health and environmental effects of each ingredient in your formulation and may identify areas for improvement, safer alternatives, or additional information needs.
In the context of its functional class, DfE evaluates each ingredient in a formulation based on critical health and environmental endpoints.
Functional-class criteria define and more fully explore the safer end of specific ingredient-class continuums. Using the Master Criteria as a guide, the functional-class criteria tailor the health and environmental endpoints in the Master Criteria in a way appropriate to the specific functional class, designate key distinguishing characteristics and adjust thresholds as necessary. Developing the Criteria improves the general understanding of the characteristics of safer ingredients in the class and helps identify green-chemistry opportunities and successes.
The DfE functional class context allows DfE to view ingredients as part of a continuum of improved ingredient choices. Functional Class standards define and more fully explore the green end of specific ingredient-class continuums. DfE has issued three functional-class standards:
the DfE Standard for Solvents
the DfE Standard for Surfactants
the DfE Standard for Fragrances (Human Health)
and is currently developing standards for fragrances (environmental toxicity and fate) and additional functional-use classes in partnership with broad stakeholder workgroups. Additionally, there are specific environmental toxicity and fate standards for ingredients used in direct release products (products that are used outside and do not go through sewage treatment).
Flowchart courtesy of EPA’s Design for Environment program or DfE
DfE is along the lines of Green Chemistry — focusing on full, positive material declaration for safer products throughout their lifecycle and beyond.
*The Design for the Environment (DfE) label is an EPA effort to enable consumers to quickly identify and choose products that can help protect the environment and are safer for families. The label indicates that the DfE scientific review team has screened each ingredient for potential human health and environmental effects and that—based on currently available information, EPA predictive models, and expert judgment—the product contains only those ingredients that pose the least concern among chemicals in their class.
EPA’s Design for the Environment Program (DfE) has allowed use of the logo on over 2000 products. These products are formulated from the safest possible ingredients and EPA says they have collectively reduced the use of “chemicals of concern” by hundreds of millions of pounds.
The label has the look, look for the label, the label looks like this:
Hope this was informative. You may email me privately with your thoughts.
Pressure to modernize TSCA is mounting from all sides, and the American Chemistry Council (ACC) is offering a tool that agencies can use to do something about it. The ACC is proposing a chemical prioritization system that it believes could be used by the Environmental Protection Agency (EPA) to determine which chemicals warrant additional review and assessment.
Achtung means “Pay attention” in German, and the world is indeed paying attention to TSCA reform.
ACC President and CEO Cal Dooley said as part of the new tool’s announcement, “As outlined in ACC’s principles for modernizing the Toxic Substances Control Act (TSCA), establishing a clear and scientifically-sound prioritization process is key to creating a world-class chemical management system.”
The 35-year-old TSCA law does not dictate a process to utilize the information currently available to prioritize chemicals for review. ACC’s approach offers one way to evaluate chemicals against transparent, consistent and scientific criteria that take into account both hazard and exposure. In this system, chemicals are given a score based on certain criteria and then ranked based on both:
the agency’s best professional scientific judgment
Conflict of interest? The obvious problem with ACC contributing a chemical prioritization tool to EPA lies in seemingly inevitable conflicts of interest where an industry-backed association has a stake in evaluating its own products (in this case chemicals) for the marketplace.
ACC says its prioritization tool is not intended to produce conclusions about which chemicals necessarily present a risk to human health or environment. The tool is, apparently, just a gift, simple as that.
EPA’s stakeholder meeting on prioritization. On Sept. 7, before the announcement, representatives from ACC met with officials at EPA to discuss the tool in conjunction with the agency’s stakeholder dialogue on prioritization.
[EPA is opening an online discussion forum for comment from hrough Sept. 14 to get input on the prioritization factors and data sources the Agency plans to use to identify priority chemicals for review and possible risk management action under TSCA. Participate here.]
“We are glad that EPA has recognized the urgent need to prioritize chemicals for review,” said Dooley. “ACC welcomes the opportunity to participate in [this] dialogue and hopes EPA will utilize our concepts to develop a consistent and transparent prioritization process.”
There’s now an extension of time allotted for comments on glymes.
In July, the US Environmental Protection Agency (EPA) issued a proposed rule in the Federal Register concerning a proposed significant new use rule (SNUR) under section 5(a)(2) of the Toxic Substances Control Act (TSCA) for 14 glymes.
EPA’s list of 14 glymes is here for view or download, in an article written by one of the preeminent Professional Chemical Engineers in the field, Kal Kawar. The article is called “The Worst of Glymes” (who says chemists can’t be funny?). This list is easier to read than anything on the EPA site.
Since publication of the proposed rule, EPA has received a request for additional time to submit comments. Now, EPA will extend the comment period for 30 days, from September 12, 2011 to October 12, 2011.
Deadlines for comment: Comments, identified by docket identification (ID) number EPA–HQ–OPPT–2009–0767, must be received on or before October 12, 2011.
In the Federal Register of July 12, 2011 (76 FR 40850) (FRL–8877–8), EPA proposed a SNUR for 14 glymes, designated proposed significant new uses for the 14 glymes, and asked for public comment on several topics. EPA requested comment on whether any of the chemical substances included in the identified glyme category are sufficiently dissimilar from the rest such that they should be removed from the category, or whether any additional chemical substances are sufficiently similar such that they should be added to the category. Comments were also requested on whether any of the additional unconfirmed uses listed in the proposed rule are actual ongoing uses in a consumer product, and whether there are any other ongoing uses in a consumer product of the other chemicals listed in the SNUR.
The Environmental Protection Agency (EPA) has released two databases — the Toxicity Forecaster database (ToxCastDB) and a database of chemical exposure studies (ExpoCastDB) — making chemical toxicity and exposure data more available to scientists, industry and the public. This is yet another step in the inevitable march towards greater material disclosure.
ToxCastDB uses advanced scientific tools to predict the potential toxicity of chemicals. The database also:
helps determine which chemicals need further testing
lets users download data from over 500 rapid chemical tests conducted on more than 300 environmental chemicals (data on an additional 700 chemicals will be available in 2012)
ExpoCastDB uses chemical measurements from homes and child care centers to consolidate human exposure data, including chemical amounts in:
A data warehouse connects ToxCastDB and ExpoCastDB, providing one online resource of animal chemical toxicity studies from the past 30 years. The data warehouse, called Aggregated Computational Toxicology Resource (ACToR), collects data on more than 500,000 chemicals from over 500 public sources. ACToR links both exposure and toxicity data, which are required when considering potential risks posed by chemicals.
The ability to link and compare these different types of data better informs EPA’s decisions about chemical safety. Arguably, it will help industry make better decisions in manufacturing.
“Chemical safety is a major priority of EPA and its research,” said Dr. Paul Anastas, assistant administrator of EPA’s Office of Research and Development. “These databases provide the public access to chemical information, data and results that we can use to make better-informed and timelier decisions about chemicals to better protect people’s health.”