Life Cycle Thinking blog is moving.

I will continue to provide commentary about TSCA, REACH, product stewardship, sustainability, environmental marketing claims and more as part of the redesigned EHS Strategies, Inc. website.

Georjean Adams


TSCA Reform 2013

New bills on TSCA reform are due in 2013 – Sen. Lautenberg reintroducing his Safe Chemicals Act and Sen. Vitter is expected to introduce a paired down version of TSCA revisions.  Given the major pressures on Congress – fiscal mess, immigration, gun control, etc. and the Republican House – it’s not clear anything will pass this year, but there should be more to chew on.  The problem is everyone wants some thing different in “modernization” of TSCA: make it easier for EPA to issue regulations, but not too easy and convince the public chemicals are safe – whatever that means.

EPA is showing some gumption in using the extensive authorities it already has under TSCA with more SNURs, extended information-gathering under the Chemical Data Reporting rule and “Work Plans.”  I think they are still too timid (not that they can’t go too far sometimes). If they would just work their work plan based on opportunities for real risk-reduction priorities, a lot could be accomplished – although not the massive chemical bans desired by the NGOs.  (Hmmmm… could it be they can’t prioritize risk-reductions because there aren’t significant risks out there?)

It is sad that EPA’s TSCA program seems to need detailed legislative instructions to get down to work.  Unfortunately, that just encourages Congress to get into the business of writing detailed regulations instead of legislation.  Instead of knowledgeable scientists and bureaucrats, we get a handful of behind-the-scenes Congressional staff and special interest ghost writers effectively issuing regulations born of political deals, not public notice and comment rulemaking.  Instead of being able to initiate new rulemaking to change a regulation to respond to new information or learnings, we will be again stuck with the decades-long political process of new legislation.

The same goes for all the state legislation – except multiplied by 50 (or more if you count city-state efforts of the likes of SF and NYC).  At least you can get changes a little faster in than Congress to fix things.

We’ll see….

Nice industry perspective articles from ICSIS.com here and here


EPA has published another batch of 37 Significant New Use Rules (SNURs) on chemicals that had been premanufacture noticed (PMN’d).  Only 17 of them had consent orders.  Isocyanates, siloxanes, nanocarbons predominate.

Make sure you are reviewing these for possible applicability – especially if the use is not “new” to you.

Also make sure your vendors are notifying you if there are restrictions on the use of their products.  TSCA compliance is not only an issue of being listed on the Inventory.


Contact EHS Strategies, Inc. for help.

EPA declassified chemical identities in a few more health and safety studies and made some pretty graphs:  http://www.epa.gov/oppt/existingchemicals/pubs/transparency-charts.html

If I’m reading the numbers right, they have declassified about 20% of the 4,025 claims made.  3,242 claims were deemed actually legitimate.  Another 11, 508 studies had made no claims in the first place.  Only 532 of the chemicals were made over 25,000 lb per IUR reporting. Play whatever games you want with the numbers.


Regardless, these numbers don’t indicate massive fraud to me.  Good that EPA tightened up on knee-jerk claims, made without serious thought.  But the “secret toxics” issue has been overblown.

ECHA reminds submitters to get in early for the second round of REACH applicable to manufacture or import  between 100 – 1,000 metric tonnes/yr of a chemical substance not previously registered.  The official deadline is May 31, but since many dossiers have been incomplete in the past, lead registrants are strongly advised to get their dossier in by March 31.

Reminder: Imported articles are exempt unless intended to release a chemical substance.  (Notification, not registration, and customer communication can be triggered, regardless of volume, for articles with >0.1% Substances of Very High Concern.)

TSCA CDR Data Released

EPA news item:

“EPA has released the non-confidential Chemical Data Reporting (CDR) information on chemical manufacturing, processing and use in the United States.

The 2012 non-confidential database and search tool are available at www.epa.gov/cdr. Users can download the database or search the database by chemical name, CAS number, or company name to retrieve company and site-specific information about chemicals in commerce and to view information on specific uses of chemicals, such as those used in products intended for children. This website also includes more information about the CDR data results, as well as fact sheets.”

Interesting Fact Sheet on uses and reduction in CBI claims.  “The EPA received reports on 7,674 chemicals, including 354 that were reported as used in children’s products. 1,704 chemicals were reported as used in consumer products and 3,073 were used in commercial applications or products. The remaining chemicals reported were for industrial use only.”  Makes the scary 85,000 chemicals in commerce number that is used by NGOs look a little silly.  Also have to question whether some of the chemicals listed as being in children’s products were misclassified – gases propane and ethane? butane? ethyl benzene? These would be industrial intermediates at most and not used by children.

Make sure your reports are correctly represented.

Contact EHS Strategies, Inc. for help.

ECHA has recommended 10 Substances of Very High Concern to go onto the Authorization list.  Once finalized by the European Commission, Member States and EU Parliament, sunset (ban) dates will be set and companies will need to file and get authorization for use approved to continue marketing past those dates.  The proposed chemicals and their typical uses:


Substance name and
SVHC property
Uses in the scope of authorisation (examples)


Formaldehyde, oligomeric reaction products with aniline (technical MDA)

Hardener for epoxy resins; curing agent for polymers


Arsenic acid
Used to modify properties of glass and in the production of printed circuit boards


Dichromium tris(chromate)
Anti-corrosion surface treatments of steel and aluminium in the construction and the aeronautic sectors


Strontium chromate
Anti-corrosion coatings in the aeronautic/aerospace, coil coating and vehicle coating sectors


Potassium hydroxyoctaoxodi­zincatedichromate
Anti-corrosion coatings in the aeronautic/aerospace and vehicle coating sectors


Pentazinc chromate octahydroxide
Anti-corrosion coatings in the vehicle coating and the aeronautic/aerospace sectors


Bis(2-methoxyethyl) ether (Diglyme)
(toxic for reproduction)
Primarily used as a reaction solvent or process chemical in distillation applications; further in batteries and in the production of plastics


N,N-dimethylacetamide (DMAC)
(toxic for reproduction)
Solvent in synthesis, the production of synthetic fibres, in industrial coatings, paint strippers, insulation paper, films and membranes


1,2-dichloroethane (EDC)
Solvent in the manufacture of fine chemicals and pharmaceuticals and in mixtures for biochemical applications


2,2′-dichloro-4,4′-methylenedianiline (MOCA)
Curing agent in resins and in the production of polymer articles