Decoding the EPA’s Latest proposal to amend TSCA Chemical Regulation
On May 26, 2023, the U.S. Environmental Protection Agency (EPA) proposed amendments to the regulations governing new chemicals under the Toxic Substances Control Act (TSCA). The purpose of these amendments is to align the regulations with the amendments made to the TSCA in 2016 and improve the efficiency of EPA’s review process for new chemicals. The existing regulations for new chemicals under the TSCA needed to be updated to match the amendments made in 2016. There was a need to enhance the efficiency of the EPA’s review process for new chemicals and reduce the need for redoing risk assessments. The proposed amendments to the regulations aim to address the identified problems. Changes include requiring EPA approval of low volume exemptions (LVE) and low release and exposure exemptions (LoREX) before manufacturing begins, excluding per- and polyfluoroalkyl substances (PFAS) from these exemptions, and declaring certain persistent, bioaccumulative, and toxic (PBT) chemical substances ineligible for exemptions based on EPA’s 1999 PBT policy. Procedural regulations are also being amended to align them with the amended TSCA Section 5, specifying EPA’s required determinations on each notice before manufacturing or processing can commence. The proposed amendments are expected to improve the efficiency and effectiveness of the EPA’s review process for new chemicals. By improving the initial information submitted in new chemical notices, the need for redoing risk assessments can be reduced, shortening the overall review time. The amendments also address issues related to low volume and low release and exposure exemptions, PFAS, and PBT chemical substances. The ComplianceXL team is your trusted partner when it comes to navigating regulatory updates and ensuring compliance. Staying compliant with the proposed TSCA amendments is more important than ever. It is our team’s responsibility to stay on top of regulatory changes, including proposed amendments to TSCA regulations that will align them with EPA’s review process and enhance the process. Our tailored solutions assist organizations in understanding the impact, evaluating current practices, and implementing necessary measures. Talk to one of our TSCA Compliance specialists today. FAQs Q: What are the proposed changes to the regulations for low volume exemptions and low release and exposure exemptions? A: The proposed changes require EPA approval of exemption notices before manufacturing begins, make PFAS ineligible for these exemptions, and declare certain PBT chemical substances ineligible based on EPA’s 1999 PBT policy. Q: How will the proposed amendments improve the EPA’s review process for new chemicals? A: The proposed amendments aim to reduce the need for redoing risk assessments by improving the initial information submitted in new chemical notices. This improvement will help shorten the review time. Q: What are the expected benefits of these proposed amendments? A: The proposed amendments are expected to enhance the efficiency and effectiveness of the EPA’s review process for new chemicals. They will streamline the assessment of new chemical substances, reducing the time required for reviews and improving the overall process.
Everything you need to know about the Ethylene Oxide (EtO) emissions regulation by EPA
The Environmental Protection Agency (EPA) has been working to regulate the emission of ethylene oxide (EtO) to protect public health and the environment. A highly reactive and flammable gas, EtO is used in the production of medical equipment, plastics, and textiles. Although it is an essential component of manufacturing, it has been identified as a carcinogen, making it a significant concern for environmental regulators. In the US, EPA proposes to regulate EtO emissions due to a number of reasons. According to the Environmental Protection Agency (EPA): It wasn’t until recently that the EPA updated the standards to reflect the latest scientific research on EtO’s health effects that it began regulating EtO emissions in the 1980s. EPA has issued new regulations governing EtO emissions in 2020, which have tightened the limits on emissions from sterilization facilities as well as other sources because of the regulation. As a result of the new regulations, communities near facilities that use EtO will be protected and the risk of cancer from prolonged exposure to the gas will be reduced. It is essential that the EPA regulates ethylene oxide emissions since they can cause respiratory problems, nausea, headaches, and other health issues. The implementation of updated regulations for EtO emissions has proven challenging for industries that use gas. Complying with regulations requires significant changes to production processes, which can be time-consuming and costly. Finding an alternative to EtO can also be challenging, especially if the alternative does not provide the same quality or functionality. However, reducing EtO emissions will have substantial long-term benefits, making changes necessary. For industries emitting EtO, collaboration with the EPA is crucial for finding solutions that meet business needs while meeting environmental regulations As the EPA updates its regulations, industries must stay informed and adapt to the new To protect public health and the environment, EtO emissions must be monitored and regulated continuously. The industries that may be affected by EPA regulation on Ethylene Oxide (EtO): Medicinal and pharmaceutical industries: EtO is an excellent sanitizer for clinical hardware and drugs that cannot be exposed to high temperatures or dampness. Medical devices such as catheters and sutures, as well as surgical instruments, are included in this category. Chemical industry: EtO is made by converting it as a precursor to ethylene glycol. This is used to make antifreeze, polyester fibers, and plastic bottles. It is also used to manufacture synthetics, like surfactants, cleansers, and glues. Agriculture: Apart from that, EtO can also be applied to some agricultural products that are susceptible to pests, fungi, or bacteria growth, such as grains and spices, to prevent the growth of insects, fungi, etc. Food packaging: Despite being less common, EtO can also be used to sterilize some food packaging materials. The term EtO is also used to describe a carcinogenic substance. Long-term use can lead to cancers like lymphomas and leukemia. Excessive use of this drug can also lead to headaches, breathing problems, dizziness, etc. The EPA has developed guidelines for risk management procedures to ensure the safety of environment, and consumers from the toxic emissions. Although it is imperative for manufacturing industries to be compliant, they struggle to meet both environmental and business needs. ComplianceXL helps organizations comply with environmental policies, reduce the social impact, and contribute to a healthier world by minimizing EtO emissions. Find out how this under regulation on EtO emissions affects you and what you need to do to stay compliant today by contacting an ESG Specialist. FAQs: 1. How does the EPA warn about ethylene oxide? An analysis by the Environmental Protection Agency showed that ethylene oxide (EtO) emissions from some commercial sterilizers contribute to elevated cancer risk. 2. How does EPA determine what is an acceptable risk? An organization’s OH&S policy and legal obligations have been taken into consideration when reducing risk.
Key updates to the Stockholm POP convention
The Stockholm Convention, an international treaty governing hazardous pollutants, adopted a decision to ban three persistent organic pollutants at the 11th session of the Conference of the Parties (COP) held in Geneva from 1 to 12 May 2023. A global ban is adopted on the production and use of the chemicals listed below: Methoxychlor UV-328 (CAS 25973-55-1) Dechlorane Plus Chemicals like these are persistent, bioaccumulative, and harmful to human health and the environment. Time-limited exemptions have been agreed upon for specific uses of UV-328 and Dechlorane Plus. The EU proposed methoxychlor in 2019 for inclusion in the Convention. Persistent organic pollutants (POPs) are carbon-based organic chemicals that accumulate in living organisms through bioaccumulation. POPs can cause cancer, allergies, and hypersensitivity. These chemicals can damage the nervous system, cause reproductive disorders, and are endocrine disruptors. Methoxychlor was once used to replace DDT against numerous insects and pests on crops, ornamentals, livestock, and pets. It is banned in the US and the European Union due to its toxicity, persistence, and bioaccumulation ability. UV-328 is a UV absorber that protects polymers from degradation under ultraviolet radiation. The chemical may affect the liver and kidneys in animal studies. UV-328 is the first non-halogenated chemical included in the Stockholm Convention. Dechlorane Plus is a chlorinated flame retardant used in adhesives, sealants, and polymers. They are widely used in motor vehicles, electrical and electronic equipment, aerospace, and defense. Regulations that control POPs have reduced levels of POPs in humans and the environment. The adoption of procedures and mechanisms for compliance with the Stockholm Convention in the field of POPs has marked remarkable achievements in 2 decades of work. For the first 12 chemicals on the POP list, concentrations measured in the air and in the human population have decreased and remain at low levels. Newly introduced POPs also show decreasing concentration levels. Several countries have called for labelling of products containing two plastic ingredients, while others oppose it. The scientific control committee of the convention plans to evaluate the possibilities of identifying POPs in products and waste. As a consulting firm,ComplianceXL assists companies in the areas of POP compliance and supplier declaration collection by providing consulting and training services. As part of our compliance and data management strategy, we also assist customers in regularly maintaining their supplier certificates and declarations in order to ensure that they are to date at all times. Frequently Asked Questions: 1. Do dechlorane plus and UV-328 have a time-limited exemption? Special exemptions for production and/or use for 5 years after the amendment’s entry into force. These applications will continue to be supported until 2044, or until the end of the articles’ life, whichever is first 2.What are persistent organic pollutants (POPs)? Persistent organic pollutants (POPs) are carbon-based organic chemicals that can accumulate in living organisms through bioaccumulation causing serious health hazards.
New PFAS Regulations and How to Stay Compliant
Polyfluoroalkyl substances (PFAS) are collectively known as poly-fluoroalkyl substances. Unlike natural substances, these chemicals are created by humans. Consumer products and industrial products have been containing PFAS substances for decades. Due to their toxicity to humans, animals, and the environment, the substances have come under increasing scrutiny since the early 2000s. To reduce exposure to PFAS, a variety of laws, policies, and regulations have been implemented in the United States and Europe. Maine legislature banned perfluoroalkyl and poly-fluoroalkyl substances in July 2021. As a result, PFAS was defined broader than those substances listed under the Toxic Substances Control Act (TSCA) of the United States Environmental Protection Agency (EPA). CompTox, the EPA’s list of more than 12,000 PFAS, is instead referred to in the proposed law. Manufacturers, distributors, and importers of these products in Maine must comply with the law unless an exemption has been granted. In addition to the new law, two provisions go into effect on January 1st, 2023. The following are some of them: To comply with federal regulations, manufacturers must report the amount of PFAS in their products. Despite the development of a database by the Department of Environmental Protection (DEP), reporting remains a necessity. The sale of carpets, rugs, and fabric treatments containing PFAS is prohibited. We do not include carpets or rugs that have been used. California Bill AB 1817 prohibits the sale, distribution, or offering for sale of food packaging containing PFAS chemicals. As of January 1st, 2023. The sale and distribution of new products containing PFAS chemicals will be prohibited by July 1, 2023. Toxic Substances Control Act (TSCA) Section 8(a)(7) is expected to be finalized by the Environmental Protection Agency in 2023. Since 2011, manufacturers and importers have been required to report on how PFAS are used in their products, production volumes, disposal, exposures, and hazards. Over 1,300 PFAS could potentially be covered by this rule, according to the EPA. By January 2023, five European Union states are expected to submit a proposal restricting all PFAS substances. Additionally, certain perfluoroalkyl carboxylic acids (C9-C14 PFCAs) will be prohibited under EU REACH beginning in February 2023. Additionally, the EU proposes a ban on the use of all PFAS in firefighting foams. ComplianceXL provides companies with PFAS compliance consulting services as well as vendor PFAS declaration collection services. Moreover, we also provide our customers with regular maintenance services in order to ensure that the certificates and declarations of their suppliers are accurate and current at all times. FAQs 1.What made the elimination of PFAS so important? Exposure to PFAS poses a serious threat to human health. There is a global contamination crisis due to it, which fuels biodiversity crises. 2.Why are PFAS widely used in products because of their performance attributes? Fluorinated polymers have excellent temperature stability, electrical insulation, and flame retardancy. Water-repellent and anti-fogging, fluorinated coatings are available.
EPA appeals SACC review of 1,4-Dioxane risk assessment under TSCA
The U.S. Environmental Protection Agency (EPA) is seeking nominations of expert reviewers to assist the Science Advisory Committee on Chemicals (SACC) with their review of the 2023 Draft Supplement to the 1,4-Dioxane Risk Assessment under the Toxic Substances Review Act (TSCA). SACC provides the US EPA with independent scientific guidance and direction regarding the methodologies, risk assessments, and pollution prevention measures and approaches for chemicals classified under TSCA. The Risk Analysis of 1,4-Dioxane is mainly to protect Human Health & Environment. EPA has reviewed 24 conditions for risk analysis which includes laboratory chemicals, adhesives, sealants, solvents, spray polyurethane foam, printing ink, and dry film lubricants. 1,4-dioxane is found in consumer products such as detergents and soaps. This review assesses the effects of 1,4-dioxane exposure on the environment, including surface water, groundwater, ambient air, and land. It also evaluates additional conditions of use where 1,4-dioxane is present as a by-product in industrial processes. The applications of 1,4-Dioxane in manufacturing and household products are: A solvent for cotton and textile processing Chemical manufacturing, and A coolant liquid in the automotive industry. EPA intends to make the 2023 Draft Supplement to the 1,4-Dioxane Risk Evaluation for public comment in June of 2023. This document will be reviewed with the public virtually by SACC in September 2023. SACC will announce registration instructions for the meeting in the summer of 2023. The EPA considers April 24, 2023 to be the last day for any other nominations. This nomination will be considered by 10 to 15 ad hoc reviewers who will help the SACC with its review. Which are all the substance or products that contains 1,4-Dioxane? In food supplements, food containing residues from packaging adhesive traces of 1,4-Dioxane can be absorbed. It is primarily used as a solvent in some manufacturing processes. Household Products such as – Shampoo, Baby lotion, cosmetic products, bath foam, etc. 1,4-Dioxane can be found in spermicidal sponges. What are the health effects of 1,4-dioxane exposure? Effects of 1,4-dioxane to human health and environment is depends on frequency of the exposure and how much percentage of 1,4-dioxane is present. Exposure to large amounts of 1,4-dioxane can cause kidney, liver damage and adverse nervous system effects. 1,4-Dioxane for short periods of time causes irritation of the nose, eyes, and throat in the human body. Conclusion: It is important to regulate and monitor 1,4-dioxane carefully to minimize its risks and impacts on humans as well as the environment. Once the thorough risk evaluation process mandated by TSCA is completed, EPA will make a final determination on whether a chemical substance will pose any unreasonably high risks to human health or the environment upon usage. This process will allow EPA to develop and implement necessary risk management procedures to ensure the safety of chemicals that will be sold on the market. ComplianceXL provides organisations with solutions to stay compliant and socially responsible by keeping up with regulatory updates from bodies such as EPA. Find out how this will affect your organization by talking to one of our regulatory compliance specialists today. FAQs: 1. What does the risk assessment for 1 4 dioxane entail? Based on a thorough analysis of the scientific evidence, the agency’s final conclusions on which conditions of use pose unreasonably high hazards to human health or the environment are included in the 1,4-dioxane risk evaluation. 2.Why is dioxane harmful? In addition to damaging the liver and kidneys, acute exposure to large concentrations of 1,4-dioxane vapors also causes irritation of the eyes, nose, and throat.
EPA Proposes TSCA to prohibit Methylene Chloride
To safeguard human health, the EPA proposed on April 20, 2023, to prohibit most methylene chloride applications. In the revised method established by the Frank R. Lautenberg Chemical Safety for the 21st Century Act passed in 2016, methylene chloride is the second chemical that is going through risk control in accordance with the revised method. Even though methylene chloride is clearly toxic to the body, exposure can result in severe health effects, even death. “For this reason, the EPA is taking action, proposing to outlaw most uses of this chemical, while enacting more rigorous regulations to reduce exposures elsewhere.” To safeguard employee health, workplace regulations are necessary. This historic proposed ban shows considerable advancement in our efforts to put new chemical safety safeguards in place. In addition, it takes long overdue steps to improve public health. Objective of this proposal To ensure that workers are not harmed when methylene chloride is used for its remaining consumer applications, the workplace must be protected by stringent safeguards. The use of methylene chloride in a variety of industrial and commercial applications should be outlawed. Regardless of how it is produced, processed, or distributed, the production, processing, and distribution of methylene chloride should be prohibited. Ensure that producers (including imports), processors, and wholesalers of methylene chloride inform the organizations they are supplying with methylene chloride of the disallowances and keep records of this information. Benefits/Effects/Impact Alternative products with “similar costs and efficacy… are generally available,” according to an EPA analysis. This historic ban proposal demonstrates significant progress in our efforts to implement new chemical safety safeguards and take long-overdue steps to improve public health protection. Similar to this, EPA is also recommending that particular uses of methylene chloride required by the National Aeronautics and Space Administration, the Department of Defence, and the Federal Aviation Administration continue with strict workplace controls because sufficient exposure reductions are possible in these highly sophisticated environments, thereby reducing risks to workers. Using exposure data from the Toxics Release Inventory over a six-year period, the EPA identified a small number of facilities as posing possible concerns to populations along fence lines. The restrictions in the EPA’s proposed rule would apply to the bulk of these facilities’ continuous methylene chloride usage, effectively removing any potential dangers to the nearby communities Conclusion: Compliance XL provides TSCA compliance consulting services and vendor TSCA declaration collections to companies. We also help businesses to maintain their suppliers’ certificates and declarations on a regular basis to ensure they are up-to-date as part of their compliance data management strategy. FAQs: 1. How does the Toxic Substances Control Act (TSCA) Section 6 work? Some chemicals are subject to import and export requirements under Section 6 of the Toxic Substances Control Act (TSCA). 2. How does TSCA Section 6 work? TSCA Section 6(a) requires EPA to address unreasonable risks of injury to health or the environment presented by a chemical substance under the conditions of use determined by the Administrator
Asbestos Exposure: Unraveling the Hidden Threats
A group of six naturally occurring, fibrous, silicate minerals known as asbestos appears chemically inert, or as close as possible to that. Most substances do not react with them, and neither do they dissipate nor burn. Chrysotile’s outer brucite layer loses magnesium in acidic and neutral aqueous solutions. Asbestos is a contaminant of water, air, and soil when it is used in construction, mining, demolition, and manufacturing activities. The asbestos contain long-lasting fibers that penetrate deeply into the lungs, resulting in mesothelioma, asbestosis, or lung cancer, and other illnesses. Therefore, several jurisdictions around the world have banned its use. Regulatory history In 1973, the Environmental Protection Agency prohibited spray-applied asbestos-containing insulation and fireproofing. Asbestos block insulation and asbestos pipe insulation were prohibited in 1975 by the Environmental Protection Agency. In 1989, the EPA issued a final rule under Section 6 of the Toxic Substances Control Act (TSCA) outlawing most asbestos-containing products. However, most of the original ban on the importation, manufacture, or distribution in commerce of most asbestos-containing products originally covered by the 1989 final rule was overturned in 1991. A final rule issued by EPA in April 2019 strengthens its ability to rigorously review an extensive list of asbestos products that have been removed from the market. The U.S. government had to approve the sale before it could be resold. As a result, the EPA now has the authority to prohibit the use of these products or impose limitations to protect public health. Types of Asbestos These can be divided into two groups: serpentine and amphibole. Amphibole Asbestos Amphibole asbestos fibers are straight and jagged. Crocidolite Amosite Anthophyllite Tremolite Actinolite Serpentine Asbestos Chrysotile asbestos is the only serpentine type, and this also known as “white asbestos”. Which Industries are affected by the asbestos ban? Industries involved in the manufacture of high-temperature products and materials will be affected. The asbestos ban may have an impact on businesses involved in mining, mineral processing, and construction. Construction products and machinery carry asbestos because it is an effective insulator. They become even more durable when asbestos is used in products like cloth, paper, cement, and plastic. Asbestos is regulated by EPA (Environmental protection agency), and the main priority is to protect the public from the adverse health effects of asbestos, a known carcinogen. asbestos was one of the first ten chemicals selected by the EPA to undergo risk evaluation under TSCA. The prevention of asbestos exposure is crucial in protecting people’s health. It is advised to obtain professional assistance with testing, risk assessment, and safe removal if you suspect asbestos in your surroundings. Conclusion: ComplianceXL provides organizations with the consulting to understand the guidelines setup by the EPA pertaining to asbestos risk assessments. As a team of compliance specialists, we evaluate each new regulation introduced by regulatory authorities and each revision made by these authorities from time to time. FAQs: Q: What is asbestos exposure? A: Asbestos exposure occurs when someone inhales or ingests tiny asbestos fibers, which can cause serious health problems. Q: What are the health risks of asbestos exposure? A: Asbestos exposure can cause lung cancer, mesothelioma, and other respiratory diseases.
First US drinking water standard for PFAS is proposed by the EPA.
The US Environmental Protection Agency issued a proposed rule that would establish legally enforceable drinking water standards for six per- and polyfluoroalkyl substances (PFAS). A significant step has been taken towards setting the first enforceable federal standard for PFAS under the federal Safe Drinking Water Act (SDWA). PFAS compounds have come to be known as “forever chemicals” due to their propensity to stay permanently in the environment and toxicity at incredibly low concentrations. EPA’s move is expected to profoundly affect treatment requirements for drinking water suppliers and remediation clean-up requirements across a wide swath of federal and state environmental programs. EPA’s Proposed Regulation National Primary Drinking Water Regulation for six PFAS would be established by the proposed rule: perfluorooctanoic acid (PFOA) perfluorooctane sulfonic acid (PFOS) perfluorononanoic acid (PFNA) hexafluoropropylene oxide dimer acid (HFPO-DA) and its ammonium salt perfluorohexane sulfonic acid (PFHxS) perfluorobutane sulfonic acid (PFBS) and mixtures of these PFAS. The regulation seeks to establish legally-enforceable Maximum Contaminant Levels (MCLs) for these six PFAS in drinking water in the low parts per trillion—often called “non-detect” levels. In addition to enforceable levels, The EPA has concluded that PFOA and PFOS are probably carcinogenic to humans and has recommended MCLGs of 0.0 ppt. For any combination of PFNA, PFHxS, PFBS, and GenX Chemicals, the proposed MCLG is HI 1.0. These six chemicals that have been used in a variety of industries and consumer products, including firefighting foams, nonstick cookware, and waterproof clothing. If adopted, the proposed regulation will require public water systems to monitor for these chemicals. In addition, systems will be required to alert the public and lessen PFAS contamination if levels rise above the suggested regulatory limits. According to EPA, if fully implemented, the rule will, over time, prevent thousands of fatalities and lower the number of significant PFAS-related diseases by tens of thousands. This action establishes nationwide protection from PFAS pollution for all people, including environmental justice communities. In accordance with SDWA, the EPA Administrator must also submit a maximum contaminant level goal (MCLG) at the same time as the NPDWR. The MCLG is a non-enforceable public health objective that designates a point below which no known negative health impacts are anticipated. EPA is authorized to implement an NPDWR under SDWA based on its determination that these six PFAS may have severe effects on health, occur regularly and at levels that create public health concerns in public water systems, and that, in the Administrator’s sole discretion, their regulation affords a considerable opportunity for health risk reduction for those served by public water systems. According to EPA, if the rule is completely enforced, it will stop thousands of deaths and tens of thousands of significant PFAS-related diseases. The proposed drinking water standard for PFAS by the EPA would potentially affect a wide range of industries that use or have used PFAS in their products or processes. Some of the industries that could be impacted by the new standard include: Firefighting: PFAS-containing firefighting foams have been widely used for training and fire suppression, leading to PFAS contamination of soil and water. Chemical manufacturing: PFAS are used in the production of various chemicals, including plastics, coatings, and textiles. Consumer products: PFAS have been used in a wide range of consumer products, such as nonstick cookware, waterproof clothing, and food packaging. Electronics: PFAS are used in the production of semiconductors and other electronics components. Aerospace: PFAS-containing materials have been used in the aerospace industry for various applications, including fire suppression and hydraulic fluids. Automotive: PFAS are used in the manufacturing of some automotive components, such as brake pads and windshield wiper blades. Military: PFAS-containing firefighting foams have been used extensively by the military for training and fire suppression, leading to contamination of soil and water at military sites. The new drinking water standard would likely lead to increased regulation and scrutiny of these industries and their use of PFAS. Some industries may need to find alternatives to PFAS to comply with the new standard. However, some environmental and public health advocates have criticized the proposal, arguing that the MCL is not stringent enough to fully protect public health. These advocates have called for a more protective standard of 1 ppt or lower. The EPA is currently accepting public comments on the proposal, and a final decision is expected in 2024.
New York joins in the club of PFAS substance’s ban in Apparels and Clothing
What is PFAS? PFAS, or per- and polyfluoroalkyl substances, are a group of manufactured chemicals that have been widely used in a variety of industrial and consumer products that leads to cause health problems such as cancer, liver damage, and developmental issues. As a result, US (United States) Environmental Protection act (EPA) has taken the necessary actions which as follows. Developing new drinking water standards for PFOA and PFOS, two of the most well-studied PFAS compounds. PFAS monitoring in public water systems is required New York PFAS restriction: New York also started banning of per-and polyfluoroalkyl substances which are comes up in clothes and apparels after California’s steps. The New York has banned the PFAS’s substances in food packaging will be effective from December 31st, 2022. After that on December 30th, 2022, Kathy Hochul who is New York Governor has signed a bill which will help to restrict the PFAS’s substances in Clothing and apparels effectively by December 31st, 2023. Even on last year Q3, California’s government has banned the PFAS substances in Clothing. The Golden States’ law also starts restricts the PFAS Substances on the Sales & Distribution on Clothing’s & apparels effectively by Jan 1st, 2025. Compared to California’s laws and some other similar laws, New York Law is less detailed. There are few details about finding the alternate with less toxic where are California’s Law prescribes the submission of ‘Certificate of Compliance’ by the distributors and manufactures. The main difference between the two laws is, both intended to restrict the use of PFAS Substances in Clothing where California also address the use of PFAS substance levels 100ppm by 2025 & 50 ppm by 2027. While other states laws also restrict the PFAS in garments which included California & Washington in addition to their existing regulations. And Vermont and Massachusetts states could affect the PFAS garments with pending legislation. However, this Law is not applicable to the Professional uniforms or the outerwear which are intended for extreme conditions. The detailed instructions will release to explain this law which will address both the dangerous firefighting and wet-weather conditions. However, for now, PFAS will provide double functionality in firefighter clothing, as it can be used as flame-suppression foams and fire-suppressive clothing. In addition, PFAS also have a water-resistance, which means the material does not become wet and heavy while being used. This bill going to ban the use of PFAS substances in all clothing’s by December 31st, 2023. A better understanding of the use of PFAS in apparel products is still developing, but New York apparel companies will need to ramp up their analysis in order to meet the December 31, 2023, compliance deadline.Speak with our PFAS specialists if you would like more information about these chemicals and the potential regulatory and litigation risks associated with them.
Everything about EPA draft scope for disposals of Asbestos
Asbestos Risk Evaluation Part 2: Supplemental Evaluation for Legacy Uses and Associated Disposals of Asbestos Published by EPA. On December 29, 2022, the U.S. Environmental Protection Agency (EPA) announced publication of the Draft Scope of the Risk Evaluation for Asbestos Part 2 (Draft Scope) for public comment). The EPA is currently evaluating the conditions of use of asbestos in Part 2 of the risk assessment, which will include evaluating other types of asbestos fiber, in addition to chrysotile, that were excluded from part 1 of the risk assessment due to their legacy uses and associated disposals, as well as any conditions of use of asbestos in talc and talc-containing products as discussed in this report. As part of the draft scope of their risk evaluation process, EPA plans to consider the conditions of use, hazards, exposures, as well as the Potentially Exposed or Susceptible Subpopulations (PESS) affected by this asbestos. EPA has started a 45-day public comment period on the Draft Scope so that the public can provide additional information, such as additional data, that may be helpful to EPA as it prepares the final scope of this risk assessment. The deadline for submitting comments to this draft scope is February 14, 2022. In 2019, EPA continued developing the risk assessment focused on chrysotile asbestos. EPA has decided to release the full asbestos risk assessment in two parts. As reported in our January 4, 2021 issue, EPA is expected to release its final risk assessment for Asbestos, Part 1: Chrysotile Asbestos in December of 2020. Therefore, this allows EPA to move expeditiously into risk management in order to address the unreasonable risks identified in Part 1. According to the EPA, the final Part 2 Risk Evaluation for Asbestos must be published by December 1, 2024, at the latest. In Part 2, the EPA plans to evaluate legacy uses of asbestos in the industrial, commercial, and residential sectors, as well as disposal practices associated with them. As part of the life cycle assessment, EPA will evaluate the conditions of use for the use and disposal phases. In addition to manufacture, processing, and distribution, where information implicates asbestos in talc, the conditions of use may also include the manufacture, processing, and distribution of talc. As stated in the Draft Scope of Work, EPA intends to evaluate human and environmental exposures to asbestos and to evaluate releases to the environment resulting from the conditions of use of asbestos. Additionally, more information will be gathered through systematic review, which will also supply additional context for expected exposures. As part of the Part 2 risk assessment, the EPA will first evaluate the following pathways, routes, receptors, and PESS: Occupational exposure: The EPA would like to evaluate worker and occupational non-user (ONU) exposure to asbestos via inhalation, dermal, and oral route as they relate to the use and disposal of asbestos, including any implicated conditions of use for talc that contains asbestos. Consumer and bystander exposure: Asbestos exposure will be evaluated from inhalation, dermal, and oral exposure for consumers and bystanders through the use of asbestos in construction, paint, electrical, metal products, furnishing, cleaning, and treatment care products; packaging, paper, plastic, toys, and hobby products, automotive, fuel, agriculture, and outdoor use products. In addition, the direct contact and/or oral contact of products or articles containing asbestos for consumers is not described by any other codes. We will also assess whether any conditions of use for talc containing asbestos have been implicated. General population exposures: It is planned that the EPA will evaluate asbestos exposure via oral routes from drinking water, surface water, groundwater, and soil; through inhalation routes from particulates found in ambient air, and through skin exposure; and via the dermal route from contact with drinking water, surface water, groundwater, and soil within part 2 of the risk evaluation. PESS: As part of the risk assessment, EPA plans to include children, workers, ONUs, consumers, people who smoke, and bystanders as potential receptors and PESS, as well as any other PESS identified in the screening and evaluation of reasonably available information; and Environmental exposure: Within the scope of Part 2, the EPA plans to evaluate exposure to asbestos both for aquatic and terrestrial receptors within the scope of the conditions of use. ComplianceXL offers strategic, business-oriented advice to the global chemical industry. It is our goal to assist large and small chemical companies whose activities and products may be subject to EPA’s broad chemical regulatory authority under the TSCA and state legislation on chemicals. Our global compliance experts are here to help you with any questions you may have.