Cambridge Isotope Laboratories, Inc.
isotope.com
December 2010
The Standard
ENVIRONMENTAL CONTAMINANT STANDARDS
EPA Takes Action on Chemicals Used in Dyes, Flame Retardants,
and Industrial Detergents
In August 2010 the US EPA took another step forward with its
plan to address the potential health risks associated with chemical
pollutants in the environment. EPA Administrator Lisa Jackson
announced new action plans for hexabromocyclododecane
(HBCD), nonylphenol and nonylphenol ethoxylates (NP/ NPEO)
and benzidine dyes. These plans join previously developed action
plans for bisphenol A (BPA), perfluorinated compounds (PFCs),
polybrominated diphenyl ethers (PBDEs), phthalates, and short
chain chlorinated paraffins (SCCPs).
EPA’s existing chemical programs address pollution prevention, risk
assessment, hazard and exposure assessment and characterization,
and risk management for chemical substances in commercial use.
As part of the existing chemicals program, the EPA’s action plans
define a series of options the EPA can pursue toward reducing the
risks associated with these chemical pollutants, with the authority
of such programs as the Toxic Substances Control Act (TSCA) and
Pollution Prevention Act behind them. Some of these action plans
may include adding the compounds to the new Chemicals of
Concern list, enforcing new use rules for the compounds and
imposing new requirements for reporting under the Toxic Release
Inventory (TRI). The EPA may even opt to ban or limit the
production of chemicals under these new programs.1
Hexabromocyclododecane
Hexabromocyclododecane (HBCD) is a large-production-volume
flame retardant used primarily in expanded polystyrene foam (EPF)
in the building industry, but it is also found commonly in consumer
products. HBCD has demonstrated characteristics of persistence in
the environment, biomagnifications in the food web, and toxicity
to aquatic organisms, according to EPA.
EPA is considering the following actions regarding HBCD:2
1) Adding HBCD to the Chemicals of Concern List.
2)Designating HBCD as a significant new-use compound,
requiring manufacturers or processers to notify EPA before any
manufacturing or processing.
3)Potentially regulating HBCD to limit or ban manufacturing,
processing, distributing, or using HBCD.
4)Listing HBCD in the Toxics Release Inventory (TRI), requiring
manufacturers or importers to list environmental release
information.
5)Conducting a “design for the environment” plan, encouraging
users to move away from the use of HBCD in preference of
other alternatives.
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With the new action plan EPA joins both the European Chemicals
Agency which in 2008 added HBCD as a substance of very high
concern (SVHC) in its Registration, Evaluation, Authorization and
Restriction of Chemicals (REACH) program, and the United Nations
Environment Program (UNEP) which in August of 2010 submitted
HBCD to its POPs review committee for inclusion in the list of
Stockholm Convention POPs chemicals.
Nonylphenol and Nonylphenol Ethoxylates
Nonylphenol (NP) is primarily used in the manufacture of
nonylphenol ethoxylates (NPEO). NPEOs are non-ionic surfactants
used in a wide variety of cleaning and degreasing applications,
which generally allow for release into the aquatic environment.
As with most compounds on EPA’s action plans list, these
compounds can be classified as persistent, bioaccumulative and
toxic to a variety of organisms. NPEOs, while toxic themselves,
often break down in the environment to the more toxic NP.
In the past, NPEOs were commonly used in household detergent
products, but with help from the detergent manufacturers this
practice has been eliminated. Commercial and industrial use of
these compounds, however, still persists.
EPA is considering the following actions regarding NP and NPEO3:
1)Support and encourage the ongoing voluntary phase-out of
NPEs in industrial laundry detergents.
2) Proposing a significant new-use rule (SNUR) under TSCA
section 5(a) and a test rule for NP and NPEs under TSCA
section 4. The proposed SNUR would designate use of NPEs
in detergents and cleaning products a significant new use,
which would require submission of a significant new-use
notice (SNUN) to EPA.
3) Initiating rulemaking under TSCA section 5(b)(4) to add NP
and NPEs to the Chemicals of Concern list that present
or may present an unreasonable risk of injury to health
or the environment.
4) Add NP and NPEs to the TRI, which would require facilities
to report releases of these chemicals to the environment.
Benzidine Dyes
The EPA action plans for benzidine dyes cover 48 dyes derived
from benzidine and related compounds 3,3’-dichlorobenzidine,
3,3’-dimethylbenzidine, and 3,3’-dimethoxybenzidine. Benzidinebased and congener-based dyes are used in the production of
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ENV_NEWS_EPA
12/10 Supersedes all previously published literature
The Standard December 2010
ENVIRONMENTAL CONTAMINANT STANDARDS
textiles, paints, printing inks, paper and pharmaceuticals.4
Benzidine and dyes metabolized to benzidine are classified
as carcinogenic, while the related compounds and dyes that
metabolize to them are classified as reasonably expected to
be carcinogenic.
References (web links)
1. US EPA Existing Chemical Program: Existing Chemicals
2. US EPA Existing Chemical Program: HBCD
3. US EPA Existing Chemical Program: NP/ NPEO
4. US EPA Existing Chemical Program: Benzidine Dyes
5. US EPA Existing Chemical Program: Benzidine Dyes
EPA is considering the following actions regarding benzidinebased dyes:5
1)Adding four benzidine-based dyes to an existing TSCA section
5(a)(2) significant new-use rule (SNUR). A SNUR requires
manufacturers to submit an application to the agency for
review.
2)Establishing a new TSCA section 5(a)(2) SNUR for benzidine
congener-based dyes, including 44 specific such dyes.
3)Proposing to eliminate the article exemption applied to SNURs
to address potential concerns for exposure to these dyes on
imported finished textiles.
4)Initiating action under TSCA section 6, if EPA learns that these
dyes are present in imported finished textiles.
5)Consider additional regulatory action, if EPA determines that
there are other ongoing uses for these dyes and needs to
obtain information necessary to determine whether those
uses present concerns which need to be addressed.
Cambridge Isotope Laboratories, Inc., 3 Highwood Drive, Tewksbury, MA 01876 USA
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fax: +1.978.749.2768
1.800.322.1174 (North America)
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ENV_SPOT_EPA
12/10 Supersedes all previously published literature