From: Barbara_Buchner, INDSPEC Chemical Corporation
Sent: Tuesday, January 18, 2011 12:13 PM
To: Messing, Rita (MDH)
Subject: Minnesota Department of Health - Chemicals of High Concern List
Dear Dr. MessingI spoke with Dr. Hillary Carpenter at the Fall Meeting of the SCHC. Dr. Carpenter was presenting
information regarding the hazards of endocrine disruptors and I was looking for a contact within
the Minnesota Department of Health to discuss a substance we produce, Resorcinol (CAS No.
108-46-3), which is listed on MDH's 'Chemicals of High Concern' List, July 1, 2010. Dr. Carpenter
recommended that I contact you.
INDSPEC Chemical Corporation is one of three major producers of Resorcinol and the only US
producer. However, we contact you not only as a manufacturer, but also as a member of the
Resorcinol Task Force (RTF), which is a consortium that has been in place for over ten years,
dealing with regulatory matters surrounding this substance. These include submission of data
under the EPA HPV Challenge program, a TERA panel review, a CICAD submission, a REACH
registration and a SIAR submission - to name a few. Specifically, the RTF, as well as the
Resorcinol Reach Consortium (RRC), has expended many dollars and resources to develop data
to address any human health, or environmental effects and specifically to address any potential
thyroid effects related to resorcinol.
Although Resorcinol is an HPV chemical, human exposure is considerably low because the major
applications involve production of tires and manufactured rubber goods. The substance has
been used in commerce for over a hundred years with low health concerns. A reversible thyroid
effect relating to a specific, nonregulated application in the 1950's, we believe initiated its
inclusion as a potential endocrine disruptor. Without too much further information, I have
attached a paper that the Task Force is presenting at an upcoming RAPRA Conference next
month. I have been waiting for this paper to be finalized to provide it to you because I believe it
provides the background, as well as the context, concerning resorcinol as a potential endocrine
disruptor.
We have attempted to be proactive and deal with the various lists emerging in Europe. With the
developing policies regarding improving safety of consumer and children's products here in the
US, we feel that it is best to be proactive with regulators here as well. Therefore, I would like to
speak to you concerning the specifics of the information we have provided here and the details
surrounding inclusion of resorcinol on the MDH List, as well as ascertain the status of your
Priority Chemicals List going forward. I would be happy to meet with you in person or speak by
phone. My contact details are shown below. If there is someone else in your organization that I
need to speak with, please advise.
We thank you for your time concerning this important matter.
Regards,
Barbara Buchner
Barbara B. Buchner
Vice President
INDSPEC Chemical Corporation
Email received by:
Minnesota Department of Health
Site Assessment and Consultation Unit
651-201-4899
[email protected]