SVHCs & Consumer Products

There are some identified consumer products in a supply chain that contain potentially harmful chemicals, substances, and materials. Evaluation of substances of very high concerns (SVHCs) is very important.

Federal, State, and local government agencies are working in finding the harmful effects of such chemicals and searching the safe alternatives of these products containing these chemicals as one of the ingredients. Regulatory actions are required for process development, related set of regulations, and management systems at all levels of the supply chain.

Some of the known potentially harmful consumer products in the market are: some non-stick cookware, flea and tick products, air fresheners, mothballs, oven cleaners, furniture polishes, stain removers, toilet bowl cleaners, gas heaters, methylene chloride as a solvent in the food supply and in paints, and triclosan an ingredient used in over 2000 consumer products including some toothpastes, antibacterial soaps and body lotions.

These products have effects when used by the consumers via main routes of entries as Inhalation (lung or respiratory), Ingestion (gastrointestinal), and dermal (skin contact or absorption lotions) and rarely by ingestion or through eyes.

In March 2012, the US Occupational Safety and Health Administration (OSHA) announced that the Hazard Communication Standard (HCS) had been revised to align with the European Union (EU)’s Globally Harmonized System (GHS) of Classification and Labeling of Chemicals. The GHS has been adopted in most of the countries worldwide. It is the main chemical hazard communication standard (HCS) that has taken into consideration all the current requirements needed worldwide with some amendments of their local and new regulations or standards as necessary to make it workable globally.

All hazardous substances and mixtures were classified and labeled in accordance with the new HCS from June 1, 2015 based on the GHS-Revision three along with labeling standard elements and the Safety Data Sheets (SDSs) of 16-sections of the GHS SDSs. The other Federal agencies like the Department of Transportation (DOT), the Environmental Protection Agency (EPA), and the Consumer Products Safety Commission (CPSC) were involved and adopted some of the elements of the GHS.

The U.S. Federal chemical regulation law known as the Toxic Substances Control Act (TSCA) requires the U.S. EPA to keep a list of all chemicals manufactured or processed in the United States. There are more than 90,000 chemicals in commerce in the U.S along with the production of synthetic chemicals according to the Society of Chemical Manufacturers and Affiliates (SOCMA) reports.

The U.S. EPA and the EU’s Registration, Evaluation, Authorization, and Registration of Chemicals (REACH) have listing of chemicals and substances of very high concerns (SVHCs) and their related regulations.

In the U.S. the OSHA and the EPA, and the EU’s Chemical Agency (ECHA) are responsible for regulatory implementation and responding to the adopted regulations to protect public health and or the environment and maximize the acceptable use and their acceptable alternatives of least concerns or elimination the hazardous product totally. It is a lengthy process or research of finding suitable alternatives and their implementation in the consumer supply chain worldwide. All these actions have an impact on businesses and in the consumer supply chain.

Methylene Chloride as Solvent in the Supply Chain

Methylene chloride is used in many different types of consumer products, may be present in water, air, as household items or in groundwater and soil.

Methylene chloride is a known paint stripper, and a degreaser (dissolves grease). It is also present in the food supply because it is used to decaffeinate coffee and tea, and to prepare other types of flavorings.
In an industrial environment, methylene chloride is used as an aerosol spray propellant, and therefore as a blowing agent for polyurethane foams. (Commonly found in mattresses and furniture.) Also, it is found in the garment printing industry to remove heat sealed garment transfers.

Methylene Chloride Exposures

Inhalation hazards are the main concern because methylene chloride is extremely volatile. Upon exposure, it can cause dizziness, fatigue, nausea and headaches. It is broken down by the body to form carbon monoxide, which can lead to carbon monoxide poisoning and ultimately death. Finally, it is also a potential carcinogen.

Recently, the California’s Department of Toxic Substances Control (DTSC) has issued guidance for complying with its regulations regarding paint removers containing methylene chloride, after the US EPA issued a rule banning the products for consumer uses. The DTSC designated paint and varnish removers containing methylene chloride as priority products under its Safer Consumer Products program being effective as of January1, 2019 this triggered the requirement for any manufacturer selling these products in California to submit a notification by March 4, 2019.

Paint or Varnish Strippers Containing Methylene Chloride

DTSC has adopted regulations to list paint or varnish strippers containing methylene chloride as a Priority Product. Effective January 1, 2019, manufacturers of this product (see final regulations text for full description of the Priority Product) must notify the Department by March 4, 2019. To submit a Priority Product Notification, register on the Safer Consumer Products Information Management System, Cal SAFER, and submit a notification.

DTSC is taking this action to protect workers and consumers from exposure to methylene chloride that could occur during normal use of paint or varnish strippers containing methylene chloride. Inhalation and dermal exposure to methylene chloride is associated with adverse health effects, including:

  • cancer of the brain
  • liver and biliary tract
  • central nervous system depression
  • intoxication
  • unconsciousness

Numerous deaths have been reported in workers and consumers who were exposed to methylene chloride during use of paint or varnish strippers.

According the news release from the EPA’s Chemical Safety and Pollution Prevention office while banning consumer sales of methylene chloride paint removers, protection notification it is stated.

Paint removal products containing methylene chloride will not be able to be sold at any retail or distribution establishments that have consumer sales, including e-commerce sales. Those prohibitions start 180 days after the effective date of the final rule, which provides time for establishments selling this chemical to consumers to come into compliance with EPA’s ban. EPA expects that many suppliers will implement the rule much sooner. To the extent that consumers want to avoid the unreasonable health risks, consumers should not use methylene chloride for paint and coating removal.

For further info on this news release, visit the web page at: https://www.epa.gov/newsreleases/epa-bans-consumer-sales-methylene-chloride-paint-removers-protecting-public.

 

References:
  • The US EPA’s News Release, bans the use of Methylene Chloride in consumer paint removal products web page at: https://www.epa.gov/newsreleases/epa-bans-consumer-sales-methylene-chloride-paint-removers-protecting-public.
  • California’s Office of Environmental Health Hazard Assessment (OEHHA), web page at: https://oehha.ca.gov/.
  • Paint or Varnish Strippers Containing Methylene Chloride, web page at: https://dtsc.ca.gov/scp/paint-or-varnish-strippers-containing-methylene-chloride/
  • Letter of DTSC to Refs about Paint & varnish Removers containing Methylene Chloride, web page at: https://dtsc.ca.gov/wp-content/uploads/sites/31/2019/05/Letter-to-REs-about-Paint-and-Varnish-Removers-Containing-Methylene-Chloride.pdf

 

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