Tuesday, December 1, 2020

California Considers Listing Titanium Dioxide Nanoparticles and Other Chemicals as Reproductive Toxicants

California’s Office of Environmental Health Hazard Assessment’s (OEHHA) Proposition 65 Developmental and Reproductive Toxicant Identification Committee (DARTIC) will hold a virtual public meeting on Dec. 10 to consider comment and review its Prioritization Document where it considers classifying 22 chemicals as reproductive toxicants for the purpose of labeling under Proposition 65 (Prop 65). Titanium dioxide nanoparticles —  ultrafine particles 1 – 100 nanometers (nm) in diameter — are among the chemicals under OEHHA’s consideration for Prop 65 listing.

If OEHHA finalizes listing, manufacturers of products containing one or more of these chemicals must provide warnings on product labels within one year. Under Prop 65, individuals must provide warnings prior to exposure to a chemical identified by the State of California to cause cancer or reproductive harm. The duty to warn applies to most individuals causing an exposure, including product manufacturers, employers and individuals causing exposures in an affected area. Prop 65 requires the State of California maintain a list of chemicals that are known to the State to cause cancer, birth defects or other reproductive harm, or both. The list includes over 900 chemicals since it was published in 1987.

The state can add chemicals to the Prop 65 list using four mechanisms: 1) the State’s qualified expert mechanism; 2) formally required to label mechanism; 3) labor code listing mechanism; and 4) authoritative body mechanism.

Last month, ACA filed comments with OEHHA urging the agency not to list titanium dioxide nanoparticles under Prop 65.

ACA Comments

In its comments, ACA notes that paint manufacturers may use nanoscale titanium dioxide as a filter for ultra-violet light to protect binding agents in a paint matrix; however, ACA underscored that the extent of use in paints is unknown and that it may not be common.

Because no studies associate reproductive toxicity with use of products containing nanoscale titanium dioxide, ACA asserted its belief that a Prop 65 listing is not supported at this time. This is especially true for use in paint products, since any nanoscale material is bound in a matrix and rendered unavailable during use. Any releases from weathering, sanding, demolition or disposal are expected to be negligible.

Particles bound in a paint matrix do not pose a hazard

ACA urged DARTIC to consider that wetted mixtures, such as paint, containing hazardous chemicals typically pose no hazard. OEHHA has recognized that particles bound in a paint matrix do not pose a hazard during application. Studies cited in the prioritization document do not support the proposition that nanoscale titanium dioxide in paint would increase the likelihood of reproductive toxicity in users of paint products. OEHHA’s listing of crystalline silica and titanium dioxide as a carcinogen in Proposition 65, recognize that chemicals bound in a paint matrix do not pose a hazard. In considering availability for exposure of titanium dioxide, the International Agency for Research on Cancer (IARC) recognizes that “No significant exposure to primary particles of titanium dioxide is thought to occur during the use of products in which titanium dioxide is bound to other materials, such as in paints.”

ACA also noted that IARC reached a similar conclusion when considering carcinogenicity of carbon black: “End-users of these products (rubber, ink or paint) are unlikely to be exposed to airborne carbon black particles, which are bound within the product matrix.”

As such, ACA asserts that listing titanium dioxide nanomaterials for use in paint products
under Prop 65 is unwarranted.

Nanoscale titanium dioxide does not pose a significant hazard during abrasion

ACA stressed to OEHHA that any concern related to particles in wetted mixtures usually occur from sanding and abrasion after application. OEHHA’s listing of titanium dioxide and crystalline silica as Proposition 65 carcinogens is limited to “airborne, unbound particles of respirable size.” Moreover, since particles are bound in a matrix, any respirable particles typically do not contain pure form of the particle at issue, minimizing any risk posed by that chemical.

ACA pointed to a study that considers hazards associated with nanoscale titanium dioxide in paint particles where the authors conclude that hazards of nanoscale titanium dioxide in dried paint particles cannot be predicted based on hazards of pristine nanoscale titanium dioxide. The authors also note that amounts of nanoscale titanium dioxide from dried paint particles are negligible.

Specification of particle dimensions would assist in identifying products with nanoscale titanium dioxide

For clarity, ACA suggested that OEHHA harmonize California’s definition of nanoscale titanium dioxide with particle parameters identified in the U.S. Environmental Protection Agency’s (EPA) Nanoscale Materials Reporting Rule. The EPA definition specifies that:

  • Particles manufactured or processed in a form where any particles, including aggregates and agglomerates, are in the size range of 1-100 nanometers (nm) in at least one dimension; and
  • Are solid at 25 °C and standard atmospheric pressure.

Companies applied this definition in 2017 when identifying reportable products under the rule. Should DARTIC recommend listing, harmonizing California’s definition would assist companies that are already familiar with USEPA’s definition. U.S. EPA also provides some additional clarity by noting particle size must apply to at least one dimension.

For the aforementioned reasons, including insufficiency of studies indicating reproductive toxicity of nanoscale titanium dioxide as used in products, ACA urged DARTIC not to recommend listing nanoscale titanium dioxide under Prop 65 at this time.

Contact ACA’s Riaz Zaman for more information.

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from American Coatings Association https://www.paint.org/titanium-dioxide-oehha/
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ACA Publishes Member Guidance on USMCA Rules of Origin

ACA has developed a guide for members to help them navigate the Rules of Origin duties under the United States – Mexico – Canada Trade Agreement (USMCA). The USMCA is a regional trade agreement that eliminates barriers in trade and facilitates cross-border movement of goods and services between these three parties. USMCA officially went into force on July 1, 2020, replacing the previous trade agreement, the North American Free Trade Agreement (NAFTA).

The USMCA provides for duty-free trade between signatory countries of goods that would normally be subject to import duties, so long as the goods meet the USMCA’s Rules of Origin. Compliance with these rules means that the goods will be considered “originating” in the territory of the three signatory countries.

Notably, the USMCA permits duty-free trade only for products that “originate” within the territory of the signatory countries. The agreement’s product-specific rules of origin must be applied to determine whether goods, including paint and coating products, meet the requirements for originating status. Proper understanding of these rules is crucial to obtaining duty-free treatment for products shipped between North American countries, and documenting claims to such treatment.

ACA’s guidance focuses specifically on applying the Rules of Origin. It includes examples and explanations for how to apply these rules while engaging in cross-border trade, and is intended to aid understanding compliance with the USMCA Rules of Origin and its practical application.

ACA members may access the guide here. To access this guidance, please use your username and password for the ACA website. If you don’t have login credentials, contact ACA at login@paint.org.

Contact ACA’s Heidi McAuliffe for more information.

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from American Coatings Association https://www.paint.org/usmca-rules-origin/
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EPA Seeks Comment on Draft Handbook for the Integrated Risk Information System (IRIS)

On Nov. 10, the U.S. Environmental Protection Agency (EPA) opened a 90-day public comment period on its Draft ORD Staff Handbook for Developing Integrated Risk Information System (IRIS) Assessments. The IRIS program is operated by EPA’s Office of Research and Development (ORD). ORD takes a multidisciplinary and decentralized approach by consulting with multiple organizational divisions. Since the 1980s, IRIS has reviewed the toxicity data on chemicals in commerce and the environment and set hazard benchmarks, including oral reference doses (RfDs), inhalation reference concentrations (RfCs) and cancer potency factors.

IRIS assessments incorporate public input and expert peer review during development. Systematic review principles are implemented to improve the rigor, transparency, and coherence of IRIS assessments. The 280-page draft IRIS Handbook outlines 13 steps and procedures for the program’s staff to develop chemical hazard assessments.

The draft handbook does not supersede existing EPA risk assessment guidelines and does not serve as guidance for other EPA programs. It is intended to be a “living document”; updates will be based on emerging science and experience gained through its application. Ongoing assessments developed with previously established procedures may not reflect all the approaches or procedures as described in the draft handbook.

EPA is accepting comments through Feb. 10, 2021. Comments may be submitted here.

Procedures for Staff Developing IRIS Assessments

The draft IRIS Handbook delineates the 13 steps and procedures for program staff to develop chemical hazard assessments, as follows:

  1. Scoping of IRIS assessments
  2. Problem formulation and development of an assessment plan
  3. Protocol development for IRIS systematic reviews
  4. Literature search, screening, and inventory
  5. Refined evaluation plan
  6. Study evaluation
  7. Organizing the hazard review: approach to the synthesis of evidence
  8. Extraction and display of study results of health effects and toxicities from epidemiology and toxicology studies
  9. Analysis and synthesis of human and experimental animal data
  10. Analysis and synthesis of mechanistic data
  11. Evidence integration
  12. Hazard considerations and study selection for deriving toxicity values
  13. Derivation of toxicity values

Notably, the IRIS Handbook implements recommendations and input from the National Academy of Sciences, Engineering and Medicine, EPA agency reviewers, other federal agencies, EPA’s Science Advisory Board, and workshops involving input from experts in systematic review.

IRIS Assessments Role in Risk Assessment

Risk assessment is a four-step process described by the National Research Council in 1983 as “the characterization of the potential adverse health effects of human exposures to environmental hazards.” Characterizing risk involves integrating information on hazard, dose-response, and exposure into a risk characterization.

 An IRIS assessment includes the first two steps of the risk assessment process:

  1. Hazard identification, which identifies credible health hazards associated with exposure to a chemical, and
  2. Dose-response assessment, which characterizes the quantitative relationship between chemical exposure and each credible health hazard. These quantitative relationships are then used to derive toxicity values.

EPA’s program and regional offices identify human exposure pathways and estimate the amount of human exposure under different exposure scenarios (exposure assessment). Then they combine their exposure assessment with the hazard information and toxicity values from IRIS to characterize potential public health risks (risk characterization).

Contact ACA’s Riaz Zaman or Scott Braithwaite for more information.

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from American Coatings Association https://www.paint.org/iris/
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Monday, November 30, 2020

R.E. Carroll Inc. Passes NACD Responsible Distribution Verification®

R.E. Carroll Inc. recently announced that it has successfully passed its NACD Responsible Distribution® verification for the current three-year cycle. Responsible Distribution is the National Association of Chemical Distributor’s (NACD) third-party-verified environmental, health, safety, and security program that allows members to demonstrate their commitment to continuous performance improvement in every phase of chemical storage, handling, transportation, and disposal.

“Responsible Distribution is critical to the chemical distribution industry’s ability to safely deliver more than 30 million tons of product every year,” said NACD President Eric Byer. “Through their successful verification, R.E. Carroll Inc. and its senior leadership have committed to the continuous improvement in the chemical distribution industry’s responsible management and handling of chemicals that ensures NACD members effectively support the industries America relies on most, like agriculture, healthcare, oil and gas, manufacturing equipment, and many others.”

The Responsible Distribution program requires on-site, third-party verification of facilities against a set of guiding principles, including strict adherence to laws and regulations and participation with interested entities in creating responsible laws, regulations, and practices to help safeguard the community, workplace, and environment.

According to NACD, participation in Responsible Distribution has significant benefits, including lower instances of safety and environmental incidents, better documentation of company policies, better communication with local communities, reduced audit time and costs, and increased credibility.

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from American Coatings Association https://www.paint.org/r-e-carroll-inc-passes-nacd-responsible-distribution-verification/
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Dow Report Highlights Olympic Movement Partnership’s Carbon-Reduction Efforts

Dow recently released its 2020 Carbon Partnership Report, detailing the carbon-reduction impact of more than 20 carbon-mitigation projects in more than 12 countries done in collaboration with the Olympic Movement. These projects are part of partnerships with the International Olympic Committee (IOC) and organizing committees of the Sochi 2014 Olympic Winter Games and the Rio 2016 Olympic Games.

These carbon partnerships have reportedly delivered third-party-verified emission reductions of more than 5.1 million metric tons of carbon dioxide equivalent (CO2e) since launched. The report outlines how Dow’s partnerships with the Olympic Movement have brought new levels of science, innovation and collaborations across key value chains, going beyond business as usual to advance the adoption of technologies and practices that can build a low-carbon economy.

“Achieving a low-carbon economy requires new ways of collaborating across value chains, as well as investments in capacity building and low-carbon technologies,” said Nicoletta Piccolrovazzi, global technology & sustainability director, Dow Olympic & Sports Solutions. “This report provides verified proof of how collaborations that focus on a clear and common goal and go beyond business as usual can create successful, scalable solutions. Our projects go beyond purchasing carbon offsets to encourage behavior changes that result in real emission reductions.”

Environmental Resources Management (ERM) provided third-party verification of projects against the Dow Climate Solutions Framework and verified the greenhouse gas-emission reductions resulting from the projects and assigned to specific footprint owners. Carbon reductions within the report are validated as of September 2020. According to the report, each of Dow’s carbon partnerships with the Olympic Movement met and exceeded the original emission scope target:

  • The Dow Sochi-Carbon Partnerships resulted in climate benefits amounting to 2.8 million metric tons of CO2e, more than five times its commitment to Sochi 2014.
  • The Dow-Rio Carbon Partnership has delivered more than 1.5 million metric tons of CO2e to date–exceeding Dow’s commitment to balance the footprint of hosting and staging the Games. According to Dow, it is also leaving a legacy of low-carbon technologies in Latin America.
  • The Dow-IOC Carbon Partnership has delivered more than 850,000 metric tons of CO2e to date, exceeding the IOC’s goal to be a carbon-neutral organization.

Dow and the IOC’s initiative encourage global sports organizations, both within and outside of the Olympic Movement, to incorporate tangible climate action into their operations and events.

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from American Coatings Association https://www.paint.org/dow-report-highlights-olympic-movement-partnerships-carbon-reduction-efforts/
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EP Minerals Taps Lintech as its Distribution Partner for Filtration and Filler Products

EP Minerals, a U.S. Silica Company, signed an agreement with Lintech International LLC, a national distributor of specialty chemicals, to manage its portfolio of filtration and filler products in specific U.S. markets. The agreement went into effect Sept. 2.

Lintech has been awarded an exclusive territory in the Southeastern U.S. for fine filler products and non-exclusive territory for filtration products. The agreement also includes non-exclusive sales regions in the Southwest, West and Midwest, where Lintech will represent filler products. According to the companies, the product portfolio includes EP Minerals’ wide range of diatomaceous earth and perlite filtration and filler products, including Celatom®, CelaPerl® and CelaBrew®.

The agreement also provides opportunities for the distribution of U.S. Silica’s White Armor® cool roof granules and EverWhite™ cristobalite products, which are used in numerous applications, including solar reflective roofing, engineered quartz countertops, and high-performance coatings.

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from American Coatings Association https://www.paint.org/ep-minerals-taps-lintech-as-its-distribution-partner-for-filtration-and-filler-products/
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Archroma Tops List of Industrial Chemical Companies Driving Supply Chain Transparency

Archroma was recently ranked No. 1 in the “industrial chemicals” list published by the Institute of Public & Environmental Affairs (IPE) for driving transparency in their supply chain. The specialty chemical company also made the Top 50 of companies in IPE’s Green Supply Chain CITI Evaluation, which assesses brands on the environmental management of their supply chains in China. IPE is a non-profit environmental research organization registered and based in Beijing.

Headquartered in Reinach, Switzerland, Archroma is a global provider of dyes and specialty chemicals serving the coatings, adhesives, and sealants markets, as well as the textiles, and paper and packaging markets.

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from American Coatings Association https://www.paint.org/archroma-tops-list-of-industrial-chemical-companies-driving-supply-chain-transparency/
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