Detoxing Manufacturing: Part I

People exposed to toxins in sufficient concentrations and durations have an increased chance of getting cancer or experiencing other serious health effects. These health effects can include damage to the immune system, as well as neurological, reproductive (e.g., reduced fertility), developmental, respiratory, and other health problems, according to the U.S. Environmental Protection Agency (EPA).

In addition to polluting the air, some toxins such as mercury can deposit onto soils or surface waters, where they are taken up by plants and ingested by animals and are eventually magnified up through the food chain. Like humans, animals may experience health problems if exposed to sufficient quantities of air toxins over time.

Most air toxins originate from human-made sources, according to the EPA, including factories, refineries, power plants, and some building materials and cleaning solvents, as well as cars, trucks, and buses.

Intuitive reasoning indicates that one of the most effective ways to keep harmful toxins out of the air we humans breathe, the food we eat, the water we drink, and the materials we touch is to eliminate them from becoming part of products we use at the source—during manufacturing.

The EPA regulates the production and distribution of industrial and commercial chemicals to ensure that chemicals made available for sale and use in the U.S. do not harm human health or the environment. Laws written by Congress provide the authority for the EPA to write regulations to control human and environmental exposure to hazardous substances.

They include the Clean Air Act, Clean Water Act, EO 13045: Protection of Children, Environmental Health Risks and Safety Risks, and the Safe Drinking Water Act. The Toxic Substances Control Act (TSCA) addresses the manufacturing, processing, distribution, use, and disposal of commercial and industrial chemicals. The Pollution Prevention Act (PPA) establishes pollution prevention as the national policy for controlling industrial pollution at its source. The Department of Transportation’s Pipeline and Hazardous Materials Safety Administration regulates the transport of hazardous materials.

EPA has issued rules covering more than 80 categories of major industrial and commercial sources, such as chemical plants, oil refineries, aerospace manufacturers, and steel mills, as well as categories of smaller sources, such as dry cleaners, commercial sterilizers, secondary lead smelters, and chromium electroplating facilities.

Blacklisted Chemicals

The EPA lists 683 individual chemicals and hazardous substances in its Toxics Release Inventory (TRI)—a blacklist of sorts—of chemicals that it has determined to be detrimental in specific concentrations and forms. EPCRA Section 313 requires the EPA, states, and tribes to collect data annually on releases and transfers of certain toxic chemicals from industrial facilities and make the data available to the public. The EPA is working with state, local, and tribal governments to reduce the release of 187 toxic air pollutants to the environment.

The substances that the agency includes on the list:

• are toxic (poisonous) to humans, animals, or the ecosystem.
• have persistent, bioaccumulative effects.
• have a combination of both persistent bioaccumulative and toxic effects (PBTs).
• are carcinogenic.
• are mutagenic.
• have adverse effects on reproduction or development.
• are endocrine disruptors.
• are neuro-toxicants.

Some of the substances are of concern only in certain forms and concentrations. For example, aluminum is on the list, but only if it is in a fume or dust form. Dioxin and dioxin-like compounds are on the list if they are present as contaminants in a chemical and if they were created during the manufacture of that chemical.

Like the U.S. EPA, the European Chemicals Agency (ECHA) Registration, Evaluation, and Authorisation of Chemicals (REACH)’s criteria for identifying “substances of very high concern” is based on their detrimental effects:

• CMRs: Carcinogenic, mutagenic, or toxic to reproduction
• PBTs: Persistent, bioaccumulative, and toxic
• vPvBs: Very persistent or very bioaccumulative

Via REACH, the ECHA defined a list of the most hazardous substances on its Candidate List of Substances of Very High Concern for Authorisation.

The Canadian Environmental Protection Act, 1999 similarly identifies hazardous substances. The U.S. EPA and Environment Canada, the country’s environmental protection agency, coordinate and collaborate closely.

Notable Toxins

The EPA’s TRI Chemical List for RY 2013 includes:

Nonylphenol. On Sept. 30, 2014, the EPA announced that it is adding a nonylphenol category to the TRI list of reportable chemicals. The EPA reviewed the available ecological toxicity data for nonylphenol from EPA’s 2005 Aquatic Life Ambient Water Quality Criteria–Nonylphenol (PDF). The EPA’s technical evaluation of that data concluded that, because of its toxicity, nonylphenol can reasonably be anticipated to
cause significant adverse effects in aquatic organisms and, therefore, meets the
TRI listing criteria.

O-Nitrotoluene. EPA added ortho-nitrotoluene to the TRI chemical list in November of 2013. Facilities that manufacture, process, or otherwise use o-nitrotoluene should begin collecting release information on the chemical for RY 2014 (forms due July 1, 2015) if TRI chemical use and other thresholds are met. The National Toxicology Program (NTP) has stated that o-Nitrotoluene can “reasonably be anticipated to cause cancer in humans.”

Volatile Organic Compounds (VOCs). This class of compounds have a high vapor pressure, low water solubility and low molecular weights, according to the U.S. Geological Society (USGS). Methylene chloride, used as a solvent and paint stripper by a number of industries, is a VOC. Other VOCs are benzene, acetaldehyde, found in paints, coatings, adhesives, carpets, and insulation.

Trichloroethylene (TCE). Some metal fabricators use the solvent TCE in vapor degreasers, which clean metal parts in preparation for further finishing operations like painting or welding. TCE, a VOC, poses a human health hazard to the central nervous system, kidney, liver, immune system, reproductive system, and to the developing fetus. TCE is also characterized by EPA as carcinogenic to humans by all routes of exposure (i.e., by inhalation, ingestion, and dermal exposure). Because of these concerns, EPA selected TCE as one of the first existing chemicals to evaluate for safety under its Toxic Substances Control Act (TSCA) Work Plan and released a final risk assessment in June 2014.

Formaldehyde. The Formaldehyde Standards for Composite-Wood Products Act was signed into law in 2010. This legislation establishes limits for formaldehyde emissions from composite wood products: hardwood plywood, medium-density fiberboard, and particleboard. Although a small amount of formaldehyde is naturally produced by plants, animals and humans, high levels of exposure may cause some types of cancers, and irritation of the skin, eyes, nose, and throat.

Bisphenol A. BPA is a high production volume (HPV) chemical widely used in manufacturing polycarbonate plastics and epoxy resins used in nearly every industry, most often in packaging. Because BPA is a reproductive, developmental, and systemic toxicant in animal studies and is weakly estrogenic, there are questions about its potential impact particularly on children’s health and the environment. Studies employing standardized toxicity tests used globally for regulatory decision-making indicate that the levels of BPA in humans and the environment are below levels of potential concern for adverse effects. However, some authorities have taken action to protect sensitive populations, particularly infants and young children. For example, while acknowledging that science indicates exposure levels are below potential health effects levels, Canada is taking steps to ban BPA in baby bottles as a precautionary measure.

Polybrominated Biphenyls (PBBs). These organo-halogenated flame retardants used to slow the spread of flames, are reproductive toxins, endocrine disruptors, and neurotoxins.

Polychlorinated Biphenyls (PCBs). Although they are no longer commercially produced in the U.S., PCBs may be present in products and materials produced before the 1979 PCB ban. The EPA regulates the management, cleanup, and disposal of PCB wastes and the management of PCB-containing materials and equipment still in use.

Individual state governments have passed laws intended to protect their citizens from specific substances as well. For example, in March 2014, the California Department of Toxic Substances Control (DTSC) announced the first three chemicals to be evaluated under the state’s Safer Chemical Product regulations. They are the flame retardant TDCPP, also known as chlorinated tris, found in children’s foam padding sleeping products; unreacted diisocyanates in spray polyurethane foam systems, commonly used in home insulation; and methylene chloride used in paint and varnish removers and industrial surface cleaners. Often, laws passed in California eventually become the basis for federal laws.

Community Access to Information about Toxic Emitters, Polluters

National Air Toxics Assessment.  This site provides emissions and health risk information on 33 air toxins that the EPA says present the greatest threat to public health in the largest number of urban areas. Maps and lists are available and can be requested by state or county level.

Toxics Release Inventory.  This database is available to the public about releases of toxic chemicals into the environment through the air, water, and land from facilities in their communities. Interested parties can access the data by typing in their zip codes.

Sources:
U.S. Environmental Protection Agency
REACH
Environment Canada

(Editor’s Note: This is the first article in a three-part series. Part I provides an overview of specific legislation and regulations, regulated chemicals, and the reasons they’re on the list. Part II relays the stories of manufacturers that have successfully eliminated the toxic content, explains how they have done so and presents the results. Part III takes a closer look at safer substitutes, strategies, tools, programs, and agencies available to help manufacturers detoxify their products and processes.)

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