Session B: Focus on Higher Hazard Substances

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1 Session B: Focus on Higher Hazard Substances Heather Tenney, Pam Eliason, & Greg Morose MA Toxics Use Reduction Institute University of Massachusetts Lowell TUR Planner Continuing Education Conference November 20, 2014

2 Session B Agenda Higher Hazard Substance (HHS) Overview Heather Tenney, TURI Elimination of npb at International Rectifier Pam Eliason, TURI Aerospace/Defense Supply Chain: Collaborative Research Results for Hex Chrome Free Materials Greg Morose, TURI Ethyl Acetate as a potential HHS alternative Heather Tenney, TURI 2

3 Massachusetts TURA Sustain and promote the competitive position of Massachusetts industry Promote reduction in the use of toxic and hazardous substances Require businesses to analyze their use of chemicals, to look for opportunities to reduce toxics use and waste. TUR Options Assessment Alternatives Assessment Publicly report their toxic chemical use 3

4 TURA Chemical Categorization TURA List of Toxic and Hazardous Substances SAB More Hazardous Chemicals Remainder of list, uncategorized SAB Less Hazardous Chemicals TURA Higher Hazard Substances (HHS)* PBTs, TCE, perc, cadmium & compounds, formaldehyde, chromium VI, methylene chloride TURA Lower Hazard Substances (LHS)** Tert-butyl alcohol; sec-butyl alcohol; n-butyl alcohol; ferric chloride; ferrous chloride; ferric sulfate; ferrous sulfate; butyl acetate; and iso-butyl acetate *TURA Higher Hazard Substances have 1000 lb reporting threshold **Lower Hazard Substances have no per chemical fee 4

5 History of TURA Categorization 1998 Categorization of all TURA chemicals which had been reported 2002 Categorization of remaining 313 chemicals 2006 TURA Amendments allow for Higher and Lower Hazard Substances 5

6 Higher & Lower Hazard Substances Higher Hazard Substances: Lowers the TURA threshold to 1,000 lb/year Designations to date: Cadmium; Cadmium Compounds; Trichloroethylene; Perchloroethylene, Formaldehyde, Hexavalent chromium compounds, methylene chloride, and EPA PBTs Lower Hazard Substances: Eliminates the per-chemical fee Designations to date: iso-butyl alcohol; sec-butyl alcohol; n-butyl alcohol; ferric chloride; ferrous chloride; ferric sulfate; ferrous sulfate; butyl acetate; and iso-butyl acetate 6

7 Proposed Additions HHS Currently in draft regulation - comments close 11/21 n-propyl Bromide (npb) Dimethylformamide (DMF) Cyanide Compounds Hydrogen Fluoride (HF) Toluene Diisocyanate (TDI) 7

8 Proposed Additions LHS to be presented at December Advisory Committee meeting - Ethyl acetate 8

9 Categorization Objectives Focus: Focus companies efforts and TURA program support on HHS Guidance: List consists of a broad hazard spectrum; provide guidance to companies about which toxic substances are preferable, if they must be used. Coverage: Bring smaller users of the most hazardous substances into TURA reporting and planning 9

10 Contribution of Smaller Filers First Reporting Year Trichloroethylene 17, 380 lbs (22%) Cadmium 29, 429 lbs (100%) Cadmium compounds 14,625 lbs (8%) Perchloroethylene 73,770 lbs (39%) 10

11 HHS/LHS Designation Process TURA decision-making process: Decisions related to the list of Toxic or Hazardous Substances * Initiation* TURI gathers data SAB votes on a recommendation TURI prepares policy analysis Advisory Committee provides input** TURI makes revisions & conducts additional research as needed Administrative Council votes Draft regulations Regulations *Proposal may be initiated by SAB TURA Program agency MA stakeholders Advisory Committee Administrative Council Statutory Requirement **all TURA program agencies and the Advisory Committee provide input throughout the process as well. 11

12 TURA Chemical Categorization Chemical Lists TURA List of Toxic and Hazardous Substances SAB More Hazardous Chemicals Remainder of list, uncategorized SAB Less Hazardous Chemicals TURA Higher Hazard Substances (HHS)* PBTs, TCE, perc, cadmium & compounds, formaldehyde, chromium VI, methylene chloride TURA Lower Hazard Substances (LHS)** Tert-butyl alcohol; sec-butyl alcohol; n-butyl alcohol; ferric chloride; ferrous chloride; ferric sulfate; ferrous sulfate; butyl acetate; and iso-butyl acetate *TURA Higher Hazard Substances have 1000 lb reporting threshold **Lower Hazard Substances have no per chemical fee 12

13 HHS Resources 13

14 N-Propyl Bromide (npb) Reasonably anticipated to be a human carcinogen Male and female developmental toxin Peripheral and central nervous system toxin Causes eye, nose, and throat irritation, headache, dizziness, nausea, and fatigue 14

15 N-Propyl Bromide (npb) Reported by three TURA filers in ,587 lbs used 17,438 lbs released 15

16 Categorization 2006 TURA amendments direct the Administrative Council to categorize chemicals Up to 10 HHS and 10 LHS can be designated each year To date the Council has designated 7 HHS and 10 LHS 16

17 Advisory Committee Input Reporting under TURA High acute toxicity Prioritization in other jurisdictions Chemicals that may be an alternative of concern to an existing HHS Chemicals that are PBTs 17

18 Administrative Council Input Avoid adverse substitutions Other logical groupings of chemicals 18

19 Hydrogen Fluoride (HF) Highly corrosive Can cause bone decalcification Acute exposure through inhalation or skin contact can be fatal due to effects on the heart and lungs. Can cause skeletal fluorosis 19

20 Hydrogen Fluoride (HF) Reported by 4 TURA filers in ,894 lbs used 5,123 lbs released 20

21 Cyanide Compounds High levels of exposure can result in convulsions, unconsciousness and death Can cause CNS, cardiovascular, respiratory, or thyroid effects. Potential reproductive toxin 21

22 Cyanide Compounds Reported by 3 TURA filers in ,802 lbs used 0 lbs released 22

23 Toluene Diisocyanate (TDI) Potent dermal and respiratory sensitizer Reasonable anticipated to be a human carcinogen Can cause pulmonary edema Asthma attacks induced by TDI can be lethal 23

24 Toluene Diisocyanate (TDI) Reported by 5 TURA filers in ,324,842 lbs used 168 lbs released 24

25 Dimethyl Formamide (DMF) Toxic amounts of DMF may be absorbed by inhalation and through the skin Shows reproductive and developmental toxicity in many studies 25

26 Dimethyl Formamide (DMF) Reported by 8 TURA filers in ,567,168 lbs used 13,856 lbs released 26

27 27

28 Ethyl Acetate Potential Lower Hazard Substance

29 Ethyl Acetate Identified as a potential alternative in Methylene Chloride and npb HHS policy analyses On SAB s less hazardous list 29

30 Ethyl Acetate data Collected EHS summary data for ethyl acetate Compared to other LHS ( butyl acetate and iso-butyl acetate) as well as Amyl Acetate which has been delisted 30

31 Resources 31

32 Ethyl Acetate as a potential LHS SAB recommended as LHS December 2013 Advisory Committee to review policy analysis December 2014 Administrative Council to review following 32

33 Ethyl Acetate Data Principal hazards of ethyl acetate: -neurotoxicity -irritation -flammability flash point 24F 33

34 TURA Data Reported by 22 TURA filers in ,282,276 million lbs used 7,964,031 byproduct 210,532 released 34

35 Applications Ethyl Acetate identified as an alternative for: npb adhesives Methylene chloride adhesives In applications where flammables are acceptable 35

36 Alternatives to methylene chloride Ethyl acetate: Can be an effective separation and reaction solvent, but can also be subject to hydrolysis. Amy Cannon, Green Chemistry in Practice 36

37 Thank you Contact information: Heather Tenney Pam Eliason Greg Morose Massachusetts Toxics Use Reduction Institute University of Massachusetts Lowell 600 Suffolk St. Suite 501 Lowell, MA

Dimethylformamide (CAS )

Dimethylformamide (CAS ) Toxics Use Reduction Institute SUMMARY OF POLICY ANALYSIS Aug 12, 2014 Higher Hazard Substance Designation Recommendation: Dimethylformamide (CAS 68-12-2) The following document analyzes the implications