© Toxics Use Reduction Institute University of Massachusetts Lowell © Toxics Use Reduction Institute University of Massachusetts Lowell

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

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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

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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

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TURA List of Toxic and Hazardous Substances

SAB More Hazardous Chemicals

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

TURA Chemical Categorization

Remainder of list, uncategorized

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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

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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

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Proposed Additions -2014

HHS Currently in draft regulation - comments close 11/21

– n-Propyl Bromide (nPB)

– Dimethylformamide (DMF)

– Cyanide Compounds

– Hydrogen Fluoride (HF)

– Toluene Diisocyanate (TDI)

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Proposed Additions - 2014

LHS to be presented at December Advisory Committee meeting

- Ethyl acetate

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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

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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%)

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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.

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TURA List of Toxic and Hazardous Substances

SAB More Hazardous Chemicals

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

Remainder of list, uncategorized

TURA Chemical Categorization

Chemical Lists

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HHS Resources

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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

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N-Propyl Bromide (nPB)

Reported by three TURA filers in 2012

• 60,587 lbs used

• 17,438 lbs released

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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

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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

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Administrative Council Input

• Avoid adverse substitutions

• Other logical groupings of chemicals

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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

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Hydrogen Fluoride (HF)

Reported by 4 TURA filers in 2012

• 475,894 lbs used

• 5,123 lbs released

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Cyanide Compounds

• High levels of exposure can result in convulsions, unconsciousness and death

• Can cause CNS, cardiovascular, respiratory, or thyroid effects.

• Potential reproductive toxin

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Cyanide Compounds

Reported by 3 TURA filers in 2012

• 71,802 lbs used

• 0 lbs released

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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

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Toluene Diisocyanate (TDI)

Reported by 5 TURA filers in 2012

• 7,324,842 lbs used

• 168 lbs released

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Dimethyl Formamide (DMF)

• Toxic amounts of DMF may be absorbed by inhalation and through the skin

• Shows reproductive and developmental toxicity in many studies

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Dimethyl Formamide (DMF)

Reported by 8 TURA filers in 2012

• 5,567,168 lbs used

• 13,856 lbs released

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Ethyl Acetate

Potential

Lower Hazard Substance

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Ethyl Acetate

• Identified as a potential alternative in Methylene Chloride and nPB HHS policy analyses

• On SAB’s less hazardous list

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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

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Resources

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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

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Ethyl Acetate Data

Principal hazards of ethyl acetate:

-neurotoxicity

-irritation

-flammability flash point 24F

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TURA Data

Reported by 22 TURA filers in 2012

• 11,282,276 million lbs used

• 7,964,031 byproduct

• 210,532 released

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Applications

Ethyl Acetate identified as an alternative for:

• nPB – adhesives

• Methylene chloride – adhesives

In applications where flammables are acceptable

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Ethyl acetate: Can be an effective separation and reaction solvent, but can also be subject to hydrolysis.

Amy Cannon, Green Chemistry in Practice

Alternatives to methylene chloride

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Thank you Contact information:

Heather Tenney heather@turi.org

Pam Eliason pam@turi.org

Greg Morose

Gregory_Morose@uml.edu www.turi.org

Massachusetts Toxics Use Reduction Institute

University of Massachusetts Lowell 600 Suffolk St. Suite 501

Lowell, MA 01854