EPA Proposes New Rule Limiting Toluene Diisocyanates

EPA today proposed a new rule limiting Toluene Diisocyanates, TDI, widely used in auto manufacturing. These chemicals are in use in residual amounts in the production of polyurethanes and consumer products, such as coatings, elastomers, adhesives, and sealants.

They can be found in products used in and around homes or schools. Diisocyanates are well known dermal and inhalation sensitizers in the workplace and can cause asthma, lung damage, and in severe cases, death.

The rule would give EPA the opportunity to evaluate the use of, and if necessary, to take action to prohibit or limit all products containing over 0.1% of the chemical including imported products that make their way into the United States.

EPA said previously, consumer exposures have not been a focus of concern with respect to diisocyanates, because it has been assumed that consumers were generally exposed to products containing cured polyurethanes, which have been generally considered to be inert and non-toxic (Krone & Klinger, 2005).

However, an increase in the consumer availability of or exposure to polyurethane products intended to further react and undergo “curing” has occurred in the marketplace (see additional discussion in section on Consumer/General Population Exposure). For example, consumer products, such as adhesives sealants may contain TDI compounds that are not completely reacted when applied and can provide potential exposures both to the consumer as the direct user or as a bystander to such product use by others (Krone, 2004; Bello et al., 2007).

In addition, certain workers (e.g., self-employed) are not subject to the current applicable OSHA exposure limits, and are not legally required to receive health and safety training and chemical hazard information, or wear personal protective equipment and therefore could potentially be overexposed to uncured polyurethane products.

EPA’s proposed action, a Significant New Use Rule (SNUR) under the Toxic Substances Control Act (TSCA), would require manufacturers (including importers) to notify EPA at least 90 days before starting or resuming new uses of these chemicals in consumer products at levels above 0.1 percent by weight. EPA would then have the opportunity to evaluate the intended use of the chemicals and, if necessary, take action to prohibit or limit the activity.

About Ken Zino

Ken Zino is an auto industry veteran with global experience in print, broadcast and electronic media. He has auto testing, marketing, public relations and communications expertise garnered while working in Asia, Europe and the U.S.
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