In late 2023, both the European Chemicals Agency (ECHA) and the US Environmental Protection Agency (EPA) announced work establishing possible future regulatory actions concerning substances used in the production of polyvinyl chloride (PVC) plastics.
ECHA
On November 28, 2023, ECHA published an initial report on potential human health risks from PVC resin, additives, and microparticles.
For the occupational safety of workers with the resin, ECHA’s investigators found that “operational conditions and risk management measures implemented in the VCM [vinyl chloride monomer] /PVC industry are adequate and effective to control the risk for workers.”
However, the agency had concerns about the additives and microparticles. Of the 470 PVC additives ECHA identified, the investigation focused on 63 that function as heat stabilizers, plasticizers, and flame retardants. The investigation identified human health risks from some, and environmental risk from all of the 63 prioritized additives.
To address the risks from PVC additives and particles, ECHA recommended regulatory action to:
- Minimize risks from plasticizers, in particular ortho-phthalates, likely through a REACH restriction
- Reduce risks from organotin substances, likely through a REACH restriction. (ECHA notes that organotin substances are used more often in North America than in Europe with exposure facilitated by imports.)
- “Follow-up” on ECHA’s proposed EU-wide strategy on flame retardants
- Minimize the release of PVC particles (and additives) to the environment. Likely through improved technology at recycling facilities and landfills.
It is now up to the European Commission to decide whether ECHA should prepare a REACH restriction proposal.
EPA
On December 14, 2023, the EPA announced it was beginning the process of evaluating five chemicals for potential designation as High Priority Substances, including the monomer to produce PVC, vinyl chloride (CAS 75-01-4).
The other four substances under consideration are acetaldehyde (CAS 75-07-0), acrylonitrile (CAS 107-13-1), benzenamine (CAS 62-53-3), and 4,4’-methylene bis(2-chloroaniline) (MBOCA, CAS 101-14-4). All have been measured in food contact materials according to the Food Packaging Forum’s database on migrating and extractable food contact chemicals (FCCmigex).
EPA officially has the next twelve months to decide, but “expects these chemicals to be designated as high-priority for risk evaluation during the prioritization process.” When that happens, the agency will conduct a comprehensive risk evaluation under the Toxic Substances Control Act which could lead to management steps including regulating or restricting the manufacture, processing, distribution, use, or disposal of the respective chemical.
Stakeholders, including the public, can comment on EPA’s prioritization of these five chemicals until March 18, 2024.
Track this and other public consultation opportunities related to food contact materials and chemicals on FPF’s consultations page.
References
ECHA (November 28, 2023). “ECHA identifies risks from PVC additives and microparticle releases.”
US EPA (December 14, 2023). “EPA begins process to prioritize five chemicals for risk Evaluation under Toxic Substances Control Act.”
ECHA (March 15, 2023). “ECHA identifies certain brominated flame retardants as candidates for restriction.”
Read more
Kelly Franklin (December 10, 2023). “Vinyl chloride, other plastic building blocks next up for TSCA prioritization.” Enhesa
Brian Bienkowski (December 15, 2023). “EPA begins review of PVC ingredient vinyl chloride, which could lead to restrictions or ban.” Environmental Health News
Alden Wicker (January 2, 2024). “As the world swims in plastic, some offer an answer: Ban the toxic two.” Mongabay
