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As we mentioned in yesterday’s Advisor, the EPA is considering adding nonylphenol ethoxylates (NPEs) to the TRI list. At this point, that addition is not yet proposed.
Here’s a look at the chemicals that the EPA has actually proposed for TRI listing.
1-Bromopropane (CAS 106-94-5)
Last April, the EPA proposed that 1-bromopropane be added to the TRI list because the National Toxicology Program (NTP) in their 13th Report on Carcinogens (RoC) classified the chemical as ‘‘reasonably anticipated to be a human carcinogen.’’
1-bromopropane is a colorless to pale-yellow liquid used as a solvent in many commercial industries. It is volatile and has a strong odor. 1-bromopropane is also called n-propyl bromide.
The chemical is used as a cleaner for optics, electronics, and metals and as a solvent for aerosol-applied adhesives, such as those used in foam cushion manufacturing. It is also used in dry cleaning and solvent sprays for aircraft maintenance, asphalt production, and synthetic fiber manufacturing. According to the NTP, in recent years, 1-bromopropane use has increased as a result of new industrial and commercial applications as a substitute for ozone-depleting substances (ODS) or suspected carcinogens. For example, 1-bromopropane has been used to replace perchloroethylene in dry cleaning.
As a matter of fact, the EPA allows some uses of 1-bromopropane as an ODS substitute under the Agency’s Significant New Alternatives Policy (SNAP) program.
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Hexabromocyclododecane (CAS 25637-99-4 and CAS 3194-55-6)
Come this September, the EPA plans to propose that hexabromocyclododecane (HBCD) be added to the TRI list. HBCD is a flame retardant. According to the EPA, it is a persistent bioaccumulative and toxic (PBT) chemical, especially to aquatic organisms, and is also of concern for certain chronic human health effects. The Agency has developed an action plan for HBCD that includes listing it as a TRI reportable chemical.
The primary use of HBCD is as a flame retardant for foams used primarily for thermal insulation boards in the building and construction industry. It is also used as a back coating for a number of upholstery textiles and as a flame retardant in electrical and electronic appliances.
More Industries to Be Added to TRI
Also this coming September, the EPA plans to propose adding a number of industry sectors covered under TRI regulations.
The sectors the Agency will propose to add are:
- Iron Ore Mining
- Phosphate Rock Mining
- Steam and Air-Conditioning Supply
- Other Warehousing and Storage
- Solid Waste Combustors and Incinerators
- Coin-Operated Laundries and Dry Cleaners
- Dry-cleaning and Laundry Services (except Coin-Operated)
- Linen Supply
- Industrial Launderers
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What You Can Do Now
If you manufacture, process, or otherwise use 1-bromopropane or HBCD at your facility, it’s a good time to take a look at your inventory to see if you can avoid TRI requirements by eliminating them or keeping them below the threshold for reporting. You could also make sure that you comment on the proposals. Although the comment period for 1-bromopropane has closed, you can contact EPA’s Nicole Paquette. The comment period for HBCD will be announced when the proposal is published in the Federal Register. In the meantime, you can also contact Nicole Paquette about HBCD.
The comment period for the expansion of industries will be announced when the proposal is published. In the meantime, you can contact EPA’s Cory Wagner about that.