Product Stewardship

EPA extends by 6 months compliance date for prohibitions under TSCA on PIP 3:1

The Agency also plans new risk management rules for five PBTs

EPA (Environmental Protection Agency) announced its intention to extend the 6-month ban period for the presence of phenol, isopropyl, phosphate (3:1) (PIP (3:1), (CAS 68937-41-7) in plastic components and electrical and electronic articles, confirming some exemptions.

In USA it will be no longer possible to manufacture, import and distribute articles containing this substance as of 8 March 2022. The same prohibition shall apply for manufacture, import and distribution in commerce of the substance as such or in a mixture.

Phenol, isopropyl, phosphate (3:1) is widely used as a plasticizer, flame retardant, anti-wear additive or anti-compressibility additive in hydraulic fluids, lubricating oils, lubricants and greases, various industrial coatings, adhesives, sealants, and plastic articles.

EPA provides a list of codes related to the North American Industrial Classification System (NAICS), to identify sectors involved in the restriction. Products potentially affected by this ban are:

  • plastics and resins;
  • adhesives;
  • paints and coatings;
  • electrical and electronic equipment;
  • components for electrical and electronic equipment.

The extension was requested by the electronics industry which admitted that PIP (3:1) is not regulated by any other international regulation. This lack of uniformity leads inevitably to a slower collection of information throughout the supply chain, since it is essential first the awareness among manufacturers, importers and distributors regarding the prohibition imposed.

Phenol, isopropyl, phosphate (3:1) is included in the risk management rule issued according to TSCA section 6(h) in January 2021, which includes four more substances at risk of persistence, bioaccumulation, and toxicity (PBT); as follows:

  • Decabromodiphenyl ethers (decaBDE), (CAS 1163-19-5)    
  • 2,4,6‑tris(terz-butyl) phenolo (2,4,6TTBP) (CAS 732-26-3)
  • Esachlorobutanadiene (HCBD) (CAS 87-68-3)
  • Pentachlorothiophenolo (PCTP) (CAS 133-49-3)

The Agency also wants to enact new risk management rules in 2023, to reduce even more the exposure to PBTs and protect human health and the environment.

Note that the restrictions imposed don’t directly involve manufacturers and distributors in the European territory unless they export products and articles containing these substances to the US territory.

Source: EPA (1 and 2)

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