Feb 23, 2017

Lautenberg Chemical Safety Act

The Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA) rolled out in June 2016 and took the place of the Toxic Substance Controls Act (TSCA) of 1976. Along with the Environmental Protection Agency (EPA), manufacturers may need to take certain steps in relationship to the new rules.

More than 96 percent of all manufactured goods involve chemistry. One of the EPA’s many tasks will be to update the current list of chemicals that have been manufactured in the U.S. or imported since 1978. The present inventory of about 86,000 chemicals is largely considered inaccurate and out-of-date.

The EPA has been tasked to meet an array of deadlines. One they recently met required them to define the ten most dangerous chemicals, i.e., high priority. Six of the ten chemistries identified were contained in several chemical product formulas used to clean materials during the electronic assembly process. Three notable ones include –

n-propyl bromide
CAS #106-94-5
Alternative names – nPB, bromopropane, 1-propyl bromide, 1-bromopropane
See All-Spec’s guide to nPB-free products.

Trichloroethylene
CAS #79-01-6
Alternative names – TCE, 1,1,2-trichloroethene, 1,1-dichloro-2-chloroethylene, 1-chloro-2,
2-dichloroethylene, acetylene trichloride, trethylene

Perchloroethylene
CAS #127-18-4
Alternative names – Perc, perchloroethene, tetrachloroethylene, PCE
With the new rules in place, manufacturers should be preparing for more changes, if they have not already.

To Do
• Review current products and chemicals in use
• Evaluate potential risks of regulation impacts, i.e. “chemical deselection”
• Anticipate any possible need to reformulate a product
• Plan for business disruptions if a chemical becomes restricted
• Speed up regulatory reviews for roll-out of any new products
• Prepare to defend the confidentiality of information associated with a potentially high priority chemical
EPA’s deadlines
• Within 180 days from enactment, start risk evaluations for the first 10 high priority chemicals (pulled from EPA’s existing Work Plan Chemicals list).
• Within 1 year, establish the process for identifying additional high and low priority chemicals.
• Within 1 year, chemical manufacturers must report all chemicals being currently produced or processed to the EPA so they can attain an accurate accounting of chemicals currently in commerce.
• Within 3.5 years, evaluations must be underway for at least 20 high priority chemicals.
• Within 3 years, risk evaluations must be completed; possible 6-month extension.
Summary of changes
Below you’ll find a summary of some of the more important changes resulting from the LCSA, and some of the EPA’s specified duties and responsibilities going forward.
Subjects all chemicals to an EPA review for the first time
EPA will –
• Conduct a risk-based review of all chemicals in commerce
• Make all new chemicals subject to EPA review before they can go to market
• Base risk evaluations only on human health and environmental considerations
• Consider vulnerable groups like infants, pregnant women and the elderly
Requires EPA to focus on high priority chemicals
EPA will –
Establish a transparent, risk-based process to identify high and low priority chemicals and inherent hazards including –
• Uses
• Typical exposures to people including vulnerable groups
• Environment
• Proximity to drinking water sources
Makes it easier for EPA to require more safety testing of chemicals
• Requires manufacturers to perform additional safety testing on chemicals should the EPA believe more data is needed to make a safety determination.
*Previously, the EPA had to show that a chemical didn’t meet the safety standard before it could require more tests

Taken from an original article from Chemtronics

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