EDF Health

Toxic chemicals can enter food through packaging. We made a list.

By Tom Neltner, Senior Director, Safer Chemicals Initiative / Published: March 26, 2019

Boma Brown-West, Senior Manager, Tom Neltner, Chemicals Policy Director, and Michelle Harvey, Consultant.

This is the second in a series evaluating the challenges in single-use food packaging waste.

[pullquote]See our list of key chemicals of concern in food packaging.[/pullquote]In the late 1980s, the Council of Northeast Governors (CONEG) was concerned that heavy metals in packaging would accumulate in recycled materials to levels that presented serious health concerns. The organization drafted model legislation that prohibited the intentional addition of mercury, lead, cadmium, and hexavalent chromium to any component of packaging, including inks. It also set a 100 parts-per-million limit on the total amount of these four heavy metals. To ensure compliance, companies making packaging materials had to provide certificates of compliance to downstream purchasers and report compliance to the states.

CONEG also established the Toxics in Packaging Clearinghouse to maintain the model legislation, coordinate implementation of state legislation, and serve as a resource for companies seeking compliance information. The Council’s hypothesis: protecting virgin material from contamination will improve the recyclability of post-consumer materials and protect public health.

Over the years, 19 states have adopted a variation of the model legislation.  In 2018, the State of Washington took an unprecedented step of expanding its version of the legislation from heavy metals to include per- and poly-fluorinated alkyl substances (PFAS). PFAS are bioaccumulating, persistent chemicals and are associated with an array of health problems including endocrine disruption and children’s developmental harm. The State was concerned that paper and cardboard food packaging treated with these chemicals may be contaminating composting and paper recycling processes post-consumer.

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Systematic slowdown: EPA indefinitely delays virtually all proposed actions to restrict chemicals under TSCA

By / Published: December 20, 2017

Richard Denison, Ph.D., is a Lead Senior Scientist.  My colleague Ryan O’Connell assisted in the research described in this post.

By the time the long-awaited reforms of the Toxic Substances Control Act (TSCA) passed in June of 2016, nearly all stakeholders had come to agree that we needed a stronger federal chemical safety system, one that gave EPA more authority and more resources to act.  Only through this could public confidence in the system begin to be restored – to the benefit of both business and public health.

That was then.  A scant 18 months later, the law is being implemented by an Administration hell-bent on rolling back existing or indefinitely delaying new health protections, even those called for by large bipartisan majorities in Congress.  And the chemical industry?  So much for the influence of its better angels who supported reform.  It’s now going for broke, grabbing what it can while it can.[pullquote]Virtually every proposed action that would impose restrictions or conditions on specific chemicals has been either moved to the “long-term action” attic or simply deleted altogether.[/pullquote]

Yesterday, the New York Times and The Intercept ran stories spotlighting EPA’s decision to back-burner proposed restrictions on high-risk uses of three highly toxic chemicals – trichloroethylene (TCE), methylene chloride (MC), and N-methylpyrrolidone (NMP) – relegating them to the bureaucratic dustbin of “long-term actions.”  Not coincidentally, the chemical industry has strongly opposed all of the proposed restrictions.

But those aren’t the only proposed actions on chemicals for which this EPA has applied the brakes.  An examination of EPA’s two most recent semi-annual “unified agendas” – that trumpeted by the President last week, and the preceding one issued this past April – reveals a much broader and more disturbing pattern:  Virtually every proposed action that would impose restrictions or conditions on specific chemicals has been either moved to the “long-term action” attic or simply deleted altogether.   Read More »

Posted in Health policy, Industry influence, Regulation, TSCA reform / Tagged , | Read 1 Response

This SNUR is not a SNORE!

By Jennifer McPartland / Published: October 1, 2013

Jennifer McPartland, Ph.D., is a Health Scientist.

Yesterday EPA finalized a significant new use rule (SNUR) under the Toxic Substances Control Act (TSCA) that requires manufacturers and importers of certain perfluorinated chemicals to notify EPA at least 90 days before commencing any “significant new use” of these chemicals.  (See below for what EPA has designated to be a “significant new use.”)

These notifications afford EPA an opportunity to evaluate the designated new uses before they start and address any risks the new uses may pose.  Read on to learn more about some novel aspects of this final rule, including the scope of what EPA has designated as significant new uses of these chemicals.  Read More »

Posted in EPA, Health policy, Regulation / Tagged , , | Comments are closed

April brings showers…and a flurry of new studies on the risks of perfluorinated chemicals

By / Published: April 30, 2013

Rachel Shaffer is a research assistant.

What do waterproof jackets, car wax, and non-stick pans have in common?

Aside from being great Father’s Day presents (Dad, I’m thinking ahead this year!), they also all are made with perfluorinated compounds, or PFCs. There are hundreds of different PFCs, and their oil- and water-resistant properties make them useful in a variety of products, from cookware and carpets to food-packaging and electronics.  

Unfortunately, these chemicals have less desirable properties as well. Thanks to their strong molecular bonds, PFCs do not readily break down; they persist in the environment and in our bodies. And, widespread use has led to extensive human exposure. The Centers for Disease Control’s (CDC) human biomonitoring program, the National Health and Nutrition Examination Survey (NHANES), detected four types of PFCs in over 98% of samples representative of the U.S. population collected in 2003-2004.  

Two of the compounds detected in NHANES, perfluorooctane sulfonic acid (PFOS) and perfluorootanoic acid (PFOA), are the focus of three new studies published this month in Environmental Health Perspectives. These studies, one reporting an association with osteoarthritis in women, another an association with semen quality in men, and a third an association with asthma in children, add to a growing concern about the potential adverse effects of these ubiquitous chemicals.

What follows is a brief overview of the findings of these new studies.  Read More »

Posted in Emerging science, Health policy, Health science / Tagged , | Comments are closed

EPA proposes yet another TSCA workaround: Creative, yes, but why not just give it the authority it needs?

By / Published: November 2, 2011

Richard Denison, Ph.D., is a Senior Scientist.

One thing I’ve learned in observing EPA try to operate under the Toxic Substances Control Act (TSCA) over the years is that – faced with limited authority and significant evidentiary and resource burdens – the Agency often has to resort to a workaround to get something it needs to do done.

Can’t ban a nasty chemical?  Wait until it’s voluntarily withdrawn and then pounce on it with a Significant New Use Rule (SNUR) to try to wedge the door closed.  Witness PFOS and penta and octaBDE.  (Under TSCA, without a SNUR in place on a chemical, a new producer or importer could start up without even letting EPA know; where EPA has issued a SNUR for a chemical, advance notification is required and EPA least has a chance to weigh in before production or import proceeds.)

Can’t require an up-front minimum data set for new chemicals?  Recommend to companies that for certain chemicals they submit such a data set along with the pre-manufacturing notice (PMN) they’re required to file, or risk having EPA extend the review of their new chemical or negotiate with them to do the testing.  EPA has made such “recommendations” for those relatively few new chemicals where the company “anticipates” at the outset producing it in large amounts in the first three years or where significant release or exposure is projected. 

The latest such workaround?  EPA’s simultaneous issuance of a proposed test rule and a proposed SNUR for a batch of high production volume (HPV) “orphan” chemicals that no company agreed to sponsor under the Agency’s voluntary HPV Challenge Program.

Necessity is the mother of invention, they say, and these creative new proposals are a case in point.  But, my oh my, there’s gotta be a better way…. Read More »

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