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USA: EPA Postponed Compliance Date of PIP (3:1) under TSCA

MARCH 2021 - ELECTRICAL AND ELECTRONICS, HARDLINES, SOFTLINES, TOYS AND CHILDREN'S PRODUCTS

The US Environmental Protection Agency (EPA) delayed1 the enforcement of certain prohibition of flame retardant PIP (3:1) for up to 180 days and started a 60-day public consultation on the Toxic Substances Control Act's (TSCA) risk management rules on it including four other persistent, bioaccumulative and toxic (PBT) substances. 

As we reported earlier2, EPA has published final rules on 5 PBT substances: decaBDE, PIP (3:1), 2,4,6-TTBP, PCTP and HCBD. Four out of five prohibitions apply to articles (i.e. manufactured items with specific sharp and function in general) and due to start from 8 March 2021. 

Delay of enforcement of PIP (3:1)
However, EPA issued a 180-day ‘no action assurance’ (NAA) memorandum3 on 8 March 2021, pausing enforcement on prohibition for the processing and distribution in commerce of PIP (3:1) for use in articles including PIP (3:1)-containing articles. This was because EPA had received many stakeholders’ comments e.g. those from the electronics and electrical manufacturing industry who raised significant concerns about this prohibition. They would like to ask for an extension of compliance date so as to help them clear existing stocks, find and certify alternative chemicals, produce or import new articles without PIP (3:1). 

PIP (3:1) is used as a flame retardant and a plasticizer in plastic components such as PVC wire covers and casings. It can be found in consumer and commercial articles for example laptops, TVs, and gaming consoles, as well as internal components of high-tech robotics and manufacturing equipment. 

The extension aims to avoid significant disruption to the supply chain. It is up to 180 days (i.e. as late as 4 September 2021) but may be even longer as EPA will collect data to evaluate whether the extension may be necessary. The delay of enforcement applies to prohibition on processing and distribution in commerce of PIP for use in articles; including in PIP (3:1)-containing articles plus the recording keeping requirement. However, it does not apply to PIP (3:1) not already in articles (e.g. in mixtures). 

Reopen for public comment for 5 PBTs

The EPA is particularly interested to know whether the rules sufficiently reduce exposure to the 5 PBTs substances. As per the Federal Register4, the 60-days public consultation starts from 16 March 2021. It would help to support EPA’s next steps, which may include amending the final rules e.g. including additional or alternative exposure reduction measures or extending compliance dates.

 

Reference: 
DecaBDE: decabromodiphenyl ether (CAS No. 1163–19–5)
PIP (3:1): phenol, isopropylated phosphate (3:1) (CAS No. 68937–41–7)
2,4,6-TTBP: 2,4,6-Tris(tert-butyl)phenol (CAS No. 732-26-3)
HCBD: hexachlorobutadiene (CAS No.87–68–3)
PCTP: pentachlorothiophenol (CAS No.133-49-3)

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