Update | Revised TSCA Risk Determination for PV29 Drafted

Posted on 3/7/2022 by Roger Marks

Update 03/07/2022

EPA has drafted a revised TSCA chemical risk determination for Pigment Violet 29 (PV 29).

The revised risk determination would supersede the January 2021 determination, which found that PV29 posed no unreasonable risk to the environment, consumers, bystanders, or the general population. The initial risk determination found that PV29 posed an unreasonable risk to workers from ten out of fourteen conditions of use evaluated.  

Under the revised risk determination, EPA will take a “whole chemical approach” to manage the risks posed by PV29. By “whole chemical approach,” EPA means they will create risk management provisions that apply to all conditions of use for the chemical—from manufacture and processing to distribution, commercial use, and disposal.

CI Pigment Violet 29 (CASRN 81-33-4), called PV29 for short, is a substance used to color materials and as an intermediate for certain high-performance pigments called perylene pigments. PV29 is used in car paints and coatings, commercial printing, and consumer watercolor paints. 

Original Article (January 19, 2021) 

This week, US EPA released a final chemical risk evaluation for CI Pigment Violet 29 (PV29). TSCA, as amended by the Frank R. Lautenberg Chemical Safety for the 21st Century Act (LCSA), requires EPA to evaluate the risks posed by all chemicals on the TSCA inventory.

With the release of its findings on PV29, EPA has now evaluated the risks of all ten of its first batch of inventory chemicals. 

PV29 Risk Eval Findings

The Final Risk Evaluation for PV29 finds no unreasonable risk to the environment, consumers, bystanders, or the general population.

EPA found unreasonable risk to workers and occupational non-users from ten out of the 14 conditions of use they evaluated.

Uses that posed unreasonable risk to workers and occupational non-users include:
  • Domestic manufacturing or import,
  • Formulation/mixture in paints, coatings, plastic, and rubber products,
  • Use as an intermediate for other perylene pigments,
  • Use in paintings and coatings in the automobile sector,
  • Use in merchant ink for commercial printing,
  • Recycling, and
  • Disposal 
EPA found that risks to workers and occupational non-users from PV 29 can come from long-term inhalation exposure. 

What Happens Next?

Now that EPA has identified unreasonable risks to workers and occupational non-users, they must address the “risky” conditions of use with new regulations.  

Under TSCA, EPA is authorized to restrict the manufacture, import, processing, distribution, and/or use of chemicals to protect the human health and the environment. Steps EPA can take to manage a chemical’s risk can be as severe as a total ban or prohibition on manufacturing and import. EPA can also add requirements for using the chemical or otherwise limit its manufacture, processing, distribution, use, or disposal.

Once EPA completes a TSCA risk evaluation, they agency has two years to create new risk management regulations.

EPA recently announced a memo of understanding (MOU) with OSHA to work together on chemical safety requirements to protect workers.  While EPA is the agency responsible for evaluating the risks posed by each chemical, they will seek input from OSHA concerning workplace exposures.

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Tags: chemical risk evaluations, chemicals, PV29, TSCA

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