Identifying priority chemicals

The examiner had a sense of humor. He allowed my response but suggested that a patent could be granted only if we could chemically identify the HABI dimer. At that time, this could be done only by X-ray crystallography, which was a long and tedious job. However, we were pleased with his response as we had a priority date and could delay the ultimate issue for a considerable length of time. As it turned out, this application, filed in the early 1960s, became a patent (L. A. Cescon, U.S. Pat. 3,784,557, Jan. 8, 1974) in 1974, 5 years after products based on this chemistry hit the market. It had issued many years earlier as Belg. Pat. 635,804 (see above). 

For the terrestrial environment, waste sites may act as major emission sources of mixtures. In the United States, the Agency for Toxic Substances and Disease Registry (ATSDR) has performed a trend analysis to identify priority chemical mixtures associated with hazardous waste sites (De Rosa et al. 2001, 2004 Fay 2005). The information was extracted from the Hazardous Substance Release/Health Effects Database (HazDat) (ATSDR 1997). The HazDat contains data from hundreds of hazardous waste sites in the United States. A trend analysis was completed for frequently co-occurring chemicals in binary or ternary combinations found in air, water, and soil at or around hazardous waste sites (Fay and Mumtaz 1996 De Rosa et al. 2001, 2004). Table 1.1 gives an overview of frequently occurring substances at hazardous waste sites in the United States. 

Identifying priority chemicals in a drinking-water supply... 

Article 16 of the WFD, which sets out the European Union (EU) strategy against pollution of water by chemical substances, requires the Commission to identify priority substances of European relevance, for which priority action is needed at Community level. The first list of priority substances was adopted in November 2001 (Decision 2455/2001/EC). In order to assess the risk of failing the objective of good chemical status , Member States are obliged to monitor these substances in all water bodies. 

Attempts to select from the 1000s of potentially toxic chemicals a manageable list of substances that really pose health problems, have never been entirely satisfactory. A number of ranking schemes have been proposed, either with a view to deciding priorities for regulatory action, or in order to identify priorities for research and data collection. 

Chemical substances, mixtures, or in some instances, categories of substances, that have been or are subject to PAIR reporting are identified in 40 C.F.R. 712.30. The list is expanded in two ways. Chemicals identified by the ITC in its biannual recommendations of chemicals for priority testing under TSCA 4 are required to be added to the PAIR list. In addition to reacting to ITC recommendation or designation of priority testing chemicals, EPA may... 

More than a decade ago, the Emergencies Branch of Environment Canada prepared a chemical spill priority list of over 500 chemicals, each chemical being ranked according to its supply volume, reported spill frequency, historical spill volume, and toxicity. Our main objective then was to identify the minimum number of chemicals that would account for the maximum number of spills. The use of the list would be to act as a focus for the development of countermeasures, analytical methods, and spill manuals. This function has been well served. The list has since been reviewed, in 1990 (Fingas et al., 1991). 

Based on its econfidence program, DyStar has compiled a list of globally marketed textile dyes and auxiliaries that are qualified to support the objective of the Joint Roadmap Towards Zero Discharge of Hazardous Chemicals. None of the listed products use as intentional ingredients any of the 11 Priority Chemicals identified in the Joint Roadmap ... 

Although the predictive abilities of QSAR models are still limited, their utility in identifying priority chemicals can 1) increase efficiency in the allocation of scarce financial resources and 2) reduce the uncertainty inherent to the public management of compounds for which little or no information is available. 

PRIO is a web-based tool intended to be used to preventively reduce risks to human health and the environment from chemicals. The aim of PRIO is to facilitate in the assessment of health and environmental risks of chemicals so that people who work as environmental managers, purchasers and product developers can identify the need for risk reduction. To achieve this PRIO provides a guide for decision-making that can be used in setting risk reduction priorities. 

Diisopropyl methylphosphonate has been identified at 2 of the 1,416 hazardous waste sites that have been proposed for inclusion on the EPA National Priorities List (NPL) (HazDat 1997). One site, identified in Figure 5-1, is the RMA located near Denver, Colorado. As diisopropyl methylphosphonate was never made commercially, the EPA neither expects nor routinely looks for this chemical at hazardous waste sites unless site history indicates it might be present. 

Mineral Oil Hydraulic Fluids and Polyalphaolefin Hydraulic Fluids. No literature was identified dealing with the bioavailability of chemicals in this category of hydraulic fluids. Because of this wide variation and the lack of any information in mammalian species, it is difficult to estimate bioavailability to humans. Additional research on the bioavailability of this category of hydraulic fluids would be valuable but may not be as high a priority as research on bioavailability issues for the phosphate ester-based hydraulic fluids. 

Furthermore, the EU regularly produces and regularly updates the list of substances of high concern, i.e. the SVHC list. The identification of a substance as a SVHC and its inclusion in the candidate list is the first step of the authorization procedure. The European Chemical Agency in Helsinki identifies from the candidate list priority substances to be included in Annex XIV of REACH (the authorisation list). The substances on the candidate list will most probably be liable to stricter regulation in the future (authorisation/banning) which will stimulate the substitution of these chemicals. Currently in June 2012, there are 84 substances included in the candidate list. Examples of chemicals on the candidate list which may be relevant for the leather industry are phenolphthalein, boric acid, cobalt dichloride, dichromate (although not used by leather industry), phthalates (DEHP, DBP and BBP), acrylamide and short-chain chlorinated paraffins. 

Section 8(e), which requires industry to notify the EPA Administrator if it obtains information indicating that a substance presents a substantial risk, has been a fertile source of information about chemical hazards. More than 400 substantial risk notices have been filed. However, the connection between information and action is unclear with respect to the notices. I do not know of any action, either regulatory or voluntary, by either industry or EPA, that has been taken as a result of an 8(e) notice. Undoubtedly, there have been some industry actions. The apparent lack of attention by the government is more troublesome, and the recent "100-day report" by OTS identifies the need to make response to 8(e) notices a matter of higher priority. 

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