Toxic chemicals, production

Suppose one wanted to search for cases of product liability regarding hazards of chemical products. Once one enters the request, e.g. Product Liability and Chemicals on the termined and the computer has done its search, the number of cases found with the search request appears on the screen. Since this number may be large, one may want to narrow the request further (hazards of corrosive chemical products flammable chemical products, toxic chemical products, etc.). The computer indicates how many headnotes and/or cases have been retrieved and will be displayed. Once promising headnotes are found in a search, the searcher may ask to have the full text displayed. If it is not available on line, it s possible to find the case in its bound form. 

Foremost we hope - and believe - that chemoinformatics will become of increasing importance in the teaching of chemistry. The instruments and methods that are used in chemistry will continue to swamp us with data and we have to manage these data to increase our chemical knowledge. We have to understand more deeply, and exploit, the results of our experiments. Concomitantly, demands on the properties of the compounds that are produced by the chemical and pharmaceutical industries will continue to rise. We will need materials that are better we need them to be more selective, have fewer undesirable properties, able to be broken down easily in the environment without producing toxic by-products, and so on. This asks for more insight into the relationships between chemical structures and their properties. Furthermore, we have to plan and perform fewer and more efficient experiments. 

A sohd waste is considered hazardous if it is either a Hsted waste or a characteristic waste. Listed wastes include a Hst of specific processes that generate a waste and a Hst of discarded commercial chemical products. There are four hazardous waste characteristics ignitabiHty, corrosivity, reactivity, and toxicity. The last refers to the leachabiHty of a waste and the resultant toxicity in the groundwater using the analytical method referred to as toxicity characteristic leaching procedure (TCLP). A Hst of substances included under TCLP is shown in Table 1. 

Toxic Substances Control Act. EPA regulates the manufacture, use, and exposure to ha2ardous or toxic chemicals under a number of laws. Eor the chemical industry, the law of prime concern is the Toxic Substance Control Act (TSCA) (10), which was passed by the U.S. Congress in 1976. The two main goals of TSCA are acquisition of sufficient information to identify and evaluate potential ha2ards from chemical substances, and regulation of the production, use, distribution, and disposal of these substances. 

The Toxic Substances Control Act (TSCA) was enacted in 1976 to identify and control toxic chemical ha2ards to human health and the environment. One of the main provisions of TSCA was to estabUsh and maintain an inventory of all chemicals in commerce in the United States for the purpose of regulating any of the chemicals that might pose an unreasonable risk to human health or the environment. An initial inventory of chemicals was estabhshed by requiring companies to report to the United States Environmental Protection Agency (USEPA) all substances that were imported, manufactured, processed, distributed, or disposed of in the United States. Over 50,000 chemical substances were reported. PoUowing this initial inventory, introduction of all new chemical substances requires a Premanufacturing Notification (PMN) process. To be included in the PMN are the identity of the new chemical, the estimated first year and maximum production volume, manufacture and process information, a description of proposed use, potential release to the environment, possible human exposure to the new substance, and any health or environmental test data available at the time of submission. In the 10 years that TSCA has been in effect, the USEPA has received over 10,000 PMNs and up to 10% of the submissions each year are for dyes (382)... 

Hydrolysis of Nitriles. The chemical hydrolysis of nitriles to acids takes place only under strong acidic or basic conditions and may be accompanied by formation of unwanted and sometimes toxic by-products. Enzymatic hydrolysis of nitriles by nitrile hydratases, nittilases, and amidases is often advantageous since amides or acids can be produced under very mild conditions and in a stereo- or regioselective manner (114,115). 

For organic toxic chemicals and their degradation products the number of possibilities is very high. The environmental samples composition usually is very complicated. Unambiguous identification needs serial-pai allel strategy of analysis with many-stage crosschecking of data. 

Toxic chemicals can enter the body in various ways, in particular by swallowing, inhalation and skin absorption. Skin absorption may lead to dermatitis and this can be a most annoying complaint. Whereas some chemicals may have an almost universal effect on human beings, others may attack only a few persons. A person who has worked with a given chemical for some years may suddenly become sensitised to it and from then on be unable to withstand the slightest trace of that material in the atmosphere. He may as a result also be sensitised not only to the specific chemical that caused the initial trouble but to a host of related products. Unfortunately a number of chemicals used in the plastics industry have a tendency to be dermatitic, including certain halogenated aromatic materials, formaldehyde and aliphatic amines. 

Hydrogen cyanide (prussic acid) is a liquid with a boiling point of 26°C. Its vapour is flammable and extremely toxic. The effects of acute exposure are given in Table 5.34. This material is a basic building block for the manufacture of a range of chemical products such as sodium, iron or potassium cyanide, methyl methacrylate, adiponitrile, triazines, chelates. 

The testing of chemicals/wastes to establish the nature of their hazard capacity/threat in accordance with regulatory requirements falls into four categories (1) reactivity, (2) ignitability/flammability, (3) corrosivity, and (4) EP toxicity. Commercial chemical products, specific wastes, and wastes from specific processes may be listed as hazardous wastes because they are known to present toxic hazards in the manner of the tests above and/or are known to present serious toxic hazards to mammals/humans. In the discussion to follow, various chemical groups will be examined primarily in the context of reactivity, ignitability, and corrosivity. 

Laboratories Listed toxic chemicals that are manufactured, processed, or otherwise used in laboratory activities at a covered facility under the direct supervision of a technically qualified individual do not have to be factored into the threshold and release calculations. However, pilot plant scale and specialty chemical production do not qualify for this laboratory activities exemption. 

The term manufacture also includes coincidental production of a toxic chemical (e.g., as a byproduct or impurity) as a result of the manufacture, processing, use, or treatment of other chemical substances. In the case of coincidental production of an impurity (i.e., a chemical that remains in the product that is distributed in commerce), the de minimis limitation, discussed on page 11, applies. The de minimis limitation does not apply to byproducts (e.g., a chemical that is separated from a process stream and further processed or disposed). Certain listed toxic chemicals may be manufactured as a result of wastewater treatment or other treatment processes. For example, neutralization of acid wastewater can result in the coincidental manufacture of ammonium nitrate (solution). 

Use Exemptions. Certain uses of listed chemicals are specifically exempted use as a structural component of the facility use in routine janitorial or facility grounds maintenance personal uses by employees or other persons use of products containing toxic chemicals for the purpose of maintaining motor vehicles operated by the facility or use of toxic chemicals contained in intake water (used for processing or noncontactcooling) or in Intake air (used eitheras compressed air or for combustion). 

Toxic chemicals in mixtures and in trade name products must be factored into threshold and release determinations. 

De Minimis Limitation. A listed toxic chemical does not have to be considered if it Is present in a mixture at a concentration below a specified de nvnimis level. The de minimis level is 1.0%, or 0.1% if the chemical meets the OSHA carcinogen standard. See Table II for the de minimis value associated with each listed toxic chemical. For mixtures that contain more than one member of a listed chemical category, the de minimis level applies to the aggregate concentration of all such members and not to each individually. EPA included the de minimis exemption In the njle as a burden reducing step, primarily because facilities are not likely to have information on the presence of a chemical in a mixture or trade name product beyond that available in the product s MSDS. The de minimis levels are consistent with OSHA requirements lor development of MSDS information concerning composition. 

A listed toxic chemical in a mixture or trade name product received by the facility. 

Supplier Notification. In 1989 and subsequent years, suppliers of facilities in SIC codes 20-39 are required to develop and distribute a notice if the mixtures or trade name products that they manufacture or process, and subsequently distribute, contain listed toxic chemicals. These notices are distributed to other companies in SIC codes 20-39 or to companies that sell the product to facilities in SIC codes 20-39. tf a Material Safety Data Sheet (MSDS) is not required for the mixture or trade name product, the notification must be in written form (i.e., letter or attachment to a MSDS). Otherwise, the notice must be incorporated into or attached to the MSDS for that product. The supplier notification requirement began with the first shipment of a product in 1989 and must accompany the first shipment each year thereafter. In addition, a new or revised notice must be sent if a change occurs in the product which affects the weight percent of a listed chemical or if it is discovered that a previous notice did not property identify the chemicals or the percentage by weight. For more information on supplier notification, see Appendix E. 

If listed toxic chemicals are present equal to or above the de minimis cut-off level, your supplier must identify the specific components as they appear in Table II and provide their percentage composition by weight in the mixture or product, tf your supplier maintains that the identity ot a toxic chemical is a trade secret, a generic identity that is structurally descriptive must be supplied on the notice. A maximum concentration level must be provided if your supplier contends that chemical composition information is a trade secret. In either case, you do not need to make a trade secret claim on behalf of your supplier (unless you consider your use of the proprietary mixture a trade secret). On Form R, identify the toxic chemical you are reporting according to its generic name provided in the notification. (See the instructions for Part III, Section 2 on page 18 for more information.) tf the listed chemical is present below the de minimis level, no notification is required. 

Any toxic chemicals in mixtures or trade name products (M/TNP) must be factored into your threshold and release determinations. 

In this part of the form, you ara required to list all off-sIte locations to which you transfer wastes containing toxic chemicals. Do not list locations to which products containing toxic chemicals are shipped for sale or distribution in commerce or for further use. Also, do not list locations to which wastes containing chemicals are sold or sent for recovery, recycling, or reuse of the toxic chemicals. The information that you enter in this section relates to data you will report in Part III, Section 6. 

You are not required to count, as a release, quantities of a toxic chemical that are lost due to natural weathering or corrosion, normal/natural degradation of a product, or normal migration of a chemical from a product. For example, amounts of a covered toxic chemical that migrate from plastic products in... 

You must estimate, as accurately as possible, the quantity (in pounds) of the chemical or chemical category that is released annually to each environmental medium. Include only the quantity of the toxic chemical contained in the wastestream in this estimate. If the toxic chemical present at your facility was part of a mixture or trade name product, calculate only the releases of the chemical, not the other components of the mixture or trade name product. If you are only able to estimate the releases of the mixture or trade name product as a whole, you must assume that the release of the toxic chemical is... 

This column should be completed as described in the instructions for column A of Section 5 above. Enter the amount, in pounds, of the toxic chemical that is being transferred, including mixtures or trade name products containing the chemical. Do not enter the total poundage of wastes. See Section 5 for information on reporting off-site transfers of less than 1 pound As in Section 5, if the total amount transferred is less than 1,000 pounds, you may report a range, but only for reporting years 1987, 1988, and 1989. Enter not applicable, NA, in column A.2 if you have no off-site transfers of the listed chemical. 

Information provided in Part III. Section 8. of Form R is optional. In this section, you may identify waste minimization efforts relating to the reported toxic chemical. Waste minimization reduces the amount of the toxic chemicai in wastes by reducing waste generation or by recycling. This can be accomplished by equipment changes, process modifications, product reformulation, chemical substitutions, or other techniques. Waste minimization refers exclusively to practices which prevent the generation of wastes. Treatment or disposal does not minimize waste and should not be reported In this section. Recycling or reuse of a toxic chemical is considered waste minimization. Waste minimization applies to air emissions and wastewater, as well as to liquid or solid mate-... 

The following Is a hypothetical example of how one manufacturer might complete the toxic chemical release inventory reporting Form R. The facility information is purely fictitious and does not represent any known manufacturing facility. The example begins with descriptions of the facility (a lead-acid storage battery manufacturer) and of the production process at the faciiity. The completion of each section of Form R is explained and a copy of Form R, as it would be completed by this facility, follows. 

Because manufacturers reporting under section 313 must know the toxic chemical composition of the products they use to be able to accurately calculate releases, EPA requires some suppliers of mixtures ortrade name products containing one or more of the listed section 313 chemicals to notify their customers. This requirement has been in effect since January 1, 1989. 

The language of the supplier notification requirements covers mixtures or trade name products that are sold or otherwise distributed. The "otherwise distributes" language applies to intra-company transfers. However, if the company has developed an internal communications procedure that alerts their other facilities to the presence and content of covered toxic chemicals in their products, then EPA would accept this. 

A statement that the mixture or trade name product contains a toxic chemical or chemicals subject to the reporting requirements of section 313 of EPCRA (40 CFR 372) ... 

The percentage, by weight, of each toxic chemical (or all toxic chemicals within a listed category) contained in the mixture or trade name product. 

For each mixture ortrade name product that contains a listed toxic chemical, you will have to notify all customers in SIC codes 20-39 or distributors who in turn sell that product to firms in SIC codes 20-39. Unless you know othenvise, you should assume that the chain of distribution includes facilities in SIC codes 20-39. (The notification is limited to SIC 20-39 facilities and their suppliers because only facilities in those SIC codes are required to report releases under section 313.)... 

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