Do we need a national plastics control law?

20 10 2010

John Wargo wears at least three hats:  he is a professor of environmental policy, risk analysis, and political science at the Yale School of Forestry & Environmental Studies, he chairs the Environmental Studies Major at Yale College, and is an advisor to the U.S. Centers for Disease Control and Prevention.  He published this opinion on plastics in the United States last year – and I couldn’t have said it better myself:

Since 1950, plastics have quickly and quietly entered the lives and bodies of most people and ecosystems on the planet. In the United States alone, more than 100 billion pounds of resins are formed each year into food and beverage packaging, electronics, building products, furnishings, vehicles, toys, and medical devices. In 2007, the average American purchased more than 220 pounds of plastic, creating nearly $400 billion in sales.

It is now impossible to avoid exposure to plastics. They surround and pervade our homes, bodies, foods, and water supplies, from the plastic diapers and polyester pajamas worn by our children as well as our own sheets, clothing and upholstery,  to the cars we drive and the frying pans in which we cook our food.

The ubiquitous nature of plastics is a significant factor in an unexpected side effect of 20th century prosperity — a change in the chemistry of the human body. Today, most individuals carry in their bodies a mixture of metals, pesticides, solvents, fire retardants, waterproofing agents, and by-products of fuel combustion, according to studies of human tissues conducted across the U.S. by the Centers for Disease Control and Prevention. Children often carry higher concentrations than adults, with the amounts also varying according to gender and ethnicity. Many of these substances are recognized by the governments of the United States and the European Union to be carcinogens, neurotoxins, reproductive and developmental toxins, or endocrine disruptors that mimic or block human hormones.

Significantly, these chemicals were once thought to be safe at doses now known to be hazardous; as with other substances, the perception of danger grew as governments tested chemicals more thoroughly. Such is the case with Bisphenol-A (BPA), the primary component of hard and clear polycarbonate plastics, which people are exposed to daily through water bottles, baby bottles, and the linings of canned foods.

Given the proven health threat posed by some plastics, the scatter shot and weak regulation of the plastics industry, and the enormous environmental costs of plastics — the plastics industry accounts for 5 percent of the nation’s consumption of petroleum and natural gas, and more than 1 trillion pounds of plastic wastes now sit in U.S. garbage dumps — the time has come to pass a comprehensive national plastics control law.

One might assume the United States already has such a law. Indeed, Congress adopted the Toxic Substances Control Act (TSCA) in 1976 intending to manage chemicals such as those polymers used to form plastics. Yet TSCA was and is fundamentally flawed for several reasons that have long been obvious. Nearly 80,000 chemicals are now traded in global markets, and Congress exempted nearly 60,000 of them from TSCA testing requirements. Among 20,000 new compounds introduced since the law’s passage, the U.S. Environmental Protection Agency (EPA) has issued permits for all except five, but has required intensive reviews for only 200. This means that nearly all chemicals in commerce have been poorly tested to determine their environmental behavior or effects on human health. The statute’s ineffectiveness has been recognized for decades, yet Congress, the EPA, and manufacturers all share blame for the failure to do anything about it.

In contrast, the European Union in 2007 adopted a new directive known as “REACH” that requires the testing of both older and newly introduced chemicals. Importantly the new regulations create a burden on manufacturers to prove safety; under TSCA the burden rests on EPA to prove danger, and the agency has never taken up the challenge. Unless the U.S. chooses to adopt similar restrictions, U.S. chemical manufacturers will face barriers to their untested exports intended for European markets. Thus the chemical industry itself recognizes the need to harmonize U.S. and EU chemical safety law.

The most promising proposal for reform in the U.S. is the “Kid-Safe Chemical Act,” a bill first introduced in 2008 that would require industry to show that chemicals are safe for children before they are added to consumer products. Such a law is needed because there is little doubt that the growing burden of synthetic chemicals has been accompanied by an increase in the prevalence of many illnesses during the past half-century. These include respiratory diseases (such as childhood asthma), neurological impairments, declining sperm counts, fertility failure, immune dysfunction, breast and prostate cancers, and developmental disorders among the young. Some of these illnesses are now known to be caused or exacerbated by exposure to commercial chemicals and pollutants.

Few people realize how pervasive plastics have become. Most homes constructed since 1985 are wrapped in plastic film such as Tyvek, and many exterior shells are made from polyvinyl chloride (PVC) siding. Some modern buildings receive water and transport wastes via PVC pipes. Wooden floors are coated with polyurethane finishes and polyvinyl chloride tiles.

Foods and beverages are normally packaged in plastic, including milk bottles made from high-density polyethylene. Most families have at least one “non-stick” pan, often made from Teflon, a soft polymer that can scratch and hitchhike on foods to the dinner table. Between 1997 and 2005, annual sales of small bottles of water — those holding less than one liter — increased from 4 billion to nearly 30 billion bottles.

The billions of video games, computers, MP3 players, cameras, and cell phones purchased each year in the United States use a wide variety of plastic resins. And the almost 7.5 million new vehicles sold in the United States each year contain 2.5 billion pounds of plastic components, which have little hope of being recycled, especially if made from polyvinyl chloride or polycarbonate.  The American Plastics Council now estimates that only about 5 percent of all plastics manufactured are recycled; 95 billion pounds are discarded on average yearly.

The chemical contents of plastics have always been a mystery to consumers. Under federal law, ingredients need not be labeled, and most manufacturers are unwilling or unable to disclose these contents or their sources. Indeed, often the only clue consumers have to the chemical identity of the plastics they use is the voluntary resin code designed to identify products that should and should not be recycled — but it offers little usable information.

The true costs of plastics — including the energy required to manufacture them, the environmental contamination caused by their disposal, their health impacts, and the recycling and eventual disposal costs — are not reflected in product prices.  Adding to the environmental toll, most plastic is produced from natural gas and petroleum products, exacerbating global warming.

Plastics and Human Health

The controversy over BPA — the primary component of hard and clear plastics — and its potential role in human hormone disruption provides the most recent example of the need for a national plastics control law.

Normal growth and development among fetuses, infants, children, and adolescents is regulated in the body by a diverse set of hormones that promote or inhibit cell division. More than a thousand chemicals are now suspected of affecting normal human hormonal activity. These include many pharmaceuticals, pesticides, plasticizers, solvents, metals, and flame retardants.

Scientists’ growing interest in hormone disruption coincided with a consensus within the National Academy of Sciences that children are often at greater risk of health effects than adults because of their rapidly growing but immature organ systems, hormone pathways, and metabolic systems. And many forms of human illness associated with abnormal hormonal activity have become more commonplace during the past several decades, including infertility, breast and prostate cancer, and various neurological problems.

BPA illustrates well the endocrine disruption problem. Each year several billion pounds of BPA are produced in the United States. The Centers for Disease Control and Prevention has found, in results consistent with those found in other countries, that 95 percent of human urine samples tested have measurable BPA levels. BPA has also been detected in human serum, breast milk, and maternal and fetal plasma. BPA travels easily across the placenta, and levels in many pregnant women and their fetuses were similar to those found in animal studies to be toxic to the reproductive organs of the animals’ male and female offspring.

Government scientists believe that the primary source of human BPA exposure is foods, especially those that are canned, as BPA-based epoxy resins can migrate from the resins into the foods. In 1997, the FDA found that BPA migrated from polycarbonate water containers — such as the five-gallon water jugs found in offices — into water at room temperature and that concentrations increased over time. Another study reported that boiling water in polycarbonate bottles increased the rate of migration by up to 55-fold, suggesting that it would be wise to avoid filling polycarbonate baby bottles with boiling water to make infant formula from powders.

Scientists have reported BPA detected in nonstick-coated cookware, PVC stretch film used for food packaging, recycled paperboard food boxes, and clothing treated with fire retardants.

Since 1995 numerous scientists have reported that BPA caused health effects in animals that were similar to diseases becoming more prevalent in humans, abnormal penile or urethra development in males, obesity and type 2 diabetes, and immune system disorders. BPA can bind with estrogen receptors in cell membranes following part-per-trillion doses — exposures nearly 1,000 times lower than the EPA’s recommended acceptable limit.

In 2007, the National Institutes of Health convened a panel of 38 scientists to review the state of research on BPA-induced health effects. The panel, selected for its independence from the plastics industry, issued a strong warning about the chemical’s hazards:

“There is chronic, low level exposure of virtually everyone in developed countries to BPA… The wide range of adverse effects of low doses of BPA in laboratory animals exposed both during development and in adulthood is a great cause for concern with regard to the potential for similar adverse effects in humans.”

The American Chemistry Council, which advocates for the plastics industry, has criticized most scientific research that has reported an association between BPA and adverse health effects. The council’s complaints have included claims that sample sizes are too small, that animals are poor models for understanding hazards to humans, that doses administered in animal studies are normally far higher than those experienced by humans, that the mechanism of chemical action is poorly understood, and that health effects among those exposed are not necessarily “adverse.”

Research on plastics, however, now comprises a large and robust literature reporting adverse health effects in laboratory animals and wildlife at even low doses. Claims of associations between BPA and hormonal activity in humans are strengthened by consensus that everyone is routinely exposed and by the rising incidence of many human diseases similar to those induced in animals dosed with the chemical. Two competing narratives — one forwarded by independent scientists and the other promoted by industry representatives — have delayed government action to protect the health of citizens through bans or restrictions.

Action Needed

How has the plastics industry escaped serious regulation by the federal government, especially since other federally regulated sectors that create environmental or health risks such as pharmaceuticals, pesticides, motor vehicles, and tobacco have their own statutes? In the case of plastics, Congress instead has been content with limited federal regulatory responsibility, now fractured among at least four agencies: the EPA, the Food and Drug Administration, the Consumer Product Safety Commission, and the Occupational Safety and Health Administration. None of these agencies has demanded pre-market testing of plastic ingredients, none has required ingredient labeling or warnings on plastic products, and none has limited production, environmental release, or human exposure. As a result, the entire U.S. population continues to be exposed to hormonally active chemicals from plastics without their knowledge or consent.

What should be done? The Kids Safe Chemical Act represents a comprehensive solution that would apply to all commercial chemicals including plastic ingredients. Yet the nation’s chemical companies, with their enormous political power, are not likely to agree to assume the testing costs, nor are they likely to accept a health protective standard. Rather than pass another weak statute, Congress should consider a stronger alternative.

The nation needs a comprehensive plastics control law, just as we have national laws to control firms that produce other risky products, such as pesticides. Key elements of a national plastics policy should include:

  • tough  government regulations that demand pre-market testing and prohibit chemicals that do not quickly degrade into harmless compounds. Exempting previously permitted ingredients from this evaluation makes little sense, as older chemicals have often been proven more dangerous than newer ones.
  • The chemical industry itself needs to replace persistent and hazardous chemicals with those that are proven to be safe.  Plastics ingredients found to pose a significant threat to the environment or human health should be quickly phased out of production. Congress chose this approach to manage pesticide hazards, and it has proven to be reasonably effective since the passage of the Food Quality Protection Act in 1996.
  • Federal redemption fees for products containing plastics should be set at levels tied to chemical persistence, toxicity, and production volume. These fees should be high enough that consumers have a strong incentive to recycle.
  • We need mandatory labeling of plastic ingredients, in order to allow consumers to make responsible choices in the marketplace.
  • Finally, manufacturers should take responsibility for cleaning up environmental contamination from the more than one trillion pounds of plastic wastes they have produced over the past 50 years.
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Optical brighteners

14 07 2010

I got a call awhile ago from Harmony Susalla, founder and chief designer for Harmony Art  (if you haven’t seen her glorious fabrics go right now to www.harmonyart.com).  She was wondering about optical brighteners, and I discovered I couldn’t tell her much except to say that some are derived from benzene, which is a chemical nobody wants to live with.  GOTS allows the use of optical brighteners – with caveats (see below) – but they are supposed to reevaluate them “in two years from date of adoption” of version 2.0, which puts the reevaluation right about now.

So let’s explore optical brighteners, which are used extensively in:

  • Laundry detergents (to replace whitening agents removed during washing and to make the clothes appear cleaner.) – detergents may contain up to 0.2% whitening agents,
  • Paper, especially high brightness papers, resulting in their strongly fluorescent appearance under UV illumination. Paper brightness is typically measured at 457nm, well within the fluorescent activity range of brighteners. Paper used for banknotes does not contain optical brighteners, so a common method for detecting counterfeit notes is to check for fluorescence.
  • Cosmetics: One application is in formulas for washing and conditioning grey or blonde hair, where the brightener can not only increase the luminance and sparkle of the hair, but can also correct dull, yellowish discoloration without darkening the hair).  Some advanced face and eye powders contain optical brightener microspheres that brighten shadowed or dark areas of the skin, such as “tired eyes”.
  • as well as fabrics, which may contain 0.5% OBAs. A side effect of textile optical whitening is to make the treated fabrics more visible with Night Vision Devices than non-treated ones (the fluorescence caused by optical brighteners can easily be seen with an ordinary black light). This may or may not be desirable for military or other applications

You can still buy “bluing” – which is advertised to “whiten whites and brighten colors”.  Bluing works by removing yellow light to lessen the yellow tinge.   Optical brighteners – also called optical brightening agents (OBAs), fluorescent brightening agents (FBAs), and/or fluorescent whitening agents (FWAs) or “synthetic fluorescent dyes” –  work a bit differently.  Optical brighteners are chemicals similar to dyes which absorb ultraviolet light and emit it back as visible blue light – in other words, they fluoresce the ultraviolet light into visible light. The blue light emitted by the brightener compensates for the diminished blue of the treated material and changes the hue away from yellow or brown and toward white.

They are designed to mask yellow or brown tones in the fibers and make the fabric look cleaner and brighter than it would otherwise appear to the naked eye.   In other words, the undesirable color is made invisible to the eye in an “optical manner”.  Optical brighteners are used both on natural fibers (cotton, linen, hemp, silk) as well as in polymer melts for polyester and other synthetic fiber production.

Optical brighteners aren’t effective unless they remain in the fabric, and persist after washing.  They only last so long, until the point when they actually burn out and no longer do anything. They are also subject to fading when exposed long term to UV.

Brighteners can be “boosted” by the addition of certain polyols like high molecular weight polyethylene glycol or polyvinyl alcohol. These additives increase the visible blue light emissions significantly. Brighteners can also be “quenched”. Too much use of brightener will often cause a greening effect as emissions start to show above the blue region in the visible spectrum.

Optical brighteners are synthesized from various chemicals.  The group of chemicals which are called “optical brighteners” consists of approximately 400 different types listed in the Color Index, but less than 90 are produced commercially. (To get more information about the Color Index click here .)

Basic classes of chemicals used in OBAs  include:

  • Triazine-stilbenes (di-, tetra- or hexa-sulfonated)
  • Coumarins
  • Imidazolines
  • Diazoles
  • Triazoles
  • Benzoxazolines
  • Biphenyl-stilbenes

Using these chemicals, many companies compose their own chemical versions of an optical brightener, and sell it under a branded name, such as:

  • Blankophar R
  • Calcofluor
  • Uvitex
  • Bluton
  • CBS
  • DMS E=416
  • Kolorcron 2B

To find out what is in the optical brightener in any fabric, you must know the name of the optical brightener, and also the C.I. number (such as Brightener 24 or 220).  Then you can look up the chemical composition of the substance – but  only if you’re a subscriber to the Color Index database.  So it’s pretty difficult to confirm what is actually in an optical brightener.

In exploring some of the chemicals used in formulating optical brighteners,  I found one called cyanuric chloride, a derivative of 1,3,5 triazine.  Cyanuric chloride is used as a precursor and crosslinking agent in sulfonated triazine-stilbene based optical brighterners.   It is also classified as “very toxic”, “harmful” and “corrosive” by the EU and has several risk phrases identified with it – including R26 (“very toxic by inhalation”).  R26 is a substance which is specifically prohibited by GOTS.  So how can optical brighteners be allowed under GOTS?

The short answer is:  some are allowed, some are not – it depends on the chemical composition of each individual optical brightener.   Like dyestuffs, GOTS allows optical brighteners if they “meet all criteria for the selection of dyes and auxiliaries as defined in chapter 2.4.6, Dyeing.”  Those criteria include the prohibition of all chemicals listed in 2.3.1 and substances which are assigned certain risk phrases “or combinations thereof”.   But in order to know if a particular optical brightener meets these criteria, it’s necessary to know the chemical formula for that brightener.   And that takes a bit of detective work – and even so you might not be able to get final answers.  Don’t you begin to feel like a hamster in one of those wheels going round and round?

What are the problems associated with optical brighteners?
Some brighteners have been proven to cause allergic skin reactions or eye irritation in sensitive people.   The German Textiles Working Group conducted a health assessment of various optical brightening agents  following concerns of potential health risks to the public. It was found that there is a general lack of information on toxicity and a need for studies into dermal  absorption and the release of these substances from clothes.  While it has not been shown to negatively affect health, it has also not been proven safe.

They are known to be toxic to fish and other animal and plant life and have been found to cause mutations in bacteria.

Most OBAs are not readily biodegradable, so chemicals remain in wastewater for long periods of time, negatively affecting water quality and animal and plant life.  It is assumed that the substances accumulate in sediment or sludge, leading to high concentrations.
In wastewater, OBAs can also leach into groundwater, streams, and lakes. Since fluorescence is easy to detect,  optical brightener monitoring is an emerging technique to quickly and cost-effectivley detect the contamination of stormwater by sanitary wastewater.

REACH is the new European Union regulation which aims to  improve human health and the environment through better and earlier identification of the properties of chemical substances.  REACH stands for Registration, Evaluation, Authorisation and Restriction of Chemical substances.   REACH contains provisions to reduce the use of what are called “high volume production” chemicals.  These are defined as chemicals having annual production and/or importation volumes above 1 million pounds.  It is assumed that high volume production is a proxy for high exposure; in addition, large releases of low toxicity substances such as salts do cause environmental harm due to the sheer volume of the substance.
Much of the impact from optical brighteners comes in the form of large releases of low toxicity substances.  A number of these optical brighteners are listed as high and low production volume substances and so will be subject to REACH.   For example, C.I. Fluorescent Brightener 220 is listed as a high production volume chemical.