Thursday, October 28, 2010

59 Ways to Lose Your Liver: Chemicals of Concern for Kids

The title of this piece could also be: 59 ways to lose your livelihood... it all depends on your point of view.  If you're a manufacturer trying to keep up with the proliferating state, regional, national, and international chemical management laws -- you might want to slip out the back, Jack.

This week, the Washington State Department of Ecology published a list of 59 chemicals of high concern for children.  The list was selected from a pool of roughly 2,000 prospective chemicals that are, as ABC News/AP put it, known to:
  1. cause cancer
  2. harm fetal development
  3. influence endocrine systems
among other undesirable side effects -- where exposure reaches certain threshold ranges and if conditions allow. 

Problem is not inside your head

The Department of Ecology is proposing to adopt the Children′s Safe Products Reporting Rule. The proposal notice will be published in the Washington State Register on November 3rd, 2010.  The purpose of the proposed rule is to implement the reporting requirements of the Children′s Safe Product Act.

Online comment form is here if you have something to say about it.

Washington law requires that identifiable public records be made available promptly to members of the public for inspection and copying upon request. Some software is available on the market for material disclosure. Only records that are exempt by law may be withheld from disclosure.

Department of Ecology has begun formal rule making to carry out the reporting requirements created by the law. The agency released the proposed rules on Monday, October 25 and expects to finalize them early 2011. 

Make a new plan, Stan

The Children's Safe Product Act (CSPA) is part of Washington's greater Reducing Toxic Threats Initiative.  It certainly gets media attention.  Even though the era of helicopter parenting and "Oh No! Save the schoolchildren from dust-mites!" is mercifully over, and frankly sometimes this sort of billing can seem quite gimmicky, fact is that limiting children's exposure to toxic chemicals will never go out of style.

Washington's Children's Safe Product Act (CSPA) requires that government officials draft a list of chemicals of concern.  The current list has 59 chemicals on it.  The act requires that if any chemicals from the list of 59 appear in a product, the manufacturer will have to report the presence of the chemical in the product or in the product component.

The Associated Press reported that the Toy Industry Association felt the chemical levels that require reporting might be too low.  Here is an interesting letter of response to the initial draft pilot rule of the Children's Safe Products Act (dated January 28, 2010) from the Toy Industry Association; it makes several interesting suggestions, such as ensuring that manufacturers are only responsible for chemicals and substances that are "intentionally" put in products. 

Don't need to be coy

Notably, insists the Washington Dept. of Ecology, the mere presence of these chemicals in children’s products does not necessarily indicate that there is a risk of exposure. "When was the last time you licked the ankle area of the inside of a boot?" is one recent battle-cry. While the point is fair, whoever said it may not have spent a lot of time around children; pretty much everything ends up in their mouths, all over their hands, and on their toes.

Anyway, as stated the point of the Act isn't to get into nickels and dimes about how much cadmium is too much -- the point is: why not just call a toxin a toxin and use another, safer, ingredient in its place?  Threshold debates get very tedious and hold up the process.  That, at least, is the point of view of lawmakers in Washington.

If the rule is fully implemented, manufacturers of children's products would start mandatory reporting to the Washington State Department of Ecology in 2012 if their products contain chemicals of concern on the CHCC list. 

59 Ways to lose your livelihood

Can't resist a good subtitle, can we.

List is as follows.  You can also view and print the alphabetized CHCC list.  Place your comments at the end of this post if you have an immediate reaction.  Cheers.


CAS  Chemical
50-00-0 Formaldehyde
62-53-3 Aniline
62-75-9 N-Nitrosodimethylamine
71-36-3 n-Butanol
71-43-2 Benzene
75-01-4 Vinyl chloride
75-07-0 Acetaldehyde
75-09-2 Methylene chloride
75-15-0 Carbon disulfide
78-93-3 Methyl ethyl ketone
79-34-5 1,1,2,2-Tetrachloroethane
79-94-7 Tetrabromobisphenol A
80-05-7 Bisphenol A
84-75-3 Di-n-Hexyl Phthalate
86-30-6 N-Nitrosodiphenylamine
87-68-3 Hexachlorobutadiene
94-13-3 Propyl paraben
94-26-8 Butyl paraben
95-53-4 2-Aminotoluene
95-80-7 2,4-Diaminotoluene
99-76-3 Methyl paraben
99-96-7 p-Hydroxybenzoic acid
100-41-4 Ethylbenzene
100-42-5 Styrene
104-40-5 4-Nonylphenol; 4-NP and its isomer mixtures including CAS 84852-15-3 and CAS 25154-52-3
106-47-8 para-Chloroaniline
107-13-1 Acrylonitrile
107-21-1 Ethylene glycol
108-88-3 Toluene
108-95-2 Phenol
109-86-4 2-Methoxyethanol
110-80-5 Ethylene glycol monoethyl ester
115-96-8 Tris(2-chloroethyl) phosphate
118-74-1 Hexachlorobenzene
119-93-7 3,3'-Dimethylbenzidine and Dyes Metabolized to 3,3'-Dimethylbenzidine
120-47-8 Ethyl paraben
123-91-1 1,4-Dioxane
127-18-4 Perchloroethylene
131-55-5 Benzophenone-2 (Bp-2); 2,2',4,4'-Tetrahydroxybenzophenone
140-66-9 4-tert-Octylphenol; 1,1,3,3-Tetramethyl-4-butylphenol
140-67-0 Estragole
149-57-5 2-Ethylhexanoic Acid
556-67-2 Octamethylcyclotetrasiloxane
608-93-5 Benzene, pentachloro
842-07-9 C.I. Solvent Yellow 14
872-50-4 N-Methylpyrrolidone
1163-19-5 2,2',3,3',4,4',5,5',6,6'-Decabromodiphenyl ether; BDE-209
1763-23-1 Perfluorooctanyl sulphonic acid and its salts; PFOS
1806-26-4 Phenol, 4-octyl-
5466-77-3 2-Ethyl-hexyl-4-methoxycinnamate
7439-97-6 Mercury & mercury compounds including methyl mercury (22967-92-6)
7439-98-7 Molybdenum & molybdenum compounds
7440-36-0 Antimony & Antimony compounds
7440-38-2 Arsenic & Arsenic compounds including arsenic trioxide (1327-53-3) & dimethyl arsenic (75-60-5)
7440-43-9 Cadmium & cadmium compounds
7440-48-4 Cobalt & cobalt compounds
25013-16-5 Butylated hydroxyanisole; BHA
25154-52-3 Nonylphenol
25637-99-4 Hexabromocyclododecane

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You can also view and print the alphabetized CHCC list.