Lou DiBerardinis, my EHS Director, forwarded this thread to me
since I am responsible for the TSCA program at MIT.
No doubt we are going to see more on the risk science surrounding
3D printers. From a TSCA perspective, coatings/inks/polymers/resin
are not considered articles. Whatever resin is used to produce an object
from a 3D printer is regulated under TSCA.
A more interesting scenario would be if a naturally occurring resin
was somehow found to have applications in 3D printing and if that
naturally occurring resin turned out to have adverse human or environmental
health effects. As I understand it, EPA provides some exclusions under
the TSCA inventory for a naturally occurring compound.
Also, under TSCA, "article" is defined in a very particular way.
It is implicit the object will not change form in its end use (and in theory
not release any material to the environment). A metal pan would be
considered an article and not TSCA-regulated. A metal pan coated with
Teflon would be TSCA-regulated the Teflon is a coating, is in and of
itself not an article and is not inextricably bound to the metal pan.
On another note=E2=80=A6 how do I go about subscribing to this listserv?
Safety and Environmental Management Program Officer
MIT EHS Office
77 Massachusetts Avenue, Room N52-496
Cambridge, MA 02139
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Here is an interesting TSCA issue - the product of the printer is an object and therefore wouldn't be a TSCA applicable item. However, there was a similar issue with carbonless
paper when it first came out and that was determined to be a chemical under TSCA. So - let the discussion begin.
Frankie Wood-Black, Ph.D., REM, MBA
Principal - Sophic Pursuits