From: Monona Rossol <actsnyc**At_Symbol_Here**>
Subject: Re: FW: [DCHAS-L] [DCHAS-L] Interesting TSCA Issue
Date: Fri, 6 Nov 2015 20:08:08 -0500
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: 150df7c794a-5a8e-2699**At_Symbol_Here**
In-Reply-To <8742A0AF3202EC48B445C01371FA9A3E87153940**At_Symbol_Here**>

Well, it really doesn't help much if 3D consumables are regulated under TSCA. EPA is not charged with protecting workers with the exception of workers manufacturing chemicals for which their is a significant new use rule (SNUR).  EPA does have jurisdiction over some particular chemicals such as pesticides and PCBs. 

And "naturally occurring" has absolutely nothing to do with safety for the 3D operator.  That's an environmental and sustainable issue not a safety one.

OSHA is responsible for the faculty's safety. It is the hazcom or lab standard definition of an article or a chemical substance that figures here..  And yes, these 3D consumables are chemicals, sSDSs are needed on them.  But those SDSs are not going to tell you squat.  Many of these chemicals have never been tested for toxicity. You are going to see a Section 11 full of the words "no data available." 

And the big issue is not the toxicity of the starting materials. Instead, the issue is what these chemicals and resins release when they are heated or altered in the process of printing and consolidating.  That requires testing of the emissions of the printers.

Manufacturers are not doing that emission testing.  I've seen a couple of independent studies, enough to make me worry.  Nanoparticles are one of those worries.

So like all new inventions, they are loosed on the public without any hazard assessment.  We will have to wait until there are some problems that are obvious before there will be any safeguards in place.

Monona Rossol, M.S., M.F.A., Industrial Hygienist
President:  Arts, Crafts & Theater Safety, Inc.
Safety Officer: Local USA829, IATSE
181 Thompson St., #23
New York, NY 10012     212-777-0062


-----Original Message-----
From: Susan Leite <smleite**At_Symbol_Here**MIT.EDU>
Sent: Fri, Nov 6, 2015 7:05 pm
Subject: [DCHAS-L] FW: [DCHAS-L] Interesting TSCA Issue

Hello everyone,
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?
Thank you,
Susan Leite
Safety and Environmental Management Program Officer
MIT EHS Office
77 Massachusetts Avenue, Room N52-496
Cambridge, MA  02139
(v) 617.253.5246
(f) 617.258.6831
Find safer chemical substitutes with the MIT Green Chemical Alternatives Wizard

Begin forwarded message:
From: Frankie Wood-Black <fwblack**At_Symbol_Here**CABLEONE.NET>
Date: November 6, 2015 at 4:07:40 PM EST
To: <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Subject: [DCHAS-L] Interesting TSCA Issue
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
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
6855 Lake Road
Ponca City, OK 74604

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