From: Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU>
Subject: Re: [DCHAS-L] Chemical Safety headlines (10 articles)
Date: Mon, 14 Feb 2022 18:51:00 +0000
Reply-To: Monona Rossol <actsnyc**At_Symbol_Here**CS.COM>
Message-ID: 1555319031.2069494.1644864660380**At_Symbol_Here**mail.yahoo.com
In-Reply-To <14F9C4BF-DCFB-4A39-9F73-13627351826A**At_Symbol_Here**ilpi.com>


Rob,  look at the structure.  Just where do you think that pentachlorophenol laurate molecule will come apart either in the environment or the body? The H+ on the hydroxyl that makes PCP a "phenol" has popped off as has the Na+ on the sodium laurate and they are now stuck together -- temporarily.    And just how do you think the PCP laurate turned out to be a perfect substitute for PCP in so many products?  It does the same thing, because it IS essentially the same thing. 

We have to ban all the salts, esters, and chemicals that metabolize or degrade to produce the PCP or we are just kidding ourselves.

Since I talked about phthalates and we are talking about a chlorine substituted benzine ring, how about looking at the untested Chemtura Fire Master 550 that takes a banned diethylhexylpthalate (DEHP), substitutes the four hydrogens on the benzene ring in the DEHP with chlorine, calls the resulting Frankenstein a new untested chemical and it can be found in the dust in most homes in the US since it migrates out of your plastics and fabrics?  That comes under the heading of "how dare you?"

That's why I love the way the E.U. thinks about chemical regulations using the precautionary principle.  The best example is the Dye Directive.  It addresses the thousands of untested dyes by listing 22 known carcinogens and if the dye can be shown to breakdown or metabolize to release any of those 22 carcinogens that untested dye IS a carcinogen under this reg and it can't be used on products that contact the skin.  Hooray for common sense.

Now I can just go to the Colour Index, look up the structure of an azo dye, bust up the structure at all the azo bonds, look at the bits left over, and take a stab at figuring it out.

So.....we may have a partial solution here.  Let's start by degrading and/or metabolizing new chemicals and see what we get.  In many cases, we may get a known bad actor and we can cross it off the list of stuff we want in our products without having to fight for testing.

Monona






-----Original Message-----
From: Info <info**At_Symbol_Here**ILPI.COM>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Mon, Feb 14, 2022 11:16 am
Subject: Re: [DCHAS-L] Chemical Safety headlines (10 articles)

This appears to be a cancellation of the EPA registration for all products *containing* pentachlorophenol. My read is that it refers to the specific molecule only; pentachlorophenol laureate does not contain pentachlorophenol just as styrene does not contain benzene.

Pentachlorophenol and its salts and esters are listed in Annex I to Regulation 2019/1021 implementing the Stockholm Convention on Persistent Organic Pollutants, and so are banned in the EU. https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/12516-Chemical-pollutants-new-limits-for-pentachlorophenol_en  See also http://www.pic.int/Portals/5/DGDs/DGD_Pentachlorophenol_EN.pdf 

The EPA has contact info of Peter Bergquist regarding this, so you might just want to contact him directly. See https://www.govinfo.gov/content/pkg/FR-2022-02-04/html/2022-02418.htm  I don't see anything in the Federal Register addressing registration of derivatives. In fact, the document mentions there are only four registered antimicrobial products containing pentachlorophenol as an active ingredient, so it certainly looks like they are acting only on that one chemical. https://www.regulations.gov/document/EPA-HQ-OPP-2014-0653-0071  The regulation appears narrowly targeted to its use in wood preservation products only.

Rob Toreki


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On Feb 14, 2022, at 10:14 AM, Monona Rossol <0000030664c37427-dmarc-request**At_Symbol_Here**LISTS.PRINCETON.EDU> wrote:

Has anyone read over this reg?  I don't have time.  But the same kind of regulation was proposed in the 1980s and the manufacturers of on art conservation product just switched to pentachlorophenol laureate and keep selling it.  Is this reg going to apply to pentachlorophenol's many siblings?

Monona

EPA AXES PENTACHLOROPHENOL WOOD PRESERVATIVE
Tags: public, discovery, environmental, illegal, pesticides

Companies can produce, distribute, and sell the wood preservative pentachlorophenol in the US for only 2 more years, the US Environmental Protection Agency announced Feb. 4. Wood treatment facilities, however, have until 2027 to use up their existing stocks of the chemical. The National Toxicology Program lists pentachlorophenol as a "reasonably anticipated" human carcinogen. It is banned under the United Nations' Stockholm Convention on Persistent Organic Pollutants, an international treaty the US signed but has not ratified. The EPA claims that pentachlorophenol poses health risks to workers. Alternative wood preservatives-including chromated arsenicals, copper naphthenate, creosote, and dichloro-octyl-isothiazolinone-are available, the EPA says. Environmental groups have been urging the EPA for decades to ban pentachlorophenol. The chemical is persistent in the environment and contaminates about 250 Superfund hazardous waste sites where it was made, according to!
  the advocacy group Beyond Pesticides.



-----Original Message-----
From: Ralph Stuart <membership**At_Symbol_Here**DCHAS.ORG>
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Sent: Mon, Feb 14, 2022 6:37 am
Subject: [DCHAS-L] Chemical Safety headlines (10 articles)

Chemical Safety Headlines From Google
Monday, February 14, 2022 at 6:37:06 AM

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