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… how do I go about subscribing to this listserv?

 

Thank you,

Susan

 

___________________________________________________

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

smleite**At_Symbol_Here**mit.edu

http://ehs.mit.edu

 

Find safer chemical substitutes with the MIT Green Chemical Alternatives Wizard

http://ehs.mit.edu/greenchem

 

 

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>

http://www.tcetoday.com/latest%20news/2015/november/3d-printed-objects-kill-fish.aspx#.Vj0V37erTcs

 

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

fwblack**At_Symbol_Here**cableone.net

580-761-3703