DCHAS-L Archives, Nov 7, 2015 - Re: FW: [DCHAS-L] [DCHAS-L] Interesting TSCA Issue

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, so SDSs 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

actsnyc**At_Symbol_Here**cs.com www.artscraftstheatersafety.org

-----Original Message-----
From: Susan Leite <smleite**At_Symbol_Here**MIT.EDU>
To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.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

___________________________________________________

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

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>

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

Interactive Learning Paradigms, Incorporated

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