The Chemical Right-to-Know Program (ChemRTK), not to be confused with OSHA's workplace safety Right-to-Know Program, is a comprehensive new initiative formed through a cooperative agreement between the Environmental Protection Agency (EPA), the Chemical Manufacturers Association (CMA) and the Environmental Defense Fund (EDF). The program is designed to ensure that adequate information is available to the public to assess risks for chemicals that are present in the local environments.

In 1997, the study, Toxic Ignorance, prepared by the EDF, raised a variety of concerns about untested chemicals that are manufactured and imported into the U.S. A year later, the chemical industry, through the CMA, the EPA and EDF, initiated a three-part program to address these concerns. Of the three parts of ChemRTK, the High Production Volume (HPV) program is actively under way.

The HPV program affects 2800 chemicals manufactured or imported into U.S. industry in volumes exceeding one million pounds, as reported to the EPA under the 1990 Inventory Update Rule (IUR). The goal of the program is for the HPV chemicals to be tested by the year 2004 to determine their environmental risks. The required testing must be completed in order for companies to continue to sell an HPV chemical. Estimates for industry testing costs range from $500-750 million.

How will HPV testing affect you?
Many chemicals typically used in polyurethane elastomer processing are included on the HPV list. For example, all the commonly used isocyanates (TDI, MDI, HMDI, IPDI, HDI and PPDI) are included, and an industry consortium is already formed to address isocyanate HPV issues. Prepolymers made from these isocyanates, considered as polymers by the EPA, are not HPV listed and are not subject to additional testing. Most curatives, including Lonzacure MCDEA®, Versalink® 740M, Ethacure® 300, BDO, PTMEG and CHDM curatives are not listed on HPV. Mboca, however, is included on the HPV list, and will require additional testing.

What should you be doing as a result of HPV?
Talk to your suppliers, find out the status of their products relative to HPV and understand their industry's plans to carry out necessary testing. Make sure you know whether you will have a source of supply when the testing deadlines arrive in 2004. Testing will result in new hazards information. Expect changes in MSDS, labels and personal protective equipment recommendations. Think about switching to different, less hazardous raw materials that still meet your performance requirements, if appropriate. And tell your employees and neighbors about the HPV program. It's a positive part of the chemical industry's commitment to Responsible Care® and Product Stewardship, and will help make the industry a safer place to work.

The above article is an excerpt from a paper presented by Dr. Charles Bartish of Air Products at the Polyurethane Manufacturers Association Spring 1999 meeting in Hilton Head, South Carolina. For a complete copy of the paper, call our Product Information Center at (800) 345-3148 or 610-481-6799.