Recently, EPA released The Action Plan, to settle the potential health hazards caused by benzidine dyes; nonylphenol and nonylphenol; and hexabromocyclododecane.
Benzidine and its congeners are important precursors in the synthesis of dyes. Some of these dyes have the potential to metabolize to aromatic amines that are considered to be carcinogenic. Benzidine and dyes metabolized to benzidine are classified as known human carcinogens. Benzidine's congeners, 3,3'-dichlorobenzidine, 3,3'-dimethylbenzidine, and 3,3'-dimethoxybenzidine and dyes metabolized to the latter two congeners have all been classified as "reasonably anticipated to be human carcinogens."
Benzidine-based and congener-based dyes are used in the production of textiles, paints, printing inks, paper, and pharmaceuticals. These dyes have the potential to be leached from textiles, such as clothing, that are in prolonged contact with human skin. They are also used as reagents and biological stains in laboratories, are used in the food industries, and have more recent uses in laser, liquid crystal displays, ink-jet printers, and electro-optical devices.
Because these dyes have the potential to metabolize to carcinogenic amines both in and on the human body, on the basis of existing information, EPA believes that the following actions would be warranted:
1. Initiate rulemaking to add four benzidine-based dyes to an existing TSCA section 5(a)(2) significant new use rule (SNUR) for benzidine-based substances at 40 CFR 721.1660. A SNUR requires manufacturers who intend to use a chemical for the identified significant new use to submit an application to the Agency for review prior to beginning that activity.
2. Initiate rulemaking to establish a new TSCA section 5(a)(2) SNUR for benzidine congener-based dyes, including 44 specific such dyes.
3. Consider proposing to eliminate the article exemption applied to SNURs to address potential concerns for exposure to these dyes on imported finished textiles.
4. Consider initiating action under TSCA section 6 if EPA learns that these dyes are present in imported finished textiles.
5. Consider additional regulatory action, if EPA determines that there are other ongoing uses for these dyes and needs to obtain information necessary to determine whether those uses present concerns which need to be addressed.
Safety/EMC/Wireless
Inspection & Audit
Testing/Compliance/Consultation
(USA & CANADA)
