RadTech International North America (RadTech) provides resources to members and to the industry regarding regulatory, health and safety updates. Recent postings on RadTech.org offer information on BACT, TPO and ozone emissions.
BACT Listings for UV/EB
What is BACT? BACT (Best Available Control Technology) is a regulatory requirement under the Clean Air Act, referring to the most effective and technically feasible pollution-control method required for new or modified equipment. The federal version is called Lowest Achievable Emission Rate (LAER). Generally, local rules (especially in Southern California) are more stringent than federal requirements.
For UV/EB users, BACT means:
- using low-VOC to zero-VOC materials;
- demonstrating that UV/EB technology achieves emissions levels equivalent to (or better than) control devices; and
- meeting (or exceeding) regulatory requirements from various agencies (e.g., South Coast Air Quality Management District [SCAQMD], California Air Resources Board [CARB] and Environmental Protection Agency [EPA]).
Because BACT is determined on a case-by-case basis by each agency, the listings can be confusing and inconsistent across databases. This obscures the significant environmental and reporting benefits of UV/EB technology.
To address this, RadTech’s Environmental Health & Safety Committee (EHS), along with a volunteer team, has been advocating for the inclusion of UV/EB/LED in regulatory guidelines for more than decade. Led by Rita Loof, RadTech’s West Coast director, successful efforts to include UV+EB processes in the listings are a victory for the industry and part of RadTech’s commitment to easing regulatory compliance burdens.
Visit www.radtech.org for the listings, which include:
- screen printing on plastic stock (smart cards);
- screen printing posters, banners and brochures;
- coatings for sheets used in can manufacturing;
- wood product coatings; and
- lithographic printing.
Trimethylbenzoyl diphenylphosphine oxide (TPO) in Nail Products: Safety Review White Paper (members only)
RegTox Solutions, Inc. has developed a white paper summarizing hazard data for trimethylbenzoyl diphenylphosphine oxide (TPO), characterizing consumer and professional (salon) exposures for UV-cured nail applications; contextualizing margins of safety and mapping the findings to the US FDA cosmetics framework vs. the EU’s CMR-based approach; and citing TPO permissions in other jurisdictions.
The available evidence supports that the use of TPO in nail gels and other nail products at typical use levels (up to 5%) remains safe for consumers and salon workers with adequate margins of exposure. The estimated exposures are considered highly conservative based on the assumptions used and, therefore, actual (real-world) exposures likely are much lower. The EU prohibition of TPO in cosmetics is based on hazard criteria and does not include any risk assessment considerations. TPO remains permitted for use in cosmetics in other major markets (US, Canada, Australia, Japan).
Member Benefit: Regulatory Consultations
RadTech Members have the opportunity for personal consultations on regulatory questions.
Shannon Gainey, JM Huber Corporation: General chemical compliance questions – e.g. TSCA, EU-REACH etc.; Hazard Communication/GHS Classification & Labeling; Substances of Very High Concern (SVHC) Compliance. Gainey can be reached at email: shannon.gainey@huber.com; 331.771.1613 text/cell.
Rita Loof, RadTech, West Coast director: Air quality regulatory issues; educating policymakers and elected officials; UV/EB/UV LED test methods; regulatory troubleshooting. Loof can be reached at email: rita@radtech.org; 909.240.0866 text/cell.
