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Recycling end-of-life materials may be perpetuating toxic chemicals in new products

A researcher from the Canadian Environmental Law Association and paralegal, Fe de Leon, recently co-published a paper with HEJSupport International Co-Director Olga Speranskaya to bring public attention to toxic chemicals that appear in new products made out of recycled materials.  The authors of the paper argue that many countries have made investments into achieving progress towards a circular economy, but little or no attention is paid on toxic chemicals that appear in new products made out of recycled materials. The paper cites a growing body of evidence of how a circular economy fails to address concerns regarding toxic chemicals in products.

Fe de Leon, Researcher and Paralegal, CELA

In the paper, the authors cite a 2017 study prepared by IPEN, an environmental activist organization that focuses on synthetic chemicals, which revealed elevated concentrations of globally targeted toxic flame retardants in plastic toys.  The IPEN study claimed to have found elevated concentrations of toxic persistent organic pollutants (POPs) in samples of plastic toys purchased in different stores in Canada and other 25 countries globally.  The study further stated that the levels of some chemicals were more than five times higher than recommended international limits.  These chemicals include PBDEs (polybrominated diphenyl ethers) such as octabromodiphenyl ether (OctaBDE), decabromodiphenyl ether (DecaBDE); and SCCPs (short chain chlorinated paraffins).  They are listed under the Stockholm Convention on Persistent Organic Pollutants and are internationally banned or restricted due to their hazardous characteristics.  They all are persistent, highly toxic, travel long distances and build up in the food chain.  However, their presence in new products, although they are banned or restricted, opens up the discussion of a problem regarding recycling as a key component of a circular economy.

The paper concludes that product recycling and a focus on a circular economy should be encouraged.  However, material flows should be free from hazardous chemicals, at the minimum those chemicals which have already been regulated under the international treaties.

Olga Speranskaya, HEJSupport International Co-Director, IPEN CoChair

TURI Publishes Nanomaterials Fact Sheet

Recently, the Toxics Use Reduction Institute (TURI), a research, education, and policy center established by the Massachusetts Toxics Use Reduction Act of 1989, published a nanomaterials fact sheet.  The fact sheet is part of a series of chemical and material fact sheets developed by TURI that are intended to help Massachusetts companies, community organizations, and residents understand the use of hazardous substances and their effects on human health and the environment.  The fact sheet also includes information on safer alternatives and safer use options.

According to the fact sheet, TURI researchers have started a blueprint for design rules for safer nanotechnology.  The design rules include five principles, which together follow the acronym SAFER, as shown below.  The principles focus on aspects such as modifying physical-chemical characteristics of the material to diminish the hazard, considering alternative materials, and enclosing the material within another, less hazardous, material.  The fact sheet notes that other researchers have proposed other more specific design rules, which include avoiding chemical compositions of engineered nanomaterials that contain known toxic elements, and avoiding nanomaterials with dimensions that are known to possess hazardous properties.

Design Principles for SAFER Nanotechnology

  1. Size, surface, and structure: Diminish or eliminate the hazard by changing the size, surface, or structure of the nanoparticle while preserving the functionality of the nanomaterial for the specific application;
  2. Alternative materials: Identify either nano or bulk safer alternatives that can be used to replace a hazardous nanoparticle;
  3. Functionalization: Add additional molecules (or atoms) to the nanomaterial to diminish or eliminate the hazard while preserving desired properties for a specific application;
  4. Encapsulation: Enclose a nanoparticle within another less hazardous material; and
  5. Reduce the quantity: In situations where the above design principles cannot be used to reduce or eliminate the hazard of a nanomaterial, and continued use is necessary, investigate opportunities to use smaller quantities while still maintaining product functionality.

The fact sheet provides a summary of regulations concerning nanomaterials.  Massachusetts currently has no regulations specifically governing the use or release of nanomaterials.  At the federal level, the U.S. Environmental Protection Agency (EPA) primarily regulates nanomaterials under the Toxic Substances Control Act.

The fact sheet notes that as of 2017, companies using or manufacturing nanomaterials that have not been subject to pre-manufacture notices or significant new use rules will be subject to a one-time reporting and recordkeeping rule.