'REACH'ing Beyond U.S. Labeling Regulations
Although it remains to be seen what recently enacted reforms to the 1976 Toxic Substance Control Act (TSCA) will mean in practice, adhesive manufacturers are trying to stay ahead of the game in meeting what are expected to be more rigorous chemical regulations in the United States.
Those who have stayed proactive in the development of environmentally friendly products have likely anticipated that Congress would at some point iron out long-needed regulatory reform legislation. Some adhesive manufacturers have begun working to bring their existing and new pressure-sensitive adhesives (PSAs) for tapes and labels into compliance with the requirements of the European Union’s REACH standards, which are more stringent than current TSCA standards.
Launched in 2007, REACH, which stands for “Registration, Evaluation, Authorization and Restriction of Chemicals,” is widely considered to be the global model in chemical regulation, established “to improve the protection of human health and the environment from the risks that can be posed by chemicals,” according to the European Chemical Agency (ECHA). It also promotes alternative methods for assessing the hazards of chemicals to reduce testing on animals.
The effort to comply with REACH standards is also in keeping with the push within the packaging industry toward increased sustainability.
The TSCA Reform is sure to improve chemical regulation in the U.S., but to what degree is not certain.
“Our U.S. regulatory system is still reactive to what the market demands, not proactively engaged in trying to drive market activity,” states Dr. Robert DeMott, principal toxicologist at Ramboll Environ. “For example, enacting regulations designed to encourage research or new products, such as substitutions for products that may be phased out. Will the U.S. be seen as a leader or a follower in chemical regulation? The answer to this question will emerge as the TSCA Reform Act becomes regulations, guidance and reality.”
Compliance with what is currently considered to be the gold standard of regulation has merit regardless of stronger U.S. regulation, and compliance is well underway at many adhesive manufacturers. Here at Franklin, the adhesive division already has converted a number of existing PSAs within its Covinax family of products. These all-new products have been developed to be in compliance with the EU program.
Compliance efforts have focused primarily on replacing offending water-soluble components of the adhesives with components that are either environmentally benign or are not free to migrate from the adhesive, thereby protecting the environment across EU.
Franklin’s Covinax family includes both vinyl acrylic and acrylic formulations for a range of permanent, removable and specialty applications, offering a blend of performance properties to meet various performance requirements, including heat resistance, freezer-grade capability, all-temperature requirements, non-blush, waster resistance and more. The Covinax SMA-02, 331-15, 211-01 DEV and 225-00 are now in compliance with REACH protocols.
What’s more is that all PSAs that are now in compliance with REACH are expected to meet or exceed TSCA requirements when those become established. Integrating the TSCA Reform into the regulatory process is not likely to be simple and quick, however. As Richard Denison, who is a frequent contributor to EDF’s Chemicals and Nanomaterials blog, said in his June 7, 2016, commentary: “In many ways many ways the real work now begins: implementing the new law will take the same level of hard work and dedication it’s taken to get us to this point – and that will be a real challenge in an area fraught with contention and conflict.”
In the meantime, it’s important for adhesive manufacturers to start thinking on a more global level to develop PSAs that meet the high standards of environmental safety.
Franklin Adhesives & Polymers