Seeking Guidance on TSCA Section 8C
A manufacturer of wood treatment chemicals became concerned with potential adverse chemical reactions to pressure treated wood. Although no formal letters or reports of such reactions had been reported to the EPA, the client became worried about how such reactions could impact business.
In response to the client’s request, Antea Group reviewed TSCA Section 8(c) regulation [40 CFR 717] and performed an extensive risk evaluation to determine potential actions and/or reporting that may be required. It should be noted that under the TSCA Section 8(c) regulation, adverse reactions do not have to be reported if they are published in a reputable scientific article, if they are abstracted in standard reference sources, or if they are cited in the product labeling or material safety data sheet (MSDS). Therefore, Antea Group searched online toxicology sources to determine if the chemical reactions have been documented.
After a detailed review of TSCA Section 8(c) and in-depth scientific studies search were performed, Antea Group discussed the findings with the client. Based upon the review, the client was satisfied that any potential adverse reactions that may be submitted or reported, were already be known or would be included in any pesticide label or MSDS.