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July 2007 - Higher and Lower Hazard Substances

July 2007 - Higher and Lower Hazard Substances

 Initial Selection of Higher and Lower Hazard Substances

Under the 2006 amendments to TURA, the Council has the authority to designate up to 10 chemicals per year as Higher Hazard Substances (HHS) and up to 10 as Lower Hazard Substances (LHS). The Science Advisory Board (SAB) provides input to the Toxics Use Reduction Institute (TURI) based upon science. TURI makes recommendations to the Administrative Council based on both the SAB’s input and TURI’s analysis of policy implications.

It is the responsibility of the Administrative Council to make the final designations of Higher and Lower Hazard Substances. The statute requires that for the Higher Hazard Substances, the Council shall first consider those chemicals previously defined by the SAB as "Category 1: more hazardous chemicals." These previously defined lists were developed by the SAB several years ago to provide guidance to the program and firms in setting priorities.

In its chemical categorization work, the SAB uses a defined set of hazard data along with the DELPHI expert judgment method.

TURI asked the SAB to recommend ten chemicals to prioritize for consideration as candidates for HHS designation. In making recommendations about which chemicals to prioritize, each member picked 10 chemicals from the “more hazardous chemicals” list that they considered to be the most hazardous from a scientific perspective. The chemicals were then discussed in order of most votes to determine the following list of 11 for policy review at TURI.

  • Arsenic Compounds: Arsenic Compounds are a known human carcinogen, a neurotoxin and are highly toxic.
  • Benzene: Benzene is a known human carcinogen, is a developmental and reproductive toxin and is persistent.
  • Cadmium Compounds: Cadmium Compounds are a known human carcinogen, mutagen and reproductive toxin and are highly toxic.
  • Chlorine: Chlorine is persistent and toxic and has a low RfD (reference dose).
  • Cyanide Compounds: Cyanide compounds are acutely toxic.
  • Ethylene Oxide: Ethylene Oxide is a probable carcinogen and is persistent.
  • Formaldehyde: Formaldehyde is a probable human carcinogen and is highly toxic.
  • Hydrogen Cyanide: Hydrogen Cyanide is acutely toxic and persistent.
  • Nickel Compounds: Nickel Compounds are a known human carcinogen.
  • PCE: PCE, or "perc" (perchloroethylene) is persistent and a possible human carcinogen.
  • TCE: TCE (trichloroethylene) is persistent and a probable human carcinogen.

Similarly, TURI asked the SAB to recommend ten chemicals to prioritize for consideration as candidates for LHS designation. The SAB used the same process for Lower Hazard Substances as for Higher Hazard, with initial consideration of the previously defined "Category 2: less hazardous chemicals." There were only 22 chemicals on the Less Hazardous list to begin with and many were "CERCLA-only chemicals." TURA listed chemicals that originate only from the CERCLA list are being considered for retention or delisting under a separate provision of the 2006 TURA Amendments. Therefore, the SAB first considered whether to recommend retaining the "CERCLA only" “less hazardous chemicals” on the TURA list; for those that were retained, the SAB then evaluated them as potential priorities for Lower Hazard Substance designation. The SAB recommended prioritizing the following list of 11 for consideration.

  • Acetone
  • Acetic acid(>12% concentration)
  • Ethyl Acetate
  • Ethylene glycol
  • Isobutyl alcohol
  • N-butyl alcohol
  • Methanol
  • Methyl Ethyl Ketone
  • Sec-butyl alcohol
  • Silver in alloy form
  • Zinc in alloy form