Navigating the U.S. TSCA Risk Evaluation Minefield: Caution for Color Pigments Value Chain Companies

CPMA Blog: Navigating the USA TSCA Risk Evaluation Minefield: Caution for Color Pigments Value Chain Companies

Written by CPMA Executive Director David Wawer,

Industry experience during the last four years has only reinforced the belief that risk evaluations for chemicals under the new Toxic Substances Control Act (TSCA) law can lead to any outcome, depending upon the chemical, the sector, and the mindset of Environmental Protection Agency (EPA) regulators managing the specific risk evaluation. The final determination of “no risk” or “unreasonable risk” is subject to many factors, some of them scientifically definable, and others subjective. The process we have experienced reinforces the mantra that “if you’re not at the table, you’re on the menu.”

This month, the Color Pigments Manufacturers Association (CPMA) will highlight the designation of “unreasonable risk” for automotive coatings manufacturers. CI Pigment Violet 29 (PV 29) is a raw material sometimes used to manufacture automotive coatings. The EPA’s rationale for designating “unreasonable risk for color pigments manufacturing operators” was transmitted to the downstream sector called automotive coatings manufacturing. Not being at the table with CPMA during the initial phases of risk evaluation (uses and scoping) placed this sector “on the menu.” CPMA was able to persuade EPA regulators that workers at automobile manufacturing companies (customers of automotive coatings manufacturers) would not be exposed, since PV 29 was encapsulated into automotive coatings.

The EPA risk management process for PV 29 in 2021 will determine future regulatory requirements for automotive coatings manufacturers.

For more information about CPMA, visit

To contact David Wawer directly, email him at

Return to News