CPMA Blog: Plastics Masterbatch Companies: Are You at the Table or on the Menu?
Written by David Wawer, Executive Director, Color Pigments Manufacturers Association
We learned through experience that the U.S. Environmental Protection Agency (EPA), in the absence of valid industry information, defaults to worst case scenarios, particularly with respect to the January 2021 Final Risk Evaluation for Pigment Violet 29 (PV 29). During the final stages of the risk evaluation process, EPA approached the color pigments industry for specific information about worker health and safety practices for customer industries. This latter category includes plastics masterbatch businesses, as well as dispersions and preparations operations for printing inks and paints/coatings.
CPMA’s comprehensive webinar April 7, 2021 revealed many intricacies and nuances of the TSCA risk evaluation process, including an 11th hour effort by EPA to obtain comprehensive downstream customer manufacturing operations information, none of which was in the domain of color pigments manufacturers.
CPMA created a membership category for these companies in the color pigments value chain, in anticipation of the day when EPA risk management staff would insist on manufacturing operations worker safety information for plastics masterbatch companies and pigments dispersions and preparations companies. Had companies been members of CPMA at the time EPA made its request for downstream worker safety information, the risk management target now placed on their backs could have been avoided or significantly reduced. It is critical that these companies understand is that their participation with CPMA is critical for minimizing the Risk Management Rule for PV 29 on their businesses.
A further discovery about the “long reach” of the TSCA Risk Evaluation process – companies that do not view themselves as part of the color pigments industry value chain (HP, Xerox, Ricoh, Canon), but rather as part of the electronics or office equipment industries, will be impacted from a regulatory standpoint by the PV 29 Risk Management Rule. EPA’s Final Risk Evaluation for PV 29 expands the definition of color pigments industry value chain to any company purchasing raw pigments to process such materials into further downstream applications.
Emphasized during CPMA’s regulatory webinar was the fact that plastics masterbatch companies, pigments dispersions & preparations companies, paints and coatings manufacturers and printing ink manufacturers now have a front-row seat during future risk evaluations of color pigments.
For questions about EPA's final risk evaluation of PV 29 and its impacts to plastics masterbatch businesses, or anything related to the color pigments industry, please reach out to CPMA Executive Director David Wawer at dwawer@cpma.com.
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