Phthalates Work Could Benefit from Tiered Literature Approach

A four-tiered literature-review approach for certain phthalates could be useful in CPSC's work on reducing testing burdens, according to a contractor report made available September 19. An attached agency memo noted, "CPSC staff will consider this information in evaluating whether staff could make a recommendation for a Commission determination that one or more of the specified plastics does not contain any of the 10 specified phthalates in concentrations above 0.1 percent; and thus, may not require third party testing to assure compliance with [the CPSIA]." The work covered 10 phthalates and 11 plastics, and looked at issues ranging from raw and recycled materials to applications and chemical migration.

The tiers involve identifying the universe of literature, identifying secondary authorities like websites, searching the literature, and identifying information gaps.

The contractor, the Toxicology Excellence for Risk Assessment Center at the University of Cincinnati, explained:

"In Tiers 1 and 2, secondary sources were used to narrow the field of possible information for further investigation of the primary literature in Tier 3. The tiered approach also assisted us in identifying what information was not available and what gaps existed to better focus further efforts on specific phthalate(s), specific plastic(s), or specific factor(s) in Tier 4."

It identified the largest information gaps related to recycling. The report, sent to CPSC in August, is at bit.ly/2do6iIk.

About the same time (PSL, 8/8/16), commissioners voted to publish a notice of proposed rulemaking to exempt four plastics with certain additives from the third-party testing required for toys and childcare products. That action is under comment until the end of October.