MSDS AND SARA 313 REQUIREMENTS ASSOCIATED WITH IARC'S 2B CANCER CLASSIFICATION FOR VINYL ACETATE
In 1995, the International Agency for Research on Cancer (IARC) classified vinyl acetate as a Group 2B carcinogen, (i.e., possibly carcinogenic to humans). This classification change triggers several regulatory requirements for products containing 1000 ppm (0.1%) or more vinyl acetate. Most significant among these are requirements associated with Material Safety Data Sheets and SARA 313 reporting (Toxic Release Inventory).
According to IARC's analysis, there is "inadequate evidence" in humans for establishing the carcinogenicity of vinyl acetate and "limited evidence" in experimental animals. Typically, this would place a substance in the IARC Group 3 classification (i.e., not classifiable as to its carcinogenicity to humans). However, because vinyl acetate is metabolized to acetaldehyde, a substance previously classified as Group 2B, IARC also chose to classify vinyl acetate as Group 2B ("possibly carcinogenic to humans").
It is significant to note that in 1993, the American Conference of Governmental Industrial Hygienists (ACGIH) classified vinyl acetate and acetaldehyde as an "A3-Animal Carcinogen, i.e., available evidence suggests that the agent is not likely to cause cancer in humans except under uncommon routes or levels of exposure."
MATERIAL SAFETY DATA SHEETS
Pursuant to the Occupational Safety and Health Administration's (OSHA) Hazard Communication (HAZCOM) standard, mixtures containing 0.1% or greater of an IARC Group 2B substance, must include on the Material Safety Data Sheet (MSDS) a statement describing the IARC classification. A similar requirement is found in Canada's WHMIS statute. As a result of the 2B classification, MSDSs for products containing 1000 ppm (0.1%) or more vinyl acetate must include a statement regarding the IARC classification. Also, since vinyl acetate can hydrolyze to acetaldehyde under alkaline conditions, and both substances are now classified as IARC Group 2B, it is important to consider the concentration of both substances in deciding whether to include a statement regarding IARC classifications on the MSDS.
SARA 313 REQUIREMENTS - TOXIC RELEASE INVENTORY
The SARA 313 regulations codified at 40 CFR Part 372 require annual release reporting by manufacturers, processors and users of vinyl acetate (in SIC Codes 20-39) if managed in quantities greater than their associated threshold amounts (25,000 pounds for processors and 10,000 pounds for users).
The SARA 313 regulations cross-reference the OSHA HAZCOM standard for purposes of establishing a compound's de minimis value, as either 0.1% or 1.0%, when present in a mixture. For vinyl acetate, the de minimis level is 1% for the TRI report due to be filed with EPA by August 1, 1996 for calendar year 1995 releases. The change in the IARC classification for vinyl acetate means that starting on January 1, 1996, all products containing 0.1% or greater of vinyl acetate should be considered in the "threshold calculations" for the Toxic Release Inventory (TRI) report due to be filed with EPA on July 1, 1997. The de minimis level for acetaldehyde is 0.1%.
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Products containing vinyl acetate and/or acetaldehyde can continue to be safely used following good industrial hygiene and other practices as provided on your supplier label and MSDS. Because vinyl acetate monomer has an irritating odor, over time the industry has significantly reduced the concentration of vinyl acetate and acetaldehyde in their products.
In the spirit of Responsible CareŽ, customers and users of vinyl acetate-based latexes are encouraged to share end-use information and exposure data or experiences with their suppliers. Any questions concerning handling and use of vinyl acetate-based emulsion polymers should be directed towards your supplier.
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