Published name
Which chemical or chemicals would you like to provide feedback on?
Have you read the proposed standard or standards for the chemical or chemicals selected?
Do you support the proposed standard or standards?
Would you like to provide further comment on these proposed standard or standards?
Do you or your organisation use Hexachlorobenzene?
Are you aware of any substitutes for Hexachlorobenzene that are available for medical, veterinary, defence, national security, public safety, industrial safety, economic or environmental purposes?
Does the proposed standard for Hexachlorobenzene manage the risk of the chemical being released into the environment?
Do the activities required for a business to meet the proposed standards for Hexachlorobenzene impose an unreasonable burden on business?
Is the chemical clearly identified in the proposed standard?
Would you like to provide any other information on this proposed standard for Hexachlorobenzene?
You can upload a document to provide additional feedback on the proposed standard on this page.
Department of Climate Change, Energy, the Environment and Water
Australian Government
Dainichiseika Color & Chemicals Mfg. Co., Ltd.
Statement on HCB Limits Proposed by the Australian Government
To whom it may concern:
We, Dainichiseika Color & Chemicals Mfg. Co., Ltd., a Japanese chemical company manufacturing pigments, functional materials, and other intermediate materials, are pleased to make our statement on hexachlorobenzene (HCB) regulations proposed by the Australian government.
In conclusion, we would like to state that proposed regulations will cause enforcing to stop some of the key pigments usage.
I. Opinions
1. Certain pigments are known to contain HCB as UTC coming from synthesis1).
- Pigments made from tetrachlorophthalic anhydride (TCPA-derived pigments) and
pigments produced by chlorinating Pigment Blue 15 (phthalocyanine green
pigments) have been known to contain byproduct HCB.
- Regarding these pigments, there are the pigments which are having the difficulty to
meet the recently proposed standard value less than 5 mg/kg, and in particular, the
following pigments have been confirmed to contain more than 10 mg/kg HCB.
A) TCPA-derived pigments
Pigment Yellow 110 (PY110), Pigment Yellow 138 (PY138), Pigment Red 257 (PR257)
B) Phthalocyanine green pigments
Pigment Green 7 (PG7), Pigment Green 36 (PG36)
2. Degree of influence1)
A) TCPA-derived pigments
- PY110 and PY138 are used for coloring plastic products, paints and inks,
either alone or mixed with other pigments. The main applications of these
colorants are for in plastic products, such as construction materials and daily
sundries, and in paints, such as for automobile exteriors. Judging from these
applications and the concentration of HCB impurities in the final products,
the use of the final products is not considered to directly affect human health.
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- In general, it is often difficult to immediately substitute these pigments with
other substances because of the combination of hue and durability.
B) Phthalocyanine green pigments
- Both PG7 and PG36 are involved in the manufacture of a very wide variety
of products through their use as coloring agents in paints, inks, and resin
products and as pigments for color filters for liquid crystals and through the
coloring of various resins and other materials. Judging from these uses and
the concentration of the impurity HCB in the final products, it is considered
that the use of the final products does not directly affect human health.
- Currently, there is nothing better than these pigments in terms of
performance such as weather resistance and heat resistance, and it is difficult
to immediately replace them with other substances, for example, there is no
substitute in terms of their color.
II. Conclusion
Since the social and economic impact is great, we would like related industries to investigate the actual situation, and instead of setting a uniform regulation value for HCB for all chemicals, we would like HCB that exists as UTC in organic pigments to be set as a separate regulation value from other chemicals.
III. Literature
1) Assessment Committee on BAT Levels for Reduction of a Specified Chemical as a
Contaminant By-product. (2007, April). Report on BAT Levels concerning By-product
HCB in Other Pigments Derived from TCPA and Phthalocyanine Pigments.
https://www.meti.go.jp/policy/chemical_management/kasinhou/files/information/repo
rt/hcb/hcb_bat_Report_2_eng.pdf
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Do you or your organisation use Polychlorinated biphenyls?
Are you aware of any substitutes for Polychlorinated biphenyls that are available for medical, veterinary, defence, national security, public safety, industrial safety, economic or environmental purposes?
Does the proposed standard for Polychlorinated biphenyls manage the risk of the chemical being released into the environment?
Do the activities required for a business to meet the proposed standards for Polychlorinated biphenyls impose an unreasonable burden on business?
Is the chemical clearly identified in the proposed standard?
Would you like to provide any other information on this proposed standard for Polychlorinated biphenyls?
You can upload a document to provide additional feedback on the proposed standard on this page.
Department of Climate Change, Energy, the Environment and Water
Australian Government
Dainichiseika Color & Chemicals Mfg. Co., Ltd.
Statement on PCBs Limits Proposed by the Australian Government
To whom it may concern:
We, Dainichiseika Color & Chemicals Mfg. Co., Ltd., a Japanese chemical company manufacturing pigments, functional materials, and other intermediate materials, are pleased to make our statement on polychlorinated biphenyls (PCBs) regulations proposed by the
Australian government.
In conclusion, we would like to state that "meeting the products standards in proposed regulations will endanger and decline the arts and culture in Australia and it will threat the workforce venues and job security” by enforcing to stop some of the key pigments usage.
I. Our opinions
1. Regulatory aspect
In the Canadian PCB Regulations1) , it is stated in Permitted activities 11(1) that
"manufacturing, exporting, importing, selling, selling, processing, and using color
pigments containing PCBs produced incidentally if the concentration of PCBs is less
than 50 mg/kg, processing, and use" although it is indeed stated in Prohibitions 6(a)
that "manufacturing, exporting or importing products containing PCBs in
concentrations of 2 mg/kg or more".
2. Safety aspect
A) Among PCBs, having 209 isomers. 12 dioxin-like PCBs (DL-PCBs) are highly toxic.
In the literature where PCB content was measured in reagents and commercial
pigments, it is stated that PCB #11, #35, #52, #77, #101, and #153 were detected in
disazo pigments, while no trace of PCBs was found in phthalocyanine blue2). Among
these, PCB #77 is a DL-PCB, whose dioxin toxicity equivalency factor is 0.00013),
which is 1/10000 of 2,3,7,8-TCDD, the most toxic.
B) In addition, if the concentration of by-product PCBs is 2,000 mg/kg and if all PCBs
are 3,3'-dichlorobiphenyl (PCB#11: the principal component of PCBs in organic
pigments with the highest PCB concentration identified to date), there is no
significant risk is assessed in printing inks, paints, synthetic resins, textiles (textile
printing), crayons, etc. according to the risk assessment conducted4).
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3. Environmental aspect
A) According to the studies estimating the environmental abundance of PCBs
indication, approximately 1,200,000 tons of PCBs are produced worldwide, of which
approximately 30% is thought to have been released into the environment, and of
this environmental runoff, approximately 35% is estimated to be in coastal
sediments and 60% in open ocean waters.5) Compared to the amount of UTC
PCBs in pigments (on the order of mg/kg), the factor due to byproduct PCBs in
pigments is considered low.
B) The final state of discharge into the environment is not to be as a single pigment,
but as a mixture, molded product, or other final product. Hereunder, we calculated
the PCB content as off-wheel printed materials including paper, which is considered
to have the highest pigment concentration as follows:
The PCB content in each state when process yellow pigment containing 50 mg/kg
of byproduct PCBs is used (22% pigment content in ink) is as follows.
- Ink (wet): 11 mg/kg
- Ink film (dry): 19 mg/kg
- Solid printed matter (including paper): 0.3 mg/kg
- Halftone dot printed matter (including paper): 0.12 mg/kg
Therefore, we believe it is appropriate to set the amount of by-product PCBs in
pigments at 50 mg/kg in terms of the final molded product.
4. Socio-economic and cultural aspects:
A) Pigments are used in a variety of applications, but in the case of inkjet printing,
brands and manufacturers, having the difficulty to comply with the 2 mg/kg limit for
UTC PCBs in pigments, will be forced to withdraw from the market, which could
have an significantly negative impact on the digitalization thanks to inkjet printers.
B) In terms of art and culture, the impact on painting materials could not be ignored.
Art materials need to use so many different types of pigments as possible to meet the
demand for color reproduction by consumers. If a regulatory limit of 2 mg/kg of
PCBs as UTC in pigments is enforced, many colors will be lost without being able
to meet this limit, and this will lead to a cultural decline in Australia.
II. About the analysis
It is assumed that various analytical results are referred to in determining the regulatory values. However, it is not clear whether these were analyzed by the same method, and it is neither clear whether the results are properly evaluated depending upon the inclusion or exclusion of PCBs with one or two chlorine atoms. (Though the method in ISO 787-28 can
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properly analyze PCBs in organic pigments is with a working range of 1 mg/kg to 150 mg/kg, quantification of the values lower than this require to reexamine the analytical method by an expert due to the value out of the said working range)
III. Conclusion
We would like to request that the regulatory value for PCBs present as UTCs in organic pigments be set at 50 mg/kg.
IV. Literatures
1) Canada. (2021, October). PCB Regulations.
https://laws-lois.justice.gc.ca/PDF/SOR-2008-273.pdf
2) Katsunori Anesaki, Poster Presentation at the 20th Annual Meeting of the Society of
Environmental Chemistry, 2011
3) (AIST Chemicals Risk Management Research Center "Detailed Risk Assessment Report
Series 16: Summary of Coplanar PCBs", 2008
4) Study Group on industrially technically and economically feasible levels of PCB by-
products in organic pigments "Report on industrially technically and economically feasible
levels of PCB by-products in organic pigments", 2016
5) Shigeharu Nakachi Environmental Technology p82-87 Vol34 No,2 2005
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