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 Polychlorinated biphenyls?
Do you or your organisation use Polychlorinated biphenyls for any of the following purposes?
Please specify what you use the chemical for?
It is a Not Intentionally Added Substance arising from the pigment manufacturing process
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?
If Polychlorinated biphenyls was/were no longer available, what impact would it have on your business?
This proposal would disrupt many Australian supply chains such as coating and printing inks
Does the proposed standard for Polychlorinated biphenyls manage the risk of the chemical being released into the environment?
Please provide details of why you think the proposed standard will not adequately address risks to the environment.
Because no significant health risks at the internationally recognised standard of 50ppm have been found
Please upload your document.
Our company would like to express its deepest gratitude to the Australian
Government for the opportunity to provide an opinion to public comment on IChEMS proposed standards.
PCB may also be generated as an unintentional by-product of the production of organic pigments, an essential component of many critical value chains. In Japan, the self-managed upper limit for PCB in pigments is 50 ppm under the Japanese Act on the Evaluation of Chemical Substances and Regulation of Their Manufacture. Our company has made great efforts to align with a 50 ppm limit and today PCB in organic pigments do not exceed 50 ppm in Japan. In our view, for PCB in organic pigments, a value of 50 ppm is the only appropriate UTC limit, for the two reasons as follows:
1. No significant health risk
In the past years, the Japanese government has been evaluating the need for restrictive measures of organic pigments containing PCB and, for this reason, has carried out several health risk assessments.
https://www.mhlw.go.jp/stf/shingi/2r9852000002yktn.html
These studies found no significant health risk, even when controlling for concentration levels as high as 2,000 ppm (the highest identified in organic pigments at the time of the studies), and the government concluded that no particular measure was required.
2. Misalignment with international legislation and economic impact
For years, a limit of 50 ppm has been the norm for industry worldwide. This is aligned with the mandatory limits set in other significant markets such as the
USA (TSCA 40 CFR §761.20) and Canada (PCB Regulations: SOR/2008-273), which also set maximum concentrations for PCB in organic pigments at 50 ppm. A UTC limit lower than international legislation would disrupt many Australian supply chains such as coating and printing inks.
Do the activities required for a business to meet the proposed standards for Polychlorinated biphenyls impose an unreasonable burden on business?
What information can you provide that would support that view (e.g. information on estimated cost to implement or the technical feasibility of required measures).
I would like to take this question on notice so that I can obtain information from colleagues in Japan and Europe
Is the chemical clearly identified in the proposed standard?
Would you like to provide any other information on this proposed standard for Polychlorinated biphenyls?
