On June 28, 2019, the California Office of Environmental Health Hazard Assessment (OEHHA) updated the Proposition 65 list to add p-chloro-α,α,α-trifluorotoluene (para-chlorobenzotrifluoride, or PCBTF) as a carcinogen. The listing, undertaken via the authoritative bodies listing mechanism, was based on a National Toxicology Program Technical Report published in June 2018. The Proposition 65 warning requirement for this chemical becomes effective on June 28, 2020, and the Proposition 65 discharge prohibition becomes effective on February 28, 2021.
PCBTF is a solvent used in paints and coatings. It also is used as an intermediate in the production of other chemicals. Notably, according to the American Coatings Association’s published opposition to the then-proposed listing, PCBTF is a preferred solvent in paints and coatings because it is less reactive than other volatile organic compounds. Because the chemical does not contribute significantly to ozone formation, the South Coast Air Quality Management District has exempted PCBTF from air quality regulations. In its public comments, the ACA expressed concerns that if OEHHA listed the chemical, “air quality regulators may be prompted to remove the exemption, eliminating the public health benefits from ozone reductions that flow from use of PCBTF in paint, sealant, and similar products.”
Grimaldi Law Offices has been advising clients for over 20 years on chemical and product regulation. For knowledgeable advice and in-depth analysis on your chemical regulatory compliance obligations, contact Grimaldi Law Offices at (415) 463-5186 or email us at [email protected].
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