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OEHHA Proposes NSRL and Publishes Draft Cancer Inhalation Unit Risk Factor Document for PCBTF

The California Office of Environmental Health Hazard Assessment (OEHHA) is proposing a No Significant Risk Level for p-chloro-α,α,α-trifluorotoluene (PCBTF) under Proposition 65, and has published a draft cancer inhalation unit risk factor (IUR) document for the chemical under the Air Toxics Hot Spots Program. The deadline for comments for both the proposed NSRL and the draft IUR document is December 2, 2019. OEHHA also is hosting two workshops, on November 13 (in Diamond Bar, CA) and 15 (in Oakland, CA), 2019, to discuss the draft IUR factor document.

PCBTF is used in the preparation of dyes, pharmaceuticals, pesticides, and as a solvent in paints, inks, and high-solids coating formulations, as well as for metal cleaning. Currently, in recognition of its negligible contribution to the formation of ozone, PCBTF is exempt from the definition of volatile organic compounds under the California air regulations, thereby giving manufacturers of coatings and other products the flexibility to formulate those products to meet both performance standards and California’s strict VOC air standards.

OEHHA listed PCBTF as a Proposition 65 carcinogen on June 28, 2019 under the authoritative bodies listing mechanism. The listing was based on conclusions drawn by the National Toxicology Program that the substance purportedly causes cancer. OEHHA is now proposing an NSRL of 23 micrograms per day, meaning that no Proposition 65 warnings are required for exposures to PCBTF below that amount.

Under the California Air Toxics Hot Spots program, OEHHA is required to develop guidelines for conducing health risk assessments. Pursuant to that mandate, OEHHA also is proposing an IUR for PCBTF of 8.6 × 10-6 (µg/m3)-1 . IURs are used in the Air Toxics Hot Spots Program to estimate lifetime cancer risks associated with inhalation exposure to a carcinogen.

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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Ms. Grimaldi maintains a diverse environmental law practice focusing on chemical and product regulation and litigation defense. Her practice areas include Proposition 65, California's Safer Consumer Products Regulations, California's Rigid Plastic Packaging Container Act and the federal Toxic Substances Control Act. Ms. Grimaldi graduated from the University of California Hastings College of the Law magna cum laude and holds a Bachelor of Science Degree in Bacteriology from University of California, Davis. Prior to attending law school, she worked as a research assistant in laboratories at the University of California, San Francisco Cancer Research Institute and at the University of California, San Francisco School of Medicine.