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CERAMIC DECORATING: Regulatory Updates

March 1, 2010
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This column features a collection of regulatory updates from Sandra Spence, a legislative liason for the Society of Glass and Ceramic Decorated Products (SGCDpro).

NMFC Change Could Prove Costly to Members

SGCDpro has recently learned of a change in the National Motor Freight Classification (NMFC) provisions for glassware that will impact members. The old item (88140) had a range of classes depending on the released value of each shipment. The new item, however, includes a released value of $19 per pound, with classes then determined by the density of the commodity as prepared for shipment.

What this means is that it will now be necessary to calculate the density, in pounds per cubic foot, of every shipment of glassware. Each bill of lading will need to reflect this change, and failure to comply will result in carrier classification changes and charges from the carriers for incorrect bill of lading information.

New Alphabet Soup Issue for Industry: TSCA

The industry now faces a new regulatory issue involving the Toxic Substances Control Act (TSCA). Enacted in 1976, the TSCA regulates the introduction of new or existing chemicals. For 33 years, ceramic mixtures (colors and frits and some other materials, such as cement) have been classified as "statutory mixtures." Recently, the U.S. Environmental Protection Agency (EPA) announced that it will issue a "clarification," suggesting that the 1976 interpretation that allowed for statutory mixtures was never really the law.

Accordingly, the EPA will require a separate classification for each and every color and formula of colors and frits (i.e., if there are 10 blue formulations, that means 10 classifications), and each will have to be approved by the EPA. Although it is expected to publish a statement to this effect in the Federal Register soon and allow for public comments, the EPA is claiming that this new interpretation is not considered to be a regulation subject to normal procedures for the adoption of new regulations.

The new interpretation will require color manufacturers to submit a pre-manufacturing notification to the EPA prior to manufacturing (or importing) any formula. The EPA will then review each notification, as it does for "new" chemicals. If the agency finds an "unreasonable risk to human health or the environment," it may regulate the substance in a variety of ways, from limiting uses or production volume to an outright ban.

CPSC Extends Stay of Enforcement on Testing

The Consumer Product Safety Commission (CPSC) has voted to extend the stay on certification and third-party testing for children's products subject to lead content limits until February 10, 2011. Under this decision, products must still meet the current 300 ppm lead limit, but certification and third-party testing to show compliance will not be required for children's products until after February 10, 2011. SGCDpro joined the National Association of Manufacturers' CPSIA Coalition in urging the CPSC to take this action.

Toxics in Packaging Refuses to Specify Standard Test for Glass Enamels

In response to SGCDpro's concern that there are no standard test procedures to determine the heavy-metal content of glass bottles, the Toxics in Packaging Clearinghouse (TPCH) contacted four private laboratories and an enamel manufacturer suggested by SGCDpro.

The TPCH concluded that "laboratories currently have the capabilities to analyze enamels for the restricted metals. TPCH does not believe it is appropriate to suggest any one method as 'the' standard test method for which to test enamels. Rather, TPCH continues to recommend performance objectives for testing, and to suggest that rigorous QA/QC practices be used to support claims of compliance. The performance objective is to determine the accurate total concentration of metal present to evaluate compliance with state statutes. In the absence of the exemption for vitrified labels to pass the TCLP or CA WET, the enamel components are ideally tested prior to application to the glass container. As with any packaging component subject to state requirements, packaging certifications can be based on testing by or QA/QC documentation of the supplier(s) of the packaging component(s)."

SGCDpro had asked the TPCH to specify an appropriate standard test procedure to give decorators confidence that certifications of colors used in decorating glass packaging would not cause enforcement actions. Based on a reversal of a long-standing TPCH interpretation, as of September 2009, glass bottles and the enamels used to decorate them are considered to be separate package components. As a result, the bottle and each color must be certified to not exceed 100 ppm of the incidental presence of a total of heavy metals. No heavy metals may be intentionally introduced into any of the decorating materials.

For additional information on any of these issues, visit www.sgcd.org.

Any views or opinions expressed in this column are those of the author and do not represent those of Ceramic Industry, its staff, Editorial Advisory Board or BNP Media.

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