To VI HSE Committee,

At the request of VI member ExxonMobil, VI filed the brief comments below to the European Chemicals Agency (ECHA) in response to their request to the public for information on uses and health effects of DINP plasticizers. Since some end products such as appliances that would contain power cords plasticized with DINP are exported to Europe, this comment initiative is relevant to vinyl resin producers and flexible vinyl compounders. Our comments are herewith:

General Comment:

“Dear ECHA,

The Vinyl Institute is a U.S. based trade association representing the producers of vinyl resins and additives, including plasticizers. It was recently brought to our attention that a proposal is being considered to require classification and labelling for di-isononyl phthalate (DINP) plasticizer. This plasticizer is widely used in U.S. flexible vinyl applications including certain flooring, wire and cable insulation, seals and gaskets, footwear, upholstery, and many other applications some of which are exported from the U.S. to Europe. As such, it is an important ingredient to producers and consumers alike. Thus, it is critical that the health aspects be properly evaluated, understood, and communicated. The VI recently submitted comments* to the U.S. Consumer Products Safety Commission (CPSC) on their analysis of DINP by the Chronic Hazard Advisor Panel. In these comments which are attached for your review, two key characteristics of DINP were highlighted that must be weighed heavily when assessing potential exposure of this substance : 1.) DINP has an extremely low vapor pressure, and 2.) DINP has strong molecular bonds to the PVC molecule. Both of these characteristics are responsible for the low emissions and high retention of DINP in a finished article. For these reasons, the Vinyl Institute does not support the proposed classification. Given the high importance of this substance to our members, and the data supporting its retention and low exposure to consumers, we would urge that ECHA and RAC ensure a full and thorough scientific evaluation of all the relevant data on DINP.

*Comments of the Vinyl Institute to U.S. Consumer Products Safety Commission, RE: Estimated Phthalate Exposure and Risk to Pregnant Women and Women of Reproductive Age as Assessed Using 2013/2014 NHANES Biomonitoring Data, Docket Number CPSC-2014-0033, March 24, 2017”

Specific comment:

“To the VI’s knowledge, DINP has not shown adverse reproductive effects in certain animal studies.”

Please let me know if there are any questions, or if you would like any further information.

Regards,

Rich

Additional Resources

VI Comments to CPSC on CHAP NHANES Information submitted 03-24-2017