Last week, the EPA released a draft analysis of chemicals that may substitute for bisphenol A’s use in thermal paper — that’s the material often used in sales receipts, supermarket labels, parking tickets, airline tickets, and similar items.

Readers may recall that in 2010, EPA released a chemical action plan that summarized hazard, exposure, and use information on bisphenol A (BPA) and identified various actions EPA was considering.  Part of that action plan was to help industries consider alternative chemicals and provide a basis for informed decision-making by developing an in-depth comparison of potential human health and environmental impacts of chemical alternatives. Representatives from industrial, academic, governmental, and non-governmental organizations worked with EPA to select and evaluate alternatives to BPA in thermal paper and develop this report.

By way of background, BPA (a topic we have posted on before) is a high production volume (HPV) chemical with a U.S. volume estimated at 2.4 billion pounds in 2007 and an estimated value of almost $2 billion. It is a monomer used in manufacturing most polycarbonate plastics, the majority of epoxy resins, and other chemical products such as flame retardants.  Approximately 94% of BPA is used as a monomer to make polycarbonate plastic and epoxy resins. Although most human exposure to BPA is believed to come from food and beverage packaging made from these materials, less than 5% of the BPA produced is used in food contact applications.  BPA-based materials are also used in automotive and other transportation equipment, optical media such as DVDs, electrical/electronics equipment, construction, linings inside drinking water pipes, thermal paper coatings, foundry casting, and elsewhere.  It has been an extraordinarily useful product.

The BPA in Thermal Paper Alternatives Assessment is an evaluation of potential hazards associated with thermal paper developers that are likely to be functional alternatives to BPA. Thermal paper systems include a developer and other components such as dyes and sensitizers. (EPA recognized that a change in the developer may require additional adjustments to the system.) This draft report summarizes the outcomes of the alternatives assessment, and aims to improve understanding of the potential environmental and human health impacts of BPA and alternative developers in thermal paper throughout their life cycles. Importantly, this draft report does not identify functional chemicals with no or even low concern for all human health and environmental hazard endpoints; all of the alternatives are associated with some trade-offs. For example, a chemical may have a lower concern for human health but a higher concern for aquatic toxicity. Finding and choosing substitutes is not always as easy as plaintiff attorneys and advocacy groups try to suggest.

Comments on EPA’s draft alternatives assessment are due Oct. 1, 2012, at baier-anderson.caroline@epa.gov.