Legacy additives are substances that are no longer used in new PVC products but that can be present in recycled PVC. Since the use of legacy additives may be restricted by legislation, VinylPlus is committed to addressing the issue in cooperation with regulatory authorities.
In the past few years, VinylPlus has contributed to discussions on legacy additives by supporting research and a considerable number of studies. All the studies conducted so far confirm that recycling PVC waste containing legacy additives can be considered a viable option, since health and environmental exposures are well within the acceptable levels.
In 2016, VinylPlus commissioned two further studies to FABES to consolidate the results of its previous study, which evaluated migration models for cadmium, lead, tin and zinc in both rigid and flexible PVC – and for DEHP in just flexible PVC. The first study – aimed at determining the diffusion and partition coefficients of lead, cadmium, zinc and DEHP from recycled PVC in water, saliva and sweat – confirmed that migration rates from both rigid and flexible PVC are very low. The second study investigated the migration behaviour of chemicals from PVC flooring, focusing on DEHP. The study was concluded in December 2016. However, since DEHP solubility in water is extremely low and it tends to form colloid solutions, the study concluded that additional data might be needed to fully understand the migration behaviour.
Arche Consulting was commissioned by VinylPlus to carry out two risk assessments of lead migration, one for PVC waste during storage and the other for recycled PVC during use. Both studies demonstrated that the risks to human health and the environment are controlled.
A further study was carried out in 2016 by CATS Consultants GmbH: ‘Health Risk of Occupational Lead (Pb) Exposure in Conventional PVC Recycling and Converting Operations’. The study showed that in general lead levels in blood were within the normal range for not exposed population. However, a few (5%) occupationally exposed individuals had values at a level where subclinical and reversible neurotoxicity may start to occur. It was not possible to make a direct link between current occupational exposure and these blood levels, as some of these 5% of individuals had either previously been exposed to lead at the workplace, or lived in old houses.
RDC Environment (www.rdcenvironment.be) and BIPRO (www.bipro.de) are currently carrying out a study of the socio-economic impact of hazardous classification of post-consumer PVC waste. The study began in July 2016, and conclusions are expected in June 2017.
EU Commission Regulation 494/2011 set a limit for polymers of 100 ppm of cadmium originating from recyclate, with a derogation of up to 1,000 ppm allowed in specified rigid PVC construction products. These limits are to be reviewed by 31 December 2017. In 2016, the EU Commission asked ECHA to carry out a review of the cadmium restrictions by September 2017. As part of this review, ECHA contracted VITO, which had already in 2009 developed an impact assessment of various possible options to reconcile the recycling of PVC waste still containing legacy cadmium with the restrictions of Annex XVII of REACH. To contribute to the review, the PVC industry is modelling the amount of waste that could arise up to 2050, as well as its cadmium content.