TORONTO—U.S. and Canadian tire makers face multiple challenges on the regulatory front, and it is incumbent on them to know their responsibilities under the law.
This was the message of three speakers at "Driving to the Future," the 2019 Tire & Rubber Summit, held June 12 in Toronto by the Tire and Rubber Association of Canada.
North American tire makers must deal with the Canadian Chemicals Management Plan and the Toxic Substances Control Act in the U.S., according to Sarah Amick, vice president for environmental, health, safety and sustainability at the U.S. Tire Manufacturers Association.
In place since 2006, the CMP is under the aegis of two Canadian ministries, according to Amick—Environment and Climate Change Canada and Health Canada.
The goal of the CMP is to evaluate and manage substances deemed to be toxic, with some 4,300 substances to be evaluated by 2021, Amick said. Currently the Phase III list, containing about 1,500 chemicals, is being assessed—including several substances important to the tire industry, she said.
The CMP's draft screening assessment of zinc began in April of this year and is due sometime in September, according to Amick.
A draft screening assessment for benzothiazoles is set to begin in October of this year, with completion by March 2020, she said. A final screening assessment of tetramethylthiuram disulfide was due any day as of June 12, she said.
TSCA is the primary federal chemical management law in the U.S., according to Amick. An updated version of the regulation passed in Congress with bipartisan support in 2016, and the U.S. Environmental Protection Agency continues to work on implementation, she said.
Under TSCA, Amick said, the EPA designates chemicals of being either low- or high-priority for risk assessment; evaluates those in the latter category; and imposes restrictions of those determined to present an unreasonable risk to human health.
Several substances used in tire manufacturing, including formaldehyde and 1,3-butadiene, are currently being evaluated under TSCA, according to Amick.
The USTMA is responding to these and other TSCA challenges, she said, by:
- Educating the EPA about tire manufacturing and the materials used to make tires;
- Working with other chemical user associations;
- Working directly with chemical manufacturers; and
- Providing data to the EPA about tire materials.
Tire manufacturers also face challenges from state regulations, especially in California, according to Amick.
The USTMA has had to advocate for the industry in the case of California stormwater laws, she said. Because California municipalities cannot meet their stormwater permit limits for zinc, the state has tried to reduce zinc content in tires under its Green Chemistry law—a move that would be both totally ineffective and ruinous to tire makers, she said.