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Prop 65 Tris Flame Retardants
Applied Technical Services performs testing for compliance with Prop 65 Tris Flame Retardants, such as TDCPP and TCEP, which can be detected at the parts-per-trillion level with our sensitive analytical instrumentation.
Why Are We Talking About Flame Retardants?
Flame retardants are additives applied toward the end of production cycle that make the substrate more resistant to catching on fire and spreading flames. A certain category of these, known as tris flame retardants, have chemical properties that are believed to cause cancer over extended periods of exposure. For this reason, three specific chemicals of the tris family of flame retardants have been identified and regulated for human exposure by a California State law called Proposition 65.
These Prop 65 tris flame retardants have largely fallen out of favor for use in consumer products, but are still present in certain industrial uses. Prop 65 sets a legal limit to their prevalence in the chemical makeup of any product sold or used in the state of California.
A Short Overview of the Law
Sometimes referred to by its formal name, the California Safe Drinking Water and Toxic Enforcement Act of 1986, Prop 65 dictates three things. Firstly, it charges the state government with maintaining a regularly updated list of chemicals known to cause either reproductive toxicity or cancer. Secondly, it punishes businesses that dump significant amounts of any listed chemical into the supply of drinking water. Finally, Prop 65 mandates that businesses operating within the state must label with sufficient warning any product or workplace that would expose a consumer to one of the toxic chemicals included on the list.
The labeling mandate is the facet of this law that most regularly causes friction between businesses and the state. The current iteration of the regulated chemicals list has nearly 950 entries. Not labeling products that require a warning opens businesses up to lawsuits (which can be brought forth by any concerned citizen of California). If found to be non-compliant, companies may face punitive fines of up to $2500 per violation per day. The law applies to all products sold in California, regardless of where the company is headquartered.
Exceptions to the Rule
Prop 65 allows for certain exceptions, waiving the labeling rule for any product which will expose consumers to listed chemicals at a rate lower than the relevant Safe Harbor Level Limits (SHLs). SHLs are determined by extensive research and vary according to the chemical in question. Those substances that do not have an established SHL are still subject to the labeling regulations if consumers would be exposed to them at any dose. One way to determine whether your product must be labeled according to Prop 65 is by sending it to a testing company like Applied Technical Services.
SHLs and Choosing the Right Testing Company
ATS performs Prop 65 compliance testing to identify tris flame retardants in client-submitted sample materials. The specific chemicals in question — Tris(2,3-dibromopropyl) phosphate (TDBPP), Tris(2-chloroethyl) phosphate (TCEP), and Tris(1,3-dichloro-2-propyl) phosphate (TDCPP) — have been added to Prop 65 at various times over the last 30 years. TDCPP has an SHL of 5.4 micrograms per day, and TDBPP presents no significant risk at 0.3 micrograms per day, while TCEP has no associated SHL. ATS’ proven methods can locate chemicals in concentrations as low as 100 parts-per-trillion.
How We Test for Prop 65 Tris Flame Retardants
ATS utilizes Liquid-Chromatography / Mass-Spectroscopy (LC-MS-MS) techniques to analyze for the presence of TDBPP, TCEP, and TDCPP. Through this instrumentation, we can both identify and quantify the presence of individual chemical compounds at incredibly low detection levels. Although capable of returning an exhaustive list of components, ATS’ chemists can isolate testing to just tris flame retardant chemicals or expand the focus to include additional analytes/compounds of interest as relevant to a client’s needs.
ATS and Toxicant Analysis
For over 50 years, ATS has provided testing, engineering consulting, and inspection services of unparalleled quality. We proudly serve clients from around the world who represent a variety of different industries. Our lab is staffed with a host of expert chemists who regularly perform LC-MS-MS and other methods related to chemical identification. ATS partners with manufacturers/importers, legal professionals, toxicologists, and consumer advocacy groups to ensure Prop 65 compliance. We return accurate findings within a quick turnaround window – let ATS take a closer look at your samples.
