BPA Alternatives in Thermal Paper Partnership - About this Project
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On July 31, 2012, through its Design for the Environment (DfE) program, EPA released a
draft alternatives assessment report for bisphenol A (BPA) in thermal paper (PDF) (492pp, 6.1MB). This draft report is an assessment of 19 chemical alternatives that may substitute for BPA, which is used as a developer in thermal paper. In addition, this report provides background information about how thermal paper is made, and considerations for choosing an alternative. A chemical's inclusion in the report does not constitute EPA endorsement. This draft report does not identify functional chemicals with low concern for all human health and environmental hazard endpoints; all of the alternatives are associated with some trade-offs.
The draft report public review and comment period ran from July 31, 2012 - October 1, 2012. Six sets of formal, written public comments (PDF) (40pp, 2.89MB) were received as of October 18, 2012.
Draft Report and Individual Chapters:
Bisphenol A Alternatives in Thermal Paper (492pp, 6.1MB)
- Chapter 1: Introduction (7pp, 256K)
- Chapter 2: Products and Materials: BPA in Thermal Paper (4pp, 221K)
- Chapter 3: Background on Thermal Printing Technology (14pp, 503K)
- Chapter 4: Hazard Evaluation of Bisphenol A (BPA) and Alternatives (425pp, 5.4MB)
- Chapter 5: General Exposure and Lifecycle Information (25pp, 825K)
- Chapter 6: Considerations for Selecting Thermal Paper Developers (16pp, 451K)
Why did DfE conduct an alternatives assessment?
EPA issued an action plan for bisphenol A (BPA) under its enhanced chemical management program. The action plan (PDF) (22pp, 209K, About PDF) includes a multi-stakeholder alternatives assessment for BPA in thermal paper to be conducted by EPA's Design for the Environment (DfE) Program.
Thermal paper is widely used for cash register receipts, airline tickets, event and cinema tickets, and grocery store adhesive labels. This alternatives assessment evaluates the potential hazards associated with BPA and its functional alternatives. Product manufacturers can use the information in this report to reduce the likelihood of unintended consequences in the substitution of BPA. For more information, see DfE's alternatives assessments Web page.
The goal of this assessment is to identify known and potentially functional alternatives to BPA in thermal paper and to provide information on their potential hazards. To implement this goal, DfE convened stakeholders to identify and develop information on alternatives to BPA in thermal paper, including thermal paper used for cash register receipts. DfE evaluated the hazards associated with BPA and the functional alternatives that act as developers for dyes in this application. Human health and environmental profiles for each chemical are based on a review of literature in the public domain, structure-activity relationship modeling, and, in some cases, proprietary information shared by stakeholders. Information from the partnership will be made available to decision-makers and the public in a manner that protects proprietary information.
Scope of the partnership
Products containing BPA are subject to regulation by both the EPA and the U.S. Food and Drug Administration (FDA); only products subject to regulation by the EPA are addressed by the action plan for BPA. These products include thermal paper; the manufacture of polycarbonate plastics for non-food and non-medical applications (such as compact disks and safety glasses); epoxy resins; flame retardants; and foundry castings. Products subject to regulation by the FDA generally include those related to food and medical devices, such as polycarbonate used for baby bottles and epoxy resins used in can linings.
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.
Background on BPA
BPA is a high production volume chemical with a U.S. volume estimated at 2.4 billion pounds in 2007 and an estimated value of almost $2 billion. Approximately 94 percent of BPA is used to make polycarbonate plastic and epoxy resins. Although most human exposure to BPA is believed to come from food and beverage packaging, less than 5 percent of the BPA produced is used in food contact applications.
In thermal printing applications, BPA functions chemically as a developer, which reacts with white or colorless dyes (color formers) in the presence of heat, converting them to a dark color. BPA is used mostly as a developer in lower-grade thermal paper applications, such as receipts. While thermal paper represents a small fraction of the total use of BPA, the use of BPA in thermal paper could increase cumulative human exposures and direct and indirect environmental releases of BPA. Reducing use of BPA in receipts is an opportunity to reduce one source of human exposure and releases to the environment.
"Free" or unreacted bisphenol A (BPA) has been reported present in thermal paper. Workers in certain occupations, such as cashiers and restaurant servers who handle thermal paper often, may be at greater risk of exposure. Hand-to-mouth behavior and mouthing of inappropriate objects puts young children -- who may be the most sensitive to BPA -- at greater risk of potential exposure. Additionally, older children and teenagers may potentially be exposed as they start to buy goods and as they enter the workforce, especially as cashiers.
In addition to direct human exposure to BPA through contact with thermal paper, recycling of these papers may contribute residual BPA to the supply of recycled paper; BPA has been detected in recycled toilet paper and other products. BPA in recycled toilet paper may be an additional source of release to the environment, since not all BPA is expected to degrade in wastewater treatment plants. BPA can also be discharged directly to surface water during the recycling process.
How do I get more information?
If you would like more information, please contact Cal Baier-Anderson of DfE at Baier-Anderson.Caroline@epa.gov or 202-564-1933.