BPA Alternatives in Thermal Paper Partnership - About this Project
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On January 29, 2014, through its Design for the Environment (DfE) program, EPA released a final alternatives assessment for bisphenol A (BPA) in thermal paper (PDF) (519pp, 3.72MB).
One of BPA's uses is as a developer in thermal paper, and this assessment evaluates potential hazards associated with 19 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, which are described in more detail below. In addition, the assessment provides background information about how thermal paper is made and considerations for choosing an alternative.
Note that a chemical listed in the report as an alternative does not constitute EPA's endorsement of it. All of the alternatives are associated with some trade-offs; this report does not identify any functional chemicals with low concern for all human health and environmental hazard endpoints.
Read about BPA and why it is of concern to EPA
A draft of this assessment was open for public review and comment period from July 31, 2012, to October 1, 2012.
- Six sets of formal, written public comments (PDF) were received as of October 18, 2012. (40pp, 2.89MB)
- Response to comments (PDF) (19pp, 254K).
Final Report and Individual Chapters:
Bisphenol A Alternatives in Thermal Paper (492pp, 6.1MB)
- Executive summary (8pp, 234K)
- 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 in March 2010 for bisphenol A (BPA) under its Existing Chemical Management Program. The plan called for DfE to assess the potential hazards associated with BPA and its functional alternatives so product manufacturers could use the information to reduce the likelihood of unintended consequences of using substitutes for BPA. Read more information on the goals of DfE's alternatives assessments.
DfE's BPA Alternatives Assessment Partnership
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.
The assessment is 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 is being made available to decision-makers and the public in a manner that protects proprietary information.
Background on BPA
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.
What's New with DfE?
June 12, 2014 – EPA, through DfE, issued:
- Final DfE Alternatives Assessment for Hexabromocyclododecane (HBCD) (PDF) (230pp, 1.76MB) that evaluates and compares potential hazards associated with HBCD and three alternatives. Read more.
- Draft update of a previous alternative assessment on flame retardants used in flexible polyurethane foam (PDF) (840pp, 8.05MB), which will be available for public review and comment until August 11, 2014. Please submit comments to Docket No. EPA-HQ-2014-0389 via www.regulations.gov. Read more.
- Q. & A. Consumer Fact Sheet on Flame Retardants
January 29, 2014 - EPA, through DfE, issued:
- Final Flame Retardant Alternatives Assessment for Decabromodiphenyl Ether (DecaBDE) (PDF) (901pp, 10.84MB) that evaluates and compares potential hazards associated with decaBDE and 29 alternatives. Read more.
- Final Alternatives Assessment for Bisphenol A (BPA) in Thermal Paper (PDF) (519pp, 3.72MB)that evaluates and compares potential hazards associated with BPA in thermal paper and 19 alternatives. Read more.
January 23, 2014 -- EPA updated DfE’s Safer Chemical Ingredients List (SCIL), adding 50 chemicals – bringing the number of safer fragrance chemicals to 150, and the total number of safer chemicals to nearly 650.