Drain-waste-vent: PVC Material Safety Data Sheets for PVC pipe products would list stabilizers.

Windows: PVC Material Safety Data Sheets for PVC pipe products would list stabilizers.

Stabilizers – No cadmium or lead based stabilizers are used in PVC pipes manufactured throughout the United States and Canada. PVC pipe compounds and the pipe products made from those compounds have been certified safe for contact with drinking water in accordance with the stringent requirements of NSF Standard 61. Some PVC pipe compounds/products have also received FDA approval. PVC pipes are not chemically reactive with water or most wastewater. Consequently, PVC pipes do not alter the quality of the conveyed water or wastewater.

Stabilizers (lead and cadmium)

None of the vinyl siding produced in North America is manufactured with lead, nor does it contain cadmium. In fact, through VSI’s Vinyl Siding Product Certification Program, the vinyl siding industry has proactively proposed an additional requirement to ASTM D3679, Standard for Rigid (Poly) Vinyl Chloride Siding, that “Certified vinyl siding shall not contain elemental lead or cadmium or compounds of these materials other than traces incidental to raw materials or the manufacturing process.” This limitation applies to both the PVC substrate and to any cap or film material. Even before the standard is revised to include this requirement, as part of the VSI Vinyl Siding Product Certification Program, representative samples of certified vinyl siding will be tested every six months to verify that lead or cadmium is not present. More than 95 percent of all vinyl siding produced in North America is currently certified through this program and will be subject to these testing requirements.

All PVC piping products, including DWV manufactured by National Pipe & Plastics, Inc. meet all of the requirements of the EPA safe drinking water standards and NSF Standard 61 relating to drinking water health effects. No lead or cadmium components are contained in the stabilizer used in the manufacture of National's PVC piping products.

Ferro Corp. makes and sells a variety of heat stabilizers for PVC. Ferro does not manufacture or sell lead (Pb)-based stabilizers for rigid or flexible PVC in North America for any application. Furthermore, in North America lead (as Pb or Pb compounds) is NOT part of any Ferro heat stabilizer recipe, in NOT a by-product of the reactions to make the stabilizers, and is NOT intentionally added. Recognized industry consensus standards strictly regulate use of stabilizers in the PVC applications under review by TSAC.

--Alan Olson Director of Technology and Product Stewardship Ferro Performance Chemicals Group (W) 216-750-6696

No cadmium or lead based stabilizers are used by Ipex in the manufacturing of all its PVC products. The PVC compounds and the PVC pipe products made from these compounds are certified safe for contact with drinking water, in accordance with the very stringent requirements of NSF Standard 61 and. PVC pipes are non chemically reactive with water and most wastewater, therefore they will not alter the quality of the water or wastewater they convey.

Heat Stabilizers: As a representitive of the Plastic Pipe and Fitting Association I can offer the following. NSF International policy (a third party certifier for pipe products) forbids the use of lead stabilizers in PVC pipe used to convey drinking water. NSF General Policy GP – 60 that indicates: “There shall be no lead as an intentional ingredient in any material contacting food or drinking water, except brass meeting the definition of "lead free" under the specific provisions of the Safe Drinking Water Act of the United States, as amended in 1986."

PVC pipe manufacturers use essentially the same stabilizers for DWV and potable water pipe. Most PVC piping systems in North America are produced using tin-based stabilizer systems.

Townsend Polymer and Information Services has performed several studies on the PVC stabilizer business over the last few years. The last one was in 2001, and we presently are doing a 2004 update of that study. We became aware of your interest in understanding what stabilizers are used in particular applications for PVC, and felt we might be able to provide some relevant information on this question.

At the outset, we must say that our standard information in this area is categorized based on total volume of stabilizers used in PVC by type, rather than by specific application.

There are three product categories of heat stabilizers used for PVC in North America. The estimated volume consumption by type for 2004 is as follows: tin heat stabilizers at 46%, mixed metal heat stabilizers at 43%, and lead heat stabilizers at 11%. Individual tin heat stabilizer products consist primarily of methyl tin, butyl tin and octyl tin mercaptides, maleates, and carboxylates. The mixed metals are mainly calcium zinc and barium zinc metal salts. Cadmium use has fallen significantly over the years, and is hardly used in North America.

As mentioned above, our studies do not collect information by application. However, we did some additional investigation with heat stabilizer suppliers to obtain more information about which stabilizers are used in specific applications. Based on our findings, we can say that tin heat stabilizers are predominately (>90%) used in rigid PVC such as pipe, siding and profiles. Mixed metals are used predominately (>90%) in flexible and semi-rigid PVC products such as flexible sheet, flooring and plastisols. While some lead is used in PVC, it is mainly found in electrical insulation such as wire and cable.

We understand that information that is cited in publications is highly desirable for this subject. However, specific uses of heat stabilizer products are usually considered very proprietary by the processors and the stabilizer suppliers alike. It is possible to conduct specific market research to better define individual stabilizer usage by application. A number of market research firms, including Townsend, are capable of undertaking such proprietary work for clients and organizations.

On behalf of the Resilient Floor Covering Institute the following comments are submitted:

No cadmium or lead based stabilizers are used in the production of vinyl composition tile or sheet vinyl flooring manufactured in North America by Resilient Floor Covering Institute members - Amtico, Armstrong, Congoleum, Domco, Losetas Asfalticas, Mannington and Tarkett.

The Vinyl Institute agrees with Task Group's exclusion of lead from the analysis. We believe the submittals above from Unibell, VSI and RFCI provide ample evidence for this conclusion. It is our understanding that the American Architectural Manufacturers Association certification program for vinyl windows prohibits the use of lead stabilizers. In addition to the comments provided above we will post a letter from NSF International discussing its policy on lead. NSF International standards apply to pipe in contact with drinking water.

Royal Pipe Systems uses no cadmium or lead based stabilizers in the manufacturing of all its PVC products. The PVC compounds and the PVC pipe products made with these compounds all meet the very stringent requirements of NSF Standard 61 and are therefore certified safe for contact with drinking water. PVC pipes will not react with potable water and with most wastewater. Consequently, PVC pipes will not alter the quality of the water or wastewater being conveyed through them.