Metal Working Fluid to be Listed as a Carcinogen

California’s Environmental Protection Agency’s Office of Environmental Health Hazard Assessment (OEHHA) is planning to list TRIM® VX as known to the state to cause cancer under the Safe Drinking Water and Toxic Enforcement Act of 1986. This action is being proposed under the Proposition 65 authoritative bodies listing mechanism.

TRIM® VX is a metalworking fluid used as a lubricant and coolant liquid for cleaning tools and parts during cutting, drilling, milling, and grinding.

TRIM® VX meets the criteria for listing as known to the state to cause cancer under Proposition 65, based on a study performed by the US National Toxicology Program NTP. In 2016, NTP published a report on TRIM® VX, entitled Toxicology and Carcinogenesis Studies of TRIM® VX in Wistar Han Rats and B6C3F1/N Mice (Inhalation Studies), that concluded that the chemical causes cancer. This report satisfies the formal identification and sufficiency of evidence criteria in the Proposition 65 regulations.

OEHHA relied on the NTP’s discussion of data and conclusions in the report that TRIM® VX causes cancer. NTP stated in the Conclusion section of the report’s Summary, "we conclude that exposure to aerosols of TRIM VX caused tumors of the lung in male and female mice..." The NTP report stated in the Conclusion section of the report’s Abstract and main body of the report (pages 9 and 71, respectively), "under the conditions of these 2-year inhalation studies... There was clear evidence of carcinogenic activity of TRIM VX in male B6C3F1/N mice based on the increased combined incidences of alveolar/bronchiolar adenoma or carcinoma of the lung." "There was clear evidence of carcinogenic activity of TRIM VX in female B6C3F1/N mice based on the increased combined incidences of alveolar/bronchiolar adenoma or carcinoma (primarily carcinoma) of the lung."

NTP found that TRIM® VX causes increased incidences of malignant and benign alveolar/bronchiolar tumors in male and female mice.

OEHHA has requested comments as to whether TRIM® VX meets the criteria set forth in the Proposition 65 regulations for authoritative bodies listings. In order to be considered, OEHHA must receive comments by 5:00 p.m. on February 26, 2018. Comments may be submitted electronically through OEHHA’s website at https://oehha.ca.gov/comments. Comments submitted in paper form can be mailed, faxed, or delivered in person to the address below.

Michelle Ramirez

Office of Environmental Health Hazard Assessment

P.O. Box 4010, MS-12B

Sacramento, California 95812-4010

Street Address:

1001 I Street

Sacramento, California 95814

Fax: 916-323-2265

Comments received during the public comment period will be posted on the OEHHA website after the close of the comment period. By sending your comments, you are waiving any right to privacy you may have in the information you provide. Commenters should advise OEHHA when submitting documents to request redaction of home address or personal telephone numbers. Electronic files submitted should not have any form of encryption.

For questions, contact Ms. Ramirez at Michelle.Ramirez@oehha.ca.gov or at 916-445-6900.

TSCA Reset Webcast

If your company manufactured or imported chemicals between June 21, 2006 and June 21, 2016, the EPA’s TSCA Inventory reset rule requires you to identify those substances as active on EPA central data exchange (CDX) by February 8, 2018.

If you process or use chemicals, you may identify them as active on the TSCA Inventory October 6, 2018. After October 6, 2018, chemicals which have not been identified as active on the TSCA Inventory may not, unless exempted, be imported, manufactured, processed, or used in commerce, in the United States.

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