Polyurethane association to defend MOCA in EPA risk assessment

Las Vegas — MOCA is on the minds of many at this year's Polyurethane Manufacturers Association Conference, an organization — and industry — that has become inextricably linked with the curative agent.

MOCA, or 4,4'-methylene-bis (2-chloroaniline), has been used  since the 1950s to improve the processing properties and ultimate durometer of a dynamic PU product. It also has been deemed a "known carcinogen to humans," a label that first was introduced by the Occupational Health and Safety Administration in 1973.

Now, the PMA has another chance to dim the environmental spotlight that has been on the additive for more than 50 years, as MOCA enters the pipeline of the EPA's risk assessment process.

"This might be the biggest moment for MOCA in 30 years," said Steve Seneker, a retired chemist from Anderson Development Co., based in Adrian, Mich. "This is probably our best shot … if we have a chance to stop it, this is it.

"Otherwise we have to manage it."

Seneker, along with several others in PMA, recently completed extensive research, culled from PMA guidelines and EPA information alike, on MOCA's "negligible" impact on humans.

The information is the foundation of a key presentation to EPA set for May 1.

On the call with the federal agency will be Seneker; Paul Waite, sales manager for North America with Era Polymers L.L.C. (and past president of the PMA); organization attorney Don Gallo, with Milwaukee-based Gallo Law; and Chris Goeloe, vice president of quality and responsible care with Anderson Development.

"We think MOCA is a perfect example of a win-win situation, by which our industry can continue to use MOCA freely, and a win for EPA to show that that they are not as stringent, that they see merit in establishing both high-priority and low-priority products for review," Waite told Rubber News April 14. "And MOCA is what low-priority looks like."

Rubber News is a sister publication of Plastics News.

MOCA is like many other chemicals that are unique in the performance traits they impart to a tire or non-tire rubber product. It is also going through a process similar to that facing vinyl chloride monomer.

To date, no one-for-one, drop-in replacement has been developed for MOCA, and suppliers in three states are out of MOCA: Kentucky, Oregon and California (which adopted early OSHA-proposed standards).

Since the early 1970s, the PMA has acquitted itself nicely, earning victories and credibility in the federal government's eyes for establishing its own guidelines for MOCA use and exposure.

"PMA established its own guidelines as a way to self-regulate," Waite said. "One of the reasons we have programs is to bring reasonable, rational, risk-based measures to protect against exposure to MOCA."

The birth of the organization, the very reason it was established, is entirely attributable to MOCA, as the PMA was formed to add collective clout to early proceedings with OSHA.

Things changed as they began to accelerate.

In 2014, a list of chemicals was announced by EPA as eligible for review.

And in December 2023, the EPA singled out MOCA for product prioritization, risk evaluation and risk management.

The chemical is in the risk prioritization phase now under the Toxic Substances Control Act, attorney Gallo told Rubber News. If it continues to be listed as a high-priority item, it will move to the risk evaluation and risk management stages.

"If it goes to this next stage, we all feel like we are going to lose because MOCA has been declared a carcinogen," Waite said. "If you have a carcinogen in there, you are a risk to public."

In the risk management phase, EPA could decide to phase out MOCA over a number of years; ban it immediately; or enact policies such as fenceline measurements or mandate human urinalysis tests for dermal absorption and possible contamination.

"We've worked really hard to craft policies that are good for our members and policies that respect the EPA process … but also policies that are not overburdensome to our members as well," Waite said.

The past president of the PMA added that he has engaged with manufacturers and distributors of MOCA.

"And we have been working on alternatives to MOCA for years and years," he said. "There are no drop-in replacements from a cost and processability standpoint.

"This is something that has been under fire since the 1970s."