carbonless.org
Carbonless Copy Paper Injury and Information Network

TSCA Compliant Page

Recommendation on writing to EPA TSCA

Letter should include the following: Send to the Environmental Manager, of Public Relations or H&S with his/her complete title, company name, address, cc to the CEO.  Also cc to EPA TSCA Director.  Send your complaint via fax and certified mail. Letter must specifically state their complete company name, etc that you are making a formal complaint of "significant adverse reactions" to their carbonless copy paper, an "article" which is manufactured and put into commerce by ____________.  I am enclosing a list of possible chemicals contained in your ccp, that may alone, or in a combination, have caused these significant adverse reactions to my health.  I am making these allegations on behalf of myself and others in the class who may have and/or are experiencing significant adverse reactions to your carbonless copy paper.

You must state worked with ccp in an occupational setting, how many injuries of high exposure, or if it was a daily exposure due to handling volumes of ccp daily.  State when the high exposure or daily repeated adverse health problems were diagnosed.  Advise that until that diagnosis, you had no way of knowing you had developed permanent, severe and life threatening reactions, nor that upon re-exposure to their ccp you would come close to death (if applicable).  The chemicals that have caused such harm penetrate the body through dermal contact, inhalation, and ingestion.  There are no warnings on the Material Safety Data Sheets to indicate the same type of allegations that I am making have been reported to your company hundreds to thousands of times earlier by others injured by ccp.  Once I was diagnosed with chemical damage, I discovered many other employees had the identical adverse health problems.  This caused me to search if other individuals using ccp nationwide had developed adverse problems.  Other individuals, thousands, have developed adverse health problems due to use, working or handling of carbonless copy paper.

The "significant adverse reactions" to my health and those observed and been advised of others who have suffered "significant adverse reactions" from the use and/or handling, exposure to your ccp are:  Examples:  cancer, skin damage, central nervous system damage or problems, vision and visual field damage, memory deficits, short term memory loss and problems, a noted abnormality in coordination, vascular damage, signs of isocyanate damage to the skin, peripheral neuropathy, nerve conduction damage, fatigue problems, gastrointestinal problems, digestive problems, reactive airways disease syndrome, damage to the heart, liver, kidneys and immune system. Upon reexposure to ccp, I have suffered, witnessed, read of others damaged by ccp having seizures, becoming unconscious, severe asthmatic reactions, alarming increase or decrease of blood pressure, alarming increase in heart rate, throat closings, swelling all over the body, loss of vision, severe pain, immediate  histamine release, unable to walk or talk and many more life threatening reactions. As many others severely damaged from working/handling thousands of ccp forms, I have permanent damage with disabilities.  The "significant adverse reactions" from  ccp have taken my health leaving instead a poor quality of life.

I have outlined for you the allegations as described in the "EPA TSCA Rules of Section 8(c). Also as described in EPA TSCA RULE 8(c), I am alleging that carbonless copy paper, and their chemical components, presents a substantia risk of injury to human health.  I have been advised to expect under TSCA 8(c) that this complaint is to be filed with the EPA's TSCA within 15 working days as is required by EPA TSCA Federal Laws.

You must include a list of chemicals or components in the ccp that caused your "significant adverse reactions."  CCPIIN on the http://www.carbonlesscopypaper.com components section the list gathered from public documents. On this site, the biocides page lists biocides known to have been used by ccp manufacturers in their paper.  These CCPIIN pages can be used in your TSCA complaints.   This is an outline of what is necessary under 8(c).  You may use your own wording  but an EPA person suggested the contents.  List your complete name, address,and contact numbers.

Charles M. Auer  Director OPPT  
(202) 564-3810
Office of Pollution Prevention and Toxics,
Environmental Protection Agency,
1200 Pennsylvania Ave., NW.,
Washington, DC 20460

  http://www.epa.gov/compliance/civil/federal/tsca.html http://www4.law.cornell.edu/uscode/15/ch53.html