Protopasta Labeling and Safe Use

2021 topic update:

Health and safety is important to us and we've worked to lead by example within our industry. Starting in 2019, we added Prop 65 labeling for materials including those made with powdered titanium dioxide and carbon black. These are common ingredients used by every filament manufacturer (and in so many consumer goods) that we just chose to identify even though consumers will not be exposed to these powders during normal use.

For anyone familiar with Prop 65, you know warnings are everywhere and on everything. We wanted to cover our bases and do the right thing, but went too far in 2019. Unfortunately, the proliferation of warnings either makes folks hyper-aware of all stated risks (whether real or not) or ignore all risks, even real ones. It now seems the right thing to do is remove the warnings for these two powders where there is no risk of exposure in normal use in 2021. Warnings will remain on our Stainless Steel and PC-ABS product for other chemicals, but the rest of our materials, as they are newly manufactured, will no longer warn of titanium dioxide and carbon black exposure risk.

The California Office of Environmental Health Hazard Assessment (OEHHA) shares concern about businesses putting labeling on products “just in case” or to prevent future legal trouble down the road. Our decision to remove warnings for titanium dioxide and carbon black came after reading this: https://oehha.ca.gov/media/downloads/crnr/p65shortformisorf2021.pdf

Some relevant excerpts:

A guitar manufacturer replied, “…two chemicals were listed as ingredients in paint … that is applied on to some guitars … that under normal use conditions … [manufacturer] does not anticipate that its guitars would expose a customer to these chemicals, but that the warnings were provided out of an abundance of caution.” - page 7

A reduction in over-warning furthers the purposes of the Act by reducing the unnecessary proliferation of Proposition 65 warnings where a chemical exposure is unlikely to occur and ensuring that consumers are provided with truthful, accurate information about anticipated exposures to listed chemicals from consumer products where they can occur. - page 8

What’s your stance on this topic?  We’re curious because, in the end, we want to do the right thing, and it seems avoiding undue alarm by reversing our decision to add labels for encapsulated carbon black and titanium dioxide powder is just that. We hope you agree.

Safe printing, The Protopasta Team

Now obsolete 2019 post for perspective:

You may have noticed our new Prop 65 labels on our product. Sorry if they are alarming. Fear not! Continue reading for perspective on the actual associated risk and reason for labeling.

Materials with ingredients on California's Prop 65 list include physical labeling in compliance with California law. Composition-based labeling provided as actual exposure risk is not quantified. Particulate exposure risk is low based on encapsulation in plastic. If exposing particles through abrasive processes like sanding, please seek proper PPE & ventilation to minimize particulate exposure. Vapor risk is generally low for PLAs, but other plastics like PC-ABS can introduce greater risk. Process & room conditions can also influence exposure. In general, please operate in a well-ventilated area and seek proper PPE as required.

This warning label is on any material with black or white pigments (carbon black and titanium dioxide). Pearl also contains titanium dioxide. These are industry standard additives and the risk is in particle form when not encapsulated in plastic. Glitter and other colors have no carcinogens to report. This is no different that everyone else's materials, we're just calling it out...

The carbon black all us filament manufacturers use is considered a carcinogen in powder form. A user's exposure to powdered carbon black is likely zero but it's the manufacturer's burden to prove exposure level. Instead of proving safe exposure level, we labeled based on composition. Unfortunately, this is mostly misleading, creating fear where there need not be any. Any chance of exposure would be in sanding or burning the filament to separate the carbon black. Again, carbon black is in everything so I understand this seems a bit over the top.

Again, the actual risk exposure related to titanium dioxide mirrors that of carbon black.

Our first goal with these labels is to comply with California law, but my hope would be to create awareness rather than alarm. I'm not sure these labels do that. This exercise has made us more aware of the risk when working with the dry ingredients so we can adapt our working conditions accordingly.

For our customers, the practical implication is a reminder of proper ventilation and protection from dust when sanding and fumes when printing. Carbon black and titanium dioxide is in everything around us. In fact, titanium dioxide is in particle form and free in the air in many cosmetics so there is a risk to using make-up, for example.

The style of communication California requires is more alarmist than educating. This is unfortunate because I expect the typical response is fear ceasing use or ignoring with continued use (neither of which is ideal), rather than education in assessing real risk and adapting how to use in a safe way.