- Joined
- Nov 22, 2018
- Posts
- 24
There are two long statements, so in case you don't make it to the last paragraph, you should know this: ... if you want to know if a wax (fluorinated wax such as LF or HF or a topcoat or perfluorocarbon) is approved by the EPA, just ask the manufacturer for the Material Safety Data Sheet for that specific product. It should say in section 15 (Regulatory Information) if the components are listed or exempted by United States Inventory (TSCA 8b) or not. If this section does not address this, then the wax has not been approved by the EPA.
From Swix ....
HF & LF WAXES HAVE BEEN APPROVED
As the ski season nears, I am extremely pleased to announce that all Swix and Toko waxes shipping this Fall have been cleared for compliance with the U.S. Environmental Protection Agency’s (EPA’s) requirements under the Toxic Substance Control Act (TSCA). This includes all HF and LF fluorinated glide waxes, kick waxes, liquid waxes and cleaners.
During the last two seasons, the EPA has been conducting a nationwide compliance and enforcement initiative centered on examining the chemical ingredients in ski waxes and cleaners. This initiative is part of a broader program to examine the use of perfluorinated chemicals in consumer products. All chemical substances in consumer products, including ski waxes and cleaners, must be reviewed and approved by the EPA prior to use.
The EPA regulates the use of chemical substances in consumer products through the Toxic Substance Control Act of 1976. Under TSCA, the importer (or U.S. producer) of a chemical product must certify that every chemical substance in product complies with all TSCA regulations. It is not enough to simply ask the upstream supplier if their mixture or substance complies with TSCA, or to assume that substances and mixtures approved for use in Europe are also compliant with TSCA. The EPA expects the importer/producer to independently verify compliance with U.S. law by checking the identity of individual chemical substances against a list of substances called the “TSCA Inventory” or by obtaining certain types of written documentation of compliance from the supplier.
Swix USA recently completed an extensive review of all the chemical substances contained in their products and obtained the necessary documentation to ensure 100% compliance with TSCA, Toxic Substance Control Act. This long, investigative process caused a delay in SWIX and Toko’s ability to fulfill shipment of certain products during the 2018 - 2019 season, but it was necessary to undertake the process to verify 100% compliance with TSCA for all our products. To those customers who have had orders impacted by the delay, we understand and share in your frustration and we sincerely apologize for any disruption in your business.
In our efforts to be 100% compliant and to protect our retail partners - we encourage everyone to ask your suppliers if they have undertaken the type of supply chain investigation necessary to verify and document 100% compliance with all applicable US laws and regulations. If they are not able to confirm in written documentation that they (or their suppliers) have checked the identity of the individual chemical substances in their products against the TSCA Inventory, then they have not done what EPA requires to comply with the law.
In addition, Safety Data Sheets (SDS) for all Swix and Toko waxes and cleaners are in compliance with OSHA’s (Occupational Safety and Health Administration) workplace hazard communication requirements and other regulatory requirements such as California Proposition 65 (a California law that requires proper labeling and warnings for certain products sold or shipped in the state of California). The SDSs include a statement on TSCA compliance and provide important information for safely using our products.
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Updated info on Toko waxes from Toko USA:
97% of Toko waxes have been cleared for commerce by the EPA. We have signed documentation to verify the approval of our waxes and cleaners and we are now in 100% compliance with the TSCA law (EPA). The 3% of our waxes that have yet to be approved are the 100% fluorinated products (JetStream and HelX). We are working on solutions for this category and will inform you as soon as there is progress.
We do have new exciting products though that cover what was previously the LF and HF range. These products are not compromised to satisfy the EPA requirements. These are the very same products that are used on the World Cup and are the best performing waxes on the market. The development of these new waxes started three years ago when the Euro 2020 pact was made between leading wax manufacturers, the FIS, and the EU. They say "necessity breeds innovation". This is a perfect example of that. At the time the EU expressed concern about the toxicity of fluorine in racing ski waxes. We asked them what they would like to see and an agreement was made where there were minute thresholds set as to what kind of toxins the waxes could contain. These new waxes adhere to these thresholds. Not only are they the purest waxes (many raw materials contain impurities leading to toxicity) but they are also the least dangerous to use. The thresholds on PFOS and PFOSA and 31 other toxic substances come in at miniscule levels deemed to not be unhealthy. For example, these waxes contain less than 25 parts per billion of PFOA and less than 1 part per billion of most of the other harmful substances. One part per billion is 0.000001 milligrams per kilogram of wax. Despite this achievement of making the waxes substantially less toxic, they are also the fastest waxes we have ever made. We changed the length of the fluorine chains to extremely short and then put a ton of them in each fluorine molecule such that they are even more potent (in terms of being slippery, resisting dirt, and repelling water) than the previous less safe formulation. We also changed the name of the wax line. What was previously LF is now called "Performance" and what was HF is now called "High Performance".
One product to note is the High Performance Liquid Paraffin. This is a revolutionary product that yields quick application (flexible - you can apply it race morning once you know what is happening with the weather) and very fast skis. Generally it is applied over a hard base layer such as Hot Wax Performance Blue. There are a number of advantages to applying the High Performance Liquid Paraffin over a hard base wax such as increased acceleration, improved durability, and better dirt resistance. This is because the High Performance Liquid Paraffin does not get heated in and thus does not soften the base hardness the way it would be if it were heated in. You get the best of both worlds: a hard base that accelerates quickly, is dirt resistant, and very durable while at the same time having a wax job that is super slippery and hydrophobic. The Toko High Performance Liquid Paraffin does this better than any other liquid paraffin out there because our particle sizes are the smallest on the market. Having a small particle size means that it doesn't need to be heated in (which makes the particles smaller, but also softens the base) to be durable or fast. That's the whole key to the advantage that this wax gives over competitor products. High Performance Liquid Paraffin is approved for use whenever HF products (not top coats or perfluorocarbons) are allowed. They should be applied in a warm and dry environment and allowed to dry for an hour or more ideally (less still works though). They can also be reapplied outside at Nordic sprint events between rounds or for 2nd Alpine race runs with great results in wet snow with great speed but worse durability than if applied conventionally.
All of the Performance and High Performance waxes (including the liquid paraffin) should be available to ship the first week of October. Most all other Toko products are available now including the new Base Performance waxes (previously known as NF wax) and all grip waxes, klisters, and spray klisters.
By the way, if you want to know if a wax (fluorinated wax such as LF or HF or a topcoat or perfluorocarbon) is approved by the EPA, just ask the manufacturer for the Material Safety Data Sheet for that specific product. It should say in section 15 (Regulatory Information) if the components are listed or exempted by United States Inventory (TSCA 8b) or not. If this section does not address this, then the wax has not been approved by the EPA.
From Swix ....
HF & LF WAXES HAVE BEEN APPROVED
As the ski season nears, I am extremely pleased to announce that all Swix and Toko waxes shipping this Fall have been cleared for compliance with the U.S. Environmental Protection Agency’s (EPA’s) requirements under the Toxic Substance Control Act (TSCA). This includes all HF and LF fluorinated glide waxes, kick waxes, liquid waxes and cleaners.
During the last two seasons, the EPA has been conducting a nationwide compliance and enforcement initiative centered on examining the chemical ingredients in ski waxes and cleaners. This initiative is part of a broader program to examine the use of perfluorinated chemicals in consumer products. All chemical substances in consumer products, including ski waxes and cleaners, must be reviewed and approved by the EPA prior to use.
The EPA regulates the use of chemical substances in consumer products through the Toxic Substance Control Act of 1976. Under TSCA, the importer (or U.S. producer) of a chemical product must certify that every chemical substance in product complies with all TSCA regulations. It is not enough to simply ask the upstream supplier if their mixture or substance complies with TSCA, or to assume that substances and mixtures approved for use in Europe are also compliant with TSCA. The EPA expects the importer/producer to independently verify compliance with U.S. law by checking the identity of individual chemical substances against a list of substances called the “TSCA Inventory” or by obtaining certain types of written documentation of compliance from the supplier.
Swix USA recently completed an extensive review of all the chemical substances contained in their products and obtained the necessary documentation to ensure 100% compliance with TSCA, Toxic Substance Control Act. This long, investigative process caused a delay in SWIX and Toko’s ability to fulfill shipment of certain products during the 2018 - 2019 season, but it was necessary to undertake the process to verify 100% compliance with TSCA for all our products. To those customers who have had orders impacted by the delay, we understand and share in your frustration and we sincerely apologize for any disruption in your business.
In our efforts to be 100% compliant and to protect our retail partners - we encourage everyone to ask your suppliers if they have undertaken the type of supply chain investigation necessary to verify and document 100% compliance with all applicable US laws and regulations. If they are not able to confirm in written documentation that they (or their suppliers) have checked the identity of the individual chemical substances in their products against the TSCA Inventory, then they have not done what EPA requires to comply with the law.
In addition, Safety Data Sheets (SDS) for all Swix and Toko waxes and cleaners are in compliance with OSHA’s (Occupational Safety and Health Administration) workplace hazard communication requirements and other regulatory requirements such as California Proposition 65 (a California law that requires proper labeling and warnings for certain products sold or shipped in the state of California). The SDSs include a statement on TSCA compliance and provide important information for safely using our products.
----------
Updated info on Toko waxes from Toko USA:
97% of Toko waxes have been cleared for commerce by the EPA. We have signed documentation to verify the approval of our waxes and cleaners and we are now in 100% compliance with the TSCA law (EPA). The 3% of our waxes that have yet to be approved are the 100% fluorinated products (JetStream and HelX). We are working on solutions for this category and will inform you as soon as there is progress.
We do have new exciting products though that cover what was previously the LF and HF range. These products are not compromised to satisfy the EPA requirements. These are the very same products that are used on the World Cup and are the best performing waxes on the market. The development of these new waxes started three years ago when the Euro 2020 pact was made between leading wax manufacturers, the FIS, and the EU. They say "necessity breeds innovation". This is a perfect example of that. At the time the EU expressed concern about the toxicity of fluorine in racing ski waxes. We asked them what they would like to see and an agreement was made where there were minute thresholds set as to what kind of toxins the waxes could contain. These new waxes adhere to these thresholds. Not only are they the purest waxes (many raw materials contain impurities leading to toxicity) but they are also the least dangerous to use. The thresholds on PFOS and PFOSA and 31 other toxic substances come in at miniscule levels deemed to not be unhealthy. For example, these waxes contain less than 25 parts per billion of PFOA and less than 1 part per billion of most of the other harmful substances. One part per billion is 0.000001 milligrams per kilogram of wax. Despite this achievement of making the waxes substantially less toxic, they are also the fastest waxes we have ever made. We changed the length of the fluorine chains to extremely short and then put a ton of them in each fluorine molecule such that they are even more potent (in terms of being slippery, resisting dirt, and repelling water) than the previous less safe formulation. We also changed the name of the wax line. What was previously LF is now called "Performance" and what was HF is now called "High Performance".
One product to note is the High Performance Liquid Paraffin. This is a revolutionary product that yields quick application (flexible - you can apply it race morning once you know what is happening with the weather) and very fast skis. Generally it is applied over a hard base layer such as Hot Wax Performance Blue. There are a number of advantages to applying the High Performance Liquid Paraffin over a hard base wax such as increased acceleration, improved durability, and better dirt resistance. This is because the High Performance Liquid Paraffin does not get heated in and thus does not soften the base hardness the way it would be if it were heated in. You get the best of both worlds: a hard base that accelerates quickly, is dirt resistant, and very durable while at the same time having a wax job that is super slippery and hydrophobic. The Toko High Performance Liquid Paraffin does this better than any other liquid paraffin out there because our particle sizes are the smallest on the market. Having a small particle size means that it doesn't need to be heated in (which makes the particles smaller, but also softens the base) to be durable or fast. That's the whole key to the advantage that this wax gives over competitor products. High Performance Liquid Paraffin is approved for use whenever HF products (not top coats or perfluorocarbons) are allowed. They should be applied in a warm and dry environment and allowed to dry for an hour or more ideally (less still works though). They can also be reapplied outside at Nordic sprint events between rounds or for 2nd Alpine race runs with great results in wet snow with great speed but worse durability than if applied conventionally.
All of the Performance and High Performance waxes (including the liquid paraffin) should be available to ship the first week of October. Most all other Toko products are available now including the new Base Performance waxes (previously known as NF wax) and all grip waxes, klisters, and spray klisters.
By the way, if you want to know if a wax (fluorinated wax such as LF or HF or a topcoat or perfluorocarbon) is approved by the EPA, just ask the manufacturer for the Material Safety Data Sheet for that specific product. It should say in section 15 (Regulatory Information) if the components are listed or exempted by United States Inventory (TSCA 8b) or not. If this section does not address this, then the wax has not been approved by the EPA.
