Proposed Priority Product: Nail Products Containing Triphenyl Phosphate

We propose to list nail products containing triphenyl phosphate as a Priority Product. The Product-Chemical Profile on Nail Products Containing Triphenyl Phosphate (TPhP) explains the scientific, regulatory, and legal basis for this proposal.

Rationale for Priority Product Listing

TPhP has the potential to adversely impact the general population as well as salon workers, pregnant women, infants, and children. Exposure to TPhP can cause liver toxicity, endocrine toxicity, developmental toxicity, neurotoxicity, and reproductive toxicity.

TPhP is added as a plasticizer to nail coatings and nail treatments to provide flexibility and durability. The primary route of exposure to TPhP in nail products is dermal contact, with inhalation potentially contributing as well. There is also evidence for lactational and transplacental transfer of TPhP. Exposure to TPhP can cause liver toxicity, endocrine toxicity, developmental toxicity, neurotoxicity, and reproductive toxicity. In particular, pregnant salon workers are at risk of exposing their fetuses to TPhP in the womb, as well as well as their breastfeeding infants (because TPhP can  be found in breastmilk). Furthermore, nail salon workers who bring their infants and children to work may expose them to TPhP present in indoor air. As infants and children develop, they are more susceptible to TPhP exposure than adults.

Alternatives Analysis Threshold

Because TPhP may be present as a contaminant in nail products, the Safer Consumer Products Regulations require us to set an Alternatives Analysis Threshold (AAT) level, below which manufacturers do not have to submit an Alternatives Analysis. We are proposing to set the AAT for TPhP in nail products at 250 parts per million (ppm). The rationale for the proposed AAT along with a proposed Method Performance Criteria for manufacturers to meet the AAT level is provided in our product-chemical profile.

Public Engagement