ECHA (European Chemical Agency) has launched, open to 7th February 2020, a public consultation on a proposal to classify (CLH) melamine as Cat 2 carcinogen (H351 suspected carcinogen) STOT RE1 (specific target organ toxicity, H372 urinary tract), based on possible risks from oral intake.
Melamine is widely mis-known to the public as the veneers on furniture, kitchen surfaces or kitchen utensils – but in fact these are melamine formaldehyde resin, a polymer of melamine. Melamine compounds and melamine itself are used as PIN flame retardants, because they contain nitrogen, which is released to dilute fire gases and which releases nitrous gases which inhibit flames. These compounds are highly compatible with polymers, so that losses from treated plastics are very low. Oral intake is not relevant for flame retardant use.
The proposed classification of melamine is related to oral intake, a consequence of criminal addition of melamine to foods or animal foods in the past, especially in China (the nitrogen falsely simulates higher protein content in standard analysis).
The ECHA consultation is based on a CLH report (Proposal for Harmonised Classification and Labelling) submitted by the German Federal Institute for Occupational Safety and Health (BAuA). This report concludes that “A substantial body of evidence concerning melamine-related toxicity following repeated oral exposure exists”. The data suggests that this is related to generation of crystals / stones (calculi) in kidneys, which may then be related to urinary tract cancer risk, stating that, despite the CLP Guidance which indicates that urinary bladder tumours due to crystals in the bladder is a mechanism that is not relevant for humans, nonetheless “calculus formation as a consequence of melamine exposure poses a carcinogenic risk to humans”. The report also concludes that “Available reliable and relevant … genotoxicity studies with melamine are negative and do not indicate a mutagenic activity for that substance. Based on conclusive data, classification of melamine as mutagen is not warranted”.Responses to the public consultation can include new evidence or data, analysis of the data presented by BAuA, information about downstream consequences of the proposed classifications, information about substitutes or any other relevant information. For more information, see the European Melamine Producers Association (EMPA).
Melamine compounds used as PIN flame retardants include: Melamine itself, Melamine cyanurate, Melamine borate, Melamine phosphate, Melamine polyphosphate, Melamine-poly(aluminium phosphate) – see pinfa Product Selector https://www.pinfa.eu/product-selector/
Melamine-poly(zinc phosphate)ECHA public consultation on classification of melamine, open to 7 February 2019 https://echa.europa.eu/harmonised-classification-and-labelling-consultation/-/substance-rev/24503/term
“CLH report Proposal for Harmonised Classification and Labelling” for Melamine (1,3,5-triazine-2,4,6-triamine), Federal Institute for Occupational Safety and Health (BAuA), Germany, November 2019 https://echa.europa.eu/documents/10162/2b381a74-d564-2fde-174a-35fe4eb7368a
European Melamine Producers Association (EMPA) https://melamine.cefic.org/