Risk assessment of leather dyestuff Risk assessment of leather dyestuffs by Dr. Alois Püntener Abstract Public interest is increasingly focused on leather goods and the potential risks to our health and the environment arising from them. Although these hazards are not substantiated by any established findings, the media seize on them and often paint a very alarmist picture in their stories. Fortunately, the real picture is not all black, there are also some positive aspects. The leather industry is making considerable progress in improving its environmental performance. This paper will look at risk and life-cycle assessment of leather dyes. The identification of human health and environmental hazards are important prerequisites for risk and life cycle assessment. Good quality information on exposure is needed to address the risk objectively, and possible options for risk reduction. Risk management should indeed start with a careful selection of colorants that exhibit the required performance with regard to substrate affinity, fastness and other boundary conditions. The environmental risk posed by a colorant can be defined in both its inherent ecotoxicity and the concentrations attained in the environmental compartments. There is an increasing body of circumstantial evidence indicating that the portion of colorants entering the environment is ultimately degradable either by biological or photochemical pathways. 1 Introduction There appears to be growing concern regarding the impact of leather on the environment and the health of consumers. The general public and the authorities are paying increasing attention to these areas, and additional regulations are being developed accordingly. All aspects from origination right through to disposal have to be taken into account. Life Cycle and Risk Assessments are important tools to investigate the ecological and toxicological impact of processes and products. The results of Life Cycle or Risk Assessments are only meaningful in the context of the goals, scope and limitation of the study. Life Cycle and Risk Assessments address different but similar issues. Life Cycle Assessments 1 (LCA) examine the ecological consequences, or what is known as the ”Environmental Burden" of producing and using goods: ISO 14 040 (1996 Draft). Any systematic approach to shifting the life cycle of leather towards a lower environmental impact should cover all the relevant aspects including, the air, soil, water, energy and resources involved for all parties. The cycle starts with the farmer and slaughterhouses, and moves on to the tanners, and dye and chemical manufacturers, then on to the leather goods manufacturers and retailers, and it finally ends with disposal. All relevant emissions and resource consumption should be studied. However the study can only be completed if all the participants along the process chain including tanners, leather goods producers, retailers and consumers contribute the necessary ecological data. Risk assessment 2 (RA) studies, like ”Risk Assessment of Leather Dyes”, focus on toxicity and the impact on human beings and the environment: European Union Council Directive of June 27, 1997 (67/548/EEC). A leather dye manufacturer’s responsibility does not start with the production of dyes and end with the delivery to the tanners. The integrated approach of such a study needs to consider the starting chemicals, the method and control of synthesis including purification, the packaging, the means of transport and storage, performance in dyeing, impact on the consumer and finally behaviour on ultimate disposal. Two different issues that are often not clearly differentiated have to be addressed: Workplace Risk and Consumer Risk. Leather Dyes in the Environment Workplace risk: Today, there is a great deal of data available on the toxicological aspects of dyes. Human exposure to leather dyes occurs primarily at dye manufacturing plants and within tannery dyehouses. Dye production is akin to a balancing act between the needs of a broad public on the one hand, and the demand for responsible treatment of the environment on the 2 other. Irrespective of whether ”synthetic” or ”natural” dyes are being produced, they are usually accompanied by unwanted by-products. In these respects, dye manufacture is no different from other industrial scale production such as in the manufacture of pharmaceuticals, detergents, ”natural” or ”synthetic” chemicals, or even leather. Not surprisingly, the authorities, scientists, and general public are taking an increasingly active role in the debate about the risk potential of the production of dyes, and the risks of exposure to dyes. In common with other chemicals and natural substances, dyes can trigger allergies in some individuals. Finding an universal solution to this problem is as difficult as the allergy is unpleasant to the person affected. Every replacement substance, whether ”natural” or ”synthetic”, may affect yet other individuals. The OECD Guideline No. 406 regulates a test procedure to investigate sensitisation, in order to determine possible hazards. It has been reported that the sensitisation effects of some commercial grades are due to the presence of soluble impurities. Under a recently established occupational skin surveillance scheme in the United Kingdom (UK), out of a total 2811 case reports of occupational skin disease received, only 19 cases (less then 1%) were related to employees who could possibly have been exposed to dyes 3. Consumer risk: Direct contact between dyed leather and the skin of the consumer represents a very small part of leather usage. It occurs in some watchband and sandal leathers, but the bulk of leather articles do not normally involve direct skin contact. In contrast, most textile articles are designed for direct skin contact. Dyes can also be inhaled in the form of dust but this happens, if at all, during dye manufacturing and application processing. Possible uptake through the skin or via ingestion is extremely slight, but may occur if the dye is not properly fixed. Moreover, leather products for medical use or for children have to conform to stricter restrictions than standard articles. But if leather dyes have a high level of fastness and they are properly fixed, there is little risk for the consumer of dye uptake via skin or mouth, and the risk of allergies is very small. However, the German Consumer Act 4, which includes leather as a consumer material, has intensified the discussion about the potential risk of dyed leather goods. A common misconception is that these regulations apply to all azo dyes and that every azo dye is dangerous. This is far from true. Azo dyes are the major dye class of commercial synthetic dyes for leather, textile, paper and food. Today, only a few dyes are produced that fall under the German decree and alternatives are available for those dyes. We have to remember that leather dye producers such as TFL (previously Ciba) do not manufacture or market azo dyes for leather or other materials that, when 3 analysed according to DIN 53316, could through cleavage of one or more azo groups form the specified amines listed in the German Consumer Goods Act. This applies to most members of the Ecological and Toxicological Association of Dyes and Organic Pigments Manufacturers (ETAD). Toxicological aspects Some of the raw materials and intermediates required for the synthesis of dyes are more toxic than the final dyes produced. Inevitably, therefore, these raw materials are potentially hazardous, and that must be minimised by appropriate precautions during production. These risks do not apply to the user in the tanneries and the consumer. A prerequisite is that the dye manufacturer ensures the absence of possibly hazardous raw material. Before being released to the trade, new leather dyes have to be tested for ecological and toxicological properties, as dyes are chemicals foreign to the human body. The test criteria are specified in official regulations, and followed by the manufacturer as part of his responsibility towards the user. The principles of risk assessment of new substances, like leather dyes, are laid down in European Union Commission Directive 93/67/EEC and include: hazard identification, dose-response assessment, exposure assessment for the environmental compartments, and risk characterisation. Cost of registration of a new leather dye lies between 100’000 and 250’000 US$. A testing program for existing products is also under discussion. Analysis of the available data on these dyes provides adequate evidence that no major hazard is to be feared. An examination of more than 4400 organic dyes by analysing the Material Safety Data Sheets has confirmed that most of them have an LD 50 value (lethal dose by 50% of the tested rats) that is greater than 2000 milligrams/kg 5. Only a minority of commercially available dyes must be classified as ”harmful” according to EC Guidelines. Pathways of Leather Dyes into the Environment Despite the negligible acute toxicity of dyes and the numerous efforts undertaken to avoid or reduce risks, dye manufacturers and tanneries are confronted with effluents, wastes and contaminated containers or packaging material that require carefully thought out disposal. TFL and other dye suppliers use reusable containers for bulk products, or packaging material which can be emptied without leaving any residues and does not generate any special waste. The primary route by which dye enters the environment from dye manufacturers and tanneries is through the production of wastewater, and also through the disposal of sludge containing dyes precipitated from the effluent by flocculation. A prerequisite for a colorant to enter the environment is its solubility. Colorants that enter the wastewater streams (estimates are 1 to 5% of the world production of leather dyes) normally pass through a wastewater treatment plant where they are eliminated to a large degree by adsorption on the sludge. The extent to which 4 residual amounts reach the surface waters depends on the efficiency of treatment processes. The fate of dyes adsorbed to sludge is generally incineration or disposal in a controlled landfill. Dye manufacturers: The following mass flow can be estimated for the production building of an average dye manufacturing plant. For the production of 10’000 tonnes of dyes per year 1-2% of waste and 5-10% of carbon-based chemicals in the waste water have to be expected. These materials are generated as by-products during synthesis, and are removed from the dyes to maintain quality. These by-products could also interfere with the application of the dye. For purification, special processes are often necessary which yield waste, which needs special disposal. Tanneries: In tanneries the exhaustion of a good dye is 96 to 99% (or higher) and therefore the problem is less relevant than with other chemicals. In tanneries, which in many cases produce large quantities of waste, only approximately 1% of waste arises from the dyeing process. It has to be noted that dyes are typically applied for a limited time in a number of different drums (point sources). Detailed data for the weight of processed dye are difficult to generate because of the use of different shades and production strategies, so it is not normally possible to predict usage for individual customers. Initial Environmental Concentration may be calculated for a day’s operation of a tannery dyehouse using the following formula 6 : E= W1 x W2 100-F x A 100 100 where E W1 W2 F A = = = = = (1) emission per day (kg/d) mass of dyed goods per day (t/d) mass of dye used per mass of raw hides (kg/t) degree of fixation of dyes (%) participation factor (50 %) It should be taken into consideration that many tanneries are only processing wet blue, wet end or finishing operations. W2 refers to the mass of raw hides which is 4 times greater than the mass of dye goods per day. Instead of using this somewhat unclear definition, we propose the following equations E= where D x 100-F x A 100 100 D = (2) mass of dyes used (kg) A participation factor on production per day (50 %) may be used by dyestuffs, since in practice the dyeing step with a specific dye does not take a full day. We 5 recommend a formula similar to that of ETAD7 E= where D x (100-F) x (100-P) 100 100 P = (3) degree of elimination (%) Elimination of dyes may occur through adsorption on sediments and suspended particles with subsequent removal from the waste water by settling or filtration. The results can be quite significant depending on the nature of the dye molecule. The above equations are only applicable to exhausted drum dyeing processes. Major dye-classes used in the leather industry are direct and acid dyes (this accounts for about 85%), metal complex dyes (around 10%) and, to a lesser extent, sulphur (around 2%), cationic and other dyes. A straightforward calculation of environmental releases is possible by using equation (3). Realistic parameters for a tannery producing dyed grain leather with an output of approximately 400 - 600 hides per day are as follows 8 : Dyes % fixation % dyeing dyed grain leather dyes used % elimination emission sulphur 92 2 10 t 200 kg 70 4.8 kg/d acid 96 2 10 t 200 kg 70 2.4 kg/d direct 98 2 10 t 200 kg 95 0.2 kg/d metal complex 99 2 10 t 200 kg 90 0.20 kg/d Realistic parameters for a tannery dyeing suede leather with an output of 400 -600 hides per day are as follows. In this case we have to consider that exhaustion of suede is normally higher than grain leather, however more dye is often needed and therefore fixation levels are somewhat lower: Dyes % fixation % dyeing dyed suede leather dyes used % elimination emission sulphur 90 4 10 t 400 kg 70 12 kg acid 94 4 10 t 400 kg 70 7.2 kg/d direct 96 4 10 t 400 kg 95 0.8 kg/d metal complex 98 4 10 t 400 kg 90 0.8 kg/d The volumes of effluent and the concentration of ingredients varies to a large degree depending on plant capacity, tanning technology, dyeing and waste water management. To produce 10t of leather, approximately 40t of raw hides are used and up to an estimated 2000 m3 water 9. Today, modern tannery have reduced this amount dramatically down to around 1000 m3 10. 6 Applying the above equation results to an Initial Environmental Concentration gives a concentration of 10 to 0.1 ppm dyes in the waste water for an average tannery. Such a concentration is well below any level for concern for ecotoxicity and would hardly be visible in a well-mixed effluent. However, it should not be forgotten that low concentrations, that is more than 10 ppm of colorant in receiving waters, can cause visible coloration and may raise public concern, although the low concentrations involved do not normally pose any significant environmental hazard. Dyes can be removed easily in the effluent treatment plant. Before passing through a mechanical-biological treatment, dyes are part-purified by decoloring, pH neutralisation and precipitation and through adsorption with flocculation agents. The sludge can then either be incinerated or dumped. In both cases, in a landfill or in water, biodegradability of the dye is important and ecotoxicity must be considered. In order to study the effects on aquatic organisms, aquatic toxicity is tested using Zebra fish (Brachydanio rerio) and Daphnia magna. The growth inhibition on alga (Scenedesmus subspicatus) is also measured. There is a considerable body of evidence that synthetic colorants in general, and watersoluble dyes in particular, are unlikely to be bio-accumulative. On this basis it may be predicted that long-term chronic effects on aquatic organisms are very unlikely to result from continuous exposure. Where sewage sludge is concerned, and in particular when it is used as an agricultural fertiliser, the possible effects of sludge contaminants on the soil must be considered. The Zahn-Wellen Test (OECD Guideline 302B) was adopted to determine inherent biodegradability. According to different studies, it seems unlikely that a calculation of the theoretical concentration of a dye in sewage sludge will lead to any concern about use as an agricultural fertiliser. Disposal of Leather Goods Leather is used to make consumer goods which sooner or later end up as household refuse. The consumer has a responsibility not to use the simplest method of disposal - unfortunately still in common practice - that is, just throwing refuse away. Campaigns to collect worn and unwanted articles and sporadic recycling initiatives do somewhat improve the situation. However the best solution would be to make new material or products from recovered leather. The second best way to dispose of used leather is by incineration, because leather provides considerable amounts of energy. The simplest method would be to return the used natural product leather to nature, i.e. to compost it. We are therefore studying this solution carefully. Some initial progress has been achieved. We have ascertained that soluble dyes and some organic pigments degrade under given biological conditions. This also applies to chromium complex dyes. Only copper complex dyes in high concentrations can slow down the degradation of organic substances to minerals and humic acids, since copper salts have a fungicidal effect 11. 7 Various studies have shown that dyes are degradable, and degradation of colorants in the environment is likely to be a very natural process 12, particularly under anaerobic conditions. Reductive cleavage to metabolites, which may be further degradable to natural species, could occur. Dyes and leather can also degrade by photochemical means as an ageing process, but this is also usual for dyes dissolved in water or leather exposed to sunlight. The same natural species are obtained as through composting where degradation is a biological process. Degradation in the soil or air is comparable to the process which takes place in water. Role of natural dyes The use of natural dyes is attracting growing attention. However their extraction and processing cannot, in general, be regarded as environmentally friendly or even environmentally benign. To dye 100 kg. leather with 2% dye requires approximately 100kg. dried leaves, equivalent to 500 to 1000kg. freshly picked leaves. Even if only a small fraction of the leather produced were dyed with vegetable dyes, very large plantations would be necessary. In addition, dye producing plants, with a few minor exceptions, supply no foodstuffs or other useful by-products. The chromophore is often present only in very small, often unknown quantities and is unevenly distributed. The extraction process also produces a large amount of inert materials which have to be removed from the goods or the dyebaths. Take indigo, one of best known organic dyes: From 300 kg of fresh indigo plants a farmer could produce after extraction roughly 1 kg of pure Indigo dyes with a lot of waste as a by-product. ”Isatis tinctoria” plants are harvested before they bloom and fermented in water pools. After the intense carbon dioxide output has finished, the indigo has to be oxidised, filtered and dried. The farmer would fetch a price comparable to that of synthetic Indigo - about US-$ 20/kg. This is in great contrast to the expense of growing, harvesting and isolating the Indigo component. Another well know natural dye is Cochenille: For 1 kg dye 140’000 ”Coccus cacti lice” are needed. The insect grows on the ”Opuntia coccinellifera” cactus. Compare this with the two-step synthesis of 1 kg azo dyestuff, which needs approximately: 1 1 1 0.25 0.50 50 kg raw material kg acid kg alkali kg soda nitride kg common salt l water A more realistic option in the long term could well be the production of natural dyes with the aid of genetically engineered micro-organisms. Today it is possible to achieve indigo yields of a few grams per litre per day by fermentation, however, this 8 process is still too expensive. Whether more efficient yields and better costs will be forthcoming with this or other dyes cannot be predicted at this time. Conclusion Colours and coloration in their various manifestation are a part of every culture and heritage and our daily lives would be unthinkable without them. Dyed leather in the form of shoes, clothing, upholstery and other consumer goods offer wearers and users a sense of well being and comfort. There is an increasing body of circumstantial evidence that the small portion of colorants entering the water or soil does not significantly harm the environment. Risk Assessment of leather dyes is a function of both the hazard characteristics and the environmental exposure (concentration and duration). Effects on organisms in the environment can be either short-term, e.g., acute toxicity to fish or daphnia, reproductive effects, or long-term (chronic), e.g., effects on growth. There are currently no data known that would indicate accumulation of dyes in terrestrial and aquatic food chains. If the characteristics of natural and synthetic dyes are compared, synthetic dyes are clearly superior with better fastness properties and shade reproducibility. In addition they generate less pollution during synthesis and application. High quality dyeing includes, of course, not only features such as high fastness and good fixation, but also safety in use, and no toxic hazard. Dyed leather itself is not a hazard to human beings nor is it harmful to the environment. At the consumer level, the stability of leather and fastness properties of dyes ensure a long functional life for leather goods. On balance this has the long term effect of saving raw material and energy against that needed to produce cheap throw away articles which pollute the environment. Members of the public and the authorities have to recognise that the aggregate environmental balance-sheet for dyed leather and synthetic dyes has been substantially improved by the responsible use of natural resources and pollution control in order to produce a long lasting quality product. Acknowledgements This paper is based on several in-house reports and application tests carried out by TFL Colleagues. Grateful thanks also to the ETAD for discussions. 9 Literature 1 R. Bretz and Peter Fankhauser, Chimia 51 (1997) 213-217 P. Richner and A. Weidenhaupt Chimia 51 (1997) 222-227 3 E.A. Clarke and D. Steinle, Rev. Prog. Coloration 25 (1995) 1-5 4 Bekanntmachung der Neufassung des Lebensmittel- und Bedarfsgegenständegesetzes vom 8. Juli 1993, Bundesgesetzblatt 1993, Teil 1, 1169-1188 5 R. Anliker, J.Soc.Dyers Col. 95 (1979) 317 ff 6 Technical Guideline, Documentation for Risk Assessment EU(1488) 7 H. Motschi, Chemical Safety Mervyn Richardson (1994) 329-352, Verlagsgesellschaft VCH 8 Based on intenal TFL tests and information 9 K.T.W. Alexander et all, JSLTC 76 p.17-23 10 A. Püntener, Leder und Häutemarkt, (1995) 4--14 (276 G+P) 11 A. Püntener und N. Schwind, Das Leder (1994) 18-23 12 K. Hunger, Chimia 48 (1994) 520-522 2 updated 5.Jan. 2004 10