LyondellBasell Comments on WHO BDO Proposal
Dear Valued Customer,
This is to inform you that the World Health Organization (WHO)has proposed to list BDO and GBL as Schedule 1 Psychoactive Substances under the 1971 United Nations Convention ratified by the United States. If approved by a 2/3 majority of the 53 voting nations, this listing would result in a worldwide ban of BDO and GBL for all industrial uses within 180 days. The vote will take place at the upcoming WHO convention in Vienna on March 9-17.
This ban would also impact the manufacture of NMP, THF, PTMEG (polyTHF), and their derivatives. Derogations from this ban could be sought by individual companies but would nonetheless result in very onerous and costly regulations. The US Food and Drug Administration (FDA) has already made its opposition to the WHO proposal public, but is soliciting comments from interested and affected parties.
Comments are due by February 26. BDO and GBL manufacturers and their customers have been working closely with their Chemical Industry Associations globally to develop opposition to this proposal. ACC has also reached out to other Chemical Industry Associations in the Americas and CEFIC, the European Chemical Association, to European, African, and Middle Eastern countries. A coordinated response is also being developed in Asia.
The American Chemistry Council’s (ACC) and Lyondell’s comments to the FDA are attached. We urge you to submit comments as well and to reach out to your Industry Association and your potentially impacted customers to formulate a consistent response before February 26th.
The link to submit your Company’s comments is: http://www.regulations.gov/#!docketDetail;D=FDA-2015-N-0045
Lyondell Chemical will be auditing its Product Stewardship Practices for BDO over the coming weeks. Please assist us with any requests for information, end use declaration letters, or requests for changes to current practices.