C H L O R I N A T E D P A R A F F I N S
1250 Connecticut Avenue, N.W. | Suite 700 | Washington, D.C. 20036 | 202-637-9040 | Fax: 202-637-9178
I N D U S T R Y A S S O C I A T I O N
CHLORINATED PARAFFINS IN THE TWENTY-FIRST CENTURY
By Robert J. Fensterheim, MPH
Executive Director, Chlorinated Paraffins Industry AssociationChlorinated paraffins (CPs) are a family of complex substances representing more than 200 commercial products. Use applications for chlorinated paraffins range from extreme pressure additives in lubricants, to secondary plasticizers in paints and plastics, to flame retardants in various plastics and textiles.
Chlorinated paraffins are produced through chlorination of straight-chain paraffin fractions which are typically subdivided into three categories based on their carbon chain lengths:
Short-chain C10-13 Mid-chain C14-17 Long-chain C18-30 The properties of the different chlorinated paraffins can vary significantly depending on their carbon chain length and degree of chlorination.
Mid-chain chlorinated paraffins (MCCPs) represent the largest production and use category in North America (approximately 45%); long-chain chlorinated paraffins (LCCPs) are second (approximately 33%); and short-chain chlorinated paraffins (SCCPs) account for the rest.
Chlorinated paraffins have been the subject of numerous health and environmental reviews. Regulatory attention was first focused on CPs in the United States in the mid-1970s when the US Environmental Protection Agency (EPA) undertook a comprehensive environmental and health review. Starting in the 1990's, Environment Canada began a similar review.
The North American producers of chlorinated paraffins have been working cooperatively to address the various health, environmental and regulatory issues under the auspices of the Chlorinated Paraffin Industry Association (CPIA). 1 (Additional information on CPIA can be found at www.regnet.com/cpia.) CPIA has also been cooperating with the European producers of CPs in addressing various initiatives by the European Union.
The following summarizes the current regulatory status of CPs and highlights that, when properly managed, CPs are safe for use consistent with health and environmental protection goals.
UNITED STATES
Based in part on the research and advocacy initiatives of CPIA, there are no restrictions in the US on the manufacture, processing or use of any chain length CP. The only regulatory requirement is a reporting obligation for SCCPs. Under the Toxic Release Inventory (TRI) regulations (40 CFR 372), any facility manufacturing or processing 25,000 pounds or more, or any facility using 10,000 pounds or more of SCCPs, is required to file with EPA an annual estimate of their environmental releases.It is significant to note that CPs are specifically exempt from the federal "hazardous" waste Resource Conservation and Recovery Act (RCRA) regulations. While the EPA regulations specify that waste oil containing more than 1,000 ppm halogens is presumed to be hazardous, showing that the source of the halogen is CPs is an effective way to "rebut" the presumption. There are, however, several states that require all waste oils to be managed as hazardous waste and the state of Washington has specifically designated waste oils containing CP as "hazardous" unless the used oil is being sent for rerefinement.
CANADA
There are presently no restrictions in Canada on the manufacture, processing or use of any chain length CP. Like the TRI reporting in the United States, reporting of certain CPs (alkanes, C6-18, chloro, CAS# 68920-70-7; alkanes, C10-13, chloro, CAS# 85535-84-8) is required in accordance with the National Pollutant Release Inventory (NPRI). Facilities in Canada that manufacture, process and otherwise use the specified CPs in an amount greater than 10 metric tons, are subject to this rule. Small facilities whose employees work less than 20,000 hours are exempted from this requirement.In 1993, Environment Canada classified SCCPs as "toxic" under the Canadian Environmental Protection Act based on animal carcinogenicity studies. There has been no follow-up action, since the concern identified was very limited. Environment Canada is continuing to investigate whether SCCPs should be listed as "toxic" to the environment given their acknowledged toxicity to aquatic life when discharged without proper management.
CPIA has advocated that Environment Canada initiate a Life Cycle Management Program (LCMP) as an effective response to its concerns over environmental release of SCCPs. CPIA has identified the ILMA/ORC Guide, "Management of the Metal Removal Fluid Environment" as a useful starting point for developing such a program. CPIA is soliciting metalworking fluid formulators and users interested in working on the development of a metalworking fluid LCMP. This effort is intended not only to achieve a positive outcome in Canada with respect to SCCPs, but also to support continued use of mid- and long-chain CPs throughout North America.
EUROPE
CPIA is closely monitoring, and as appropriate, responding to the European Union's risk assessment and risk management initiatives with regard to CPs. The European Union concluded that the release of SCCPs into the environment poses a risk to aquatic organisms and therefore has decided to impose "marketing and use restrictions" on the use of SCCPs in metalworking and leather finishing.The United Kingdom has begun to assess MCCPs, as part of the European Union's ongoing review of existing substances. That assessment is scheduled for completion in 2002. CPIA is actively working with the United Kingdom and the European producers to ensure no restrictions.
CPIA is also working directly with the United Kingdom to address LCCPs under the International Council of Chemical Associations (ICCA) High Production Volume (HPV) Initiative.
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COMPANY RESTRICTED LISTS
Beyond formal government oversight, some companies have their own initiatives to prohibit or restrict the use of certain compounds. CPIA actively monitors these initiatives and has successfully worked with different companies to ensure the continued use of CPs in North America. Metalworking fluid formulators are encouraged to contact CPIA if they become aware of any circumstances calling for restrictions on the use of CPs.Robert J. Fensterheim, Executive Director
Chlorinated Paraffins Industry Association
1250 Connecticut Avenue, NW, Suite 700
Washington, DC 20036
Phone: (202) 637-9040
Fax: (202) 637-9178
E-mail: bobf@regnet.com1CPIA represents the major North American manufacturers of chlorinated paraffins, which includes: Dover Chemical Corporation; Ferro Corporation, Petroleum Additives; and, Pioneer Americas, Inc.