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 UPDATE
Presented at ILMA's Annual Meeting
September 2001
CPIA prepares periodic updates to keep processors and users of chlorinated paraffins informed of the latest regulatory developments. All previous updates can be found on CPIA's web site at www.regnet.com/cpia. CPIA represents the major North American manufacturers of chlorinated paraffins which includes: Dover Chemical Corporation; Ferro Corporation, Petroleum Additives; and, Pioneer Americas, Inc. CPIA works closely with its European counterparts. UNITED STATES
No Restrictions on Manufacture, Processing or Use - There are no restrictions in the US on the manufacture, process or use of any chain length chlorinated paraffin. There are also no new regulatory developments anticipated.Chlorinated Paraffin Containing Wastes Are Not Classified as Hazardous Under RCRA - No new regulatory requirements have been issued at the federal level affecting the management and disposal of wastes containing chlorinated paraffins. These products continue to enjoy exempt status under the federal Resource Conservation and Recovery Act (RCRA) regulations. Also, CPIA is also not aware of any new requirements at the state level. CPIA is aware that at least one state (Washington) has designated waste oils containing chlorinated paraffins as "hazardous" unless the used oil is sent to be re-refined.
CPIA appreciates being notified of any state that is initiating any action that could adversely impact the processing, use and disposal of chlorinated paraffins. CPIA is also interested in working with companies that are faced with difficulties in disposing of waste containing chlorinated paraffins, which can occur if waste management companies are not adequately informed of the RCRA "rebuttable presumption" exemption provisions.
CANADA
No Restrictions on Manufacture, Processing and Use - There are no restrictions in Canada on the manufacture, process or use of any chain length chlorinated paraffin. In 1993, Environment Canada classified short-chain chlorinated paraffins (SCCPs; chlorinated paraffin products containing between 10 and 13 carbons) as "toxic" under the Canadian Environmental Protection Act. Environment Canada is also investigating whether SCCPs should be classified as "Track 1" and thereby subject to restrictions on environmental release.CPIA is continuing to advocate that Environment Canada initiate a Life Cycle Management Program (LCMP) as an effective response to their concerns over environmental release and to use the ILMA/ORC Guide, "Management of the Metal Removal Fluid Environment" as a useful starting point for developing such a program. CPIA is seeking metalworking fluid formulators and users interested in working on the development of a metalworking fluid LCMP.
EUROPE
CPIA is closely monitoring, and as appropriate, responding to the European Union's risk assessment and risk management initiatives with regards to chlorinated paraffins. Recent attention has been focused on mid-chain chlorinated paraffins (MCCPs) which are being reviewed by the European Union as part of its ongoing review of existing substances. The MCCP risk assessment is scheduled for completion in 2002. Also, CPIA is working directly with the United Kingdom in its review of environmental issues regarding long-chain chlorinated paraffins (LCCPs).CPIA volunteered to address LCCPs under the International Council of Chemical Association (ICCA) High Production Volume (HPV) Initiative. The United Kingdom is the lead country. Development of robust summaries on existing studies and conduct of additional testing is scheduled for mid-2002.
CPIA invites processors and users of MCCPs and LCCPs to work cooperatively with it on these efforts.
FORD MOTOR COMPANY
Several companies routinely prepare lists of substances that are prohibited or have restrictions on their use. CPIA is aware that the Ford Motor Company has included chlorinated paraffins on its "Restricted Substance Management Standard" largely due to restrictions imposed in Europe on the use of SCCPs, but more importantly, on general disposal limitations in Germany on fluids containing any chlorinated compound.Ford has notified CPIA that, while the Restricted Substance Management Standard states that chlorinated paraffins are restricted from use in metalworking fluids, chlorinated paraffin products already approved for use can continue to be used without restrictions. Additionally, Ford clarified that even without this deviation in North America, automotive parts brought into Ford can be manufactured with chlorinated paraffins "as long as these compounds are not incorporated into the product." According to Ford, there "is no restriction …that would preclude a supplier to Ford from using these materials in their manufacturing process."
Additional information on any of the issues discussed in this Regulatory Update or other issues regarding CPIA and chlorinated paraffins can be obtained by contacting your CP supplier or CPIA:
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.com