C H L O R I N A T E D    P A R A F F I N S
I N D U S T R Y    A S S O C I A T I O N

1250 Connecticut Avenue, N.W. | Suite 700 | Washington, D.C. 20036 | 202-637-9040 | Fax: 202-637-9178

CHLORINATED PARAFFINS

REGULATORY UPDATE

April 2001

CPIA prepares regulatory updates to keep processors and users of chlorinated paraffins informed of the latest regulatory developments. The following is an update regarding the recent regulatory developments pertaining to chlorinated paraffins. All previous updates can be found on CPIA's web site at www.regnet.com/cpia.

United States

There are no restrictions on the manufacture, process or use of any chain length chlorinated paraffin in the US. There are also no new regulatory developments anticipated.

There have also been no changes to the management of wastes containing chlorinated paraffins at the federal level and these products continue to enjoy exempt status under the federal Resource Conservation and Recovery Act regulations. CPIA has been reviewing a hazardous waste regulation issued last year by the State of Washington which does require hazardous waste treatment for metalworking fluids containing chlorinated paraffins. CPIA is interested in identifying facilities that may be adversely affected by the State of Washington regulation.

Canada

CPIA is continuing to advocate that Environment Canada initiate a Life Cycle Management Program as an effective response to their 1993 classification of short-chain chlorinated paraffins (SCCPs) as being "CEPA toxic" and to address Environment Canada's continued investigation of SCCPs as a "Track 1" substance. CPIA notified Environment Canada that the ILMA/ORC Guide, "Management of the Metal Removal Fluid Environment" can serve as a useful guide for developing a Life Cycle Management Program (LCMP). To date, Environment Canada's official position is that there is insufficient scientific information to declare SCCPs as a Track 1 substance.

CPIA is seeking metalworking fluid formulators and users interested in working on the development of an LCMP in Canada.

European Union

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 the EU review of mid-chain chlorinated paraffins. Also, CPIA is working directly with the United Kingdom in their review of environmental issues regarding long-chain chlorinated paraffins. No new developments in these areas are expected any time soon.

Ford Motor Company

Several companies routinely prepare lists of restricted substances. CPIA had been concerned about the inclusion of chlorinated paraffins on Ford Motor Company's "Restricted Substance Management Standard." CPIA learned that the primary rationale for including chlorinated paraffins pertained to restrictions on the use of SCCPs in Europe, but more importantly, on general disposal limitations in Germany on fluids containing any chlorinated compound.

CPIA contacted Ford to seek clarification on the application of the Restricted Substance Management Standard to the use of chlorinated paraffins in the United States. In late March, Ford notified CPIA that, while the Restricted Substance Management Standard prohibits the use of chlorinated paraffins in metalworking fluids, "Ford in North America is being allowed to continue the current usage of these materials under a deviation to this standard."

Ford also clarified that even without a deviation, manufactured parts brought into Ford Motor Company can be manufactured with chlorinated paraffins "as long as these compounds are not incorporated into the product." According to Ford, there "is no restriction from Ford Motor Company…that would preclude a supplier to Ford from using these materials in their manufacturing process."

Contact CPIA directly for additional information on this and any other related issue.

Mr. 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