Regulatory Updates – 2006CPIA 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 CPs in the United States, Canada, Europe and the United Nations. All previous updates are available below.UNITED STATESThere are no new regulatory developments in the United States regarding chlorinated paraffins. Several years ago, the US Environmental Protection Agency concluded that there was no need to impose any restrictions on the manufacture, processing or use of any chain length chlorinated paraffin. However, the environmental release of short-chain chlorinated paraffins (SCCPs) must be reported annually under the Toxic Release Inventory, as part of the broader “polychlorinated alkane” category. Chlorinated paraffins remain excluded from federal hazardous waste regulations. CPs in waste oils, however, must be managed as hazardous waste in the state of Washington.CANADAIn June of 2005, Environment Canada and Health Canada released for public comment updated assessments addressing SCCPs, medium-chain chlorinated paraffins (MCCPs) and long-chain chlorinated paraffins (LCCPs).The Chlorinated Paraffins Industry submitted an extensive set of comments, which raised numerous technical and policy concerns with the Reports. In its comments, the Chlorinated Paraffins Industry restated its recommendation that the Agency promote a Life Cycle Management Program to assure effective management of these substances. There has been no response yet from Canada. INTERNATIONALUNECEThe United Nations Economic Commission for Europe (UNECE) is reviewing whether SCCPs meet the criteria for Persistent Organic Pollutant (POP) under the Convention on Long-range Transboundary Air Pollution (LRTAP). The Chlorinated Paraffins Industry has strongly advocated the view that SCCPs did not qualify for inclusion given that there is no evidence to support the criteria that the compound is likely to present “significant adverse effects” (SAE). The Chlorinated Paraffins Industry has maintained that the SAE evaluation requires a determination that adverse effects are likely based on predicted levels in the environment and the expected environmental responses to those levels. While there continues to be debate over the interpretation of the SAE criteria, many of the UNECE counties are taking the view that the mere presence of the compound in remote regions is sufficient justification. The US government has expressed a view similar to the Chlorinated Paraffins Industry. However, the US position will likely not be considered given that the US is not currently a Party to LRTAP as the required legislation has not yet cleared Congress, and may not be passed before the Executive Body meeting. The next meeting of the UNECE Executive Body is December 11-15 at which time it is likely that SCCPs will be determined to meet the Track A POPs review. If SCCPs are deemed to meet the Track A review, the UNECE will begin the Track B review, which will consider the development of a management strategy. UNEP The United Nations Environment Program is also considering SCCPs under the Stockholm Convention. While the POPs criteria for Stockholm is very similar to UNECE’s, there appears to be greater scientific consideration given to the evaluation of “Significant Adverse Effects.” The UNEP Persistent Organic Review Committee (POPRC) is meeting the week of November 6 and may consider at that time whether SCCPs meet the initial screening criteria, which would trigger the development of a Risk Profile. The Chlorinated Paraffins Industry will issue an update on the latest developments, following completion of the UNEP meeting. Chlorinated Paraffins Users Group Early next year, the Chlorinated Paraffins Industry is planning to convene a Chlorinated Paraffins Users Group in order to gather information that can be used in addressing both the UNECE and the UNEP initiatives. Additional information on any of these or other issues regarding CPIA and chlorinated paraffins can be obtained by contacting your CP supplier or CPIA at info@regnet.com
Previously Issued Regulatory Updates
General UpdatesJanuary 2002 - An article entitled "Chlorinated Paraffins in the Twenty-First Century," by CPIA Executive Director, Bob Fensterheim appeared in Compoundings.CPIA Executive Director, Bob Fensterheim presented during the Independent Lubricant Manufacturers Association's (ILMA) Health and Safety Task Force Meeting, on September 30, 2001 in Las Vegas, Nevada. In September 2001, the NLGI Spokesman published a paper by Bob Fensterheim entitled, "Chlorinated Paraffins: An Overview of the Health, Environmental and Regulatory Status" that was presented at the National Lubricating Grease Institute (NLGI) 2000 Annual Meeting in Asheville, North Carolina.
Press Releases
Last Updated - October 24, 2006
|
||||