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 REGULATORY UPDATE
October 2003
The Chlorinated Paraffins Industry Association (CPIA) periodically prepares updates to inform processors and users of chlorinated paraffins of the latest regulatory developments. The following is an update on developments in the United States, Canada, Europe and the United Nations. All previous updates are available on the CPIA website at www.regnet.com/cpia.
There have been no new regulatory developments in the United States (US). 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 (CP). UNITED STATES
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.
In 1993, Environment Canada classified SCCPs as "toxic" under the Canadian Environmental Protection Act (CEPA). MCCPs and LCCPs have not been classified as toxic under CEPA. CANADA
Environment Canada is currently assessing the data gathered as a result of its November 2002 Reporting Rule for chlorinated paraffins. That rule required all Canadian companies that manufactured, imported, exported, distributed or sold chlorinated paraffins, or products formulated with chlorinated paraffins in 2000 and/or 2001, to report information by February 2003.
Short-chain Chlorinated Paraffins EUROPEAN UNION
The June 2002 Marketing and Use Directive relating to SCCPs came into force in January 2003 to address concerns relating to environmental release. Under the amended Marketing and Use Directive (76/679/EEC), SCCPs may not be marketed or used in concentrations greater than 1% for metalworking and leather finishing. EU member countries are required to adopt regulations to comply with the EU Directive by January 2004. Other uses such as paints, coatings and flame retardants are not affected.
Mid-chain Chlorinated Paraffins
A draft EU risk assessment for mid-chain chlorinated paraffins (MCCPs), prepared by the United Kingdom (UK), was posted on the European Chemical Bureau website in August of 2002. The draft assessment included a provisional recommendation that MCCPs be classified as dangerous for the environment because of concerns relating to toxicity to aquatic organisms. The CEFIC Chlorinated Paraffins Sector Group, which represents the European producers of chlorinated paraffins, is working with the UK and participating in the relevant EU Technical Meetings to promote a reasonable assessment. Additional testing of MCCPs is underway to provide necessary clarification of effects.
Long-chain Chlorinated Paraffins
Long-chain chlorinated paraffins (LCCPs) are not included on the EU priority list. The UK, however, issued a draft national environmental risk assessment for LCCPs in November 2002. The risk assessment concluded that the risk to surface water, waste water and the atmosphere from LCCPs with chain lengths greater than C20 (those typically manufactured in the US) was low.
CPIA has volunteered to work with the UK on LCCPs under the International Council of Chemical Associations (ICCA) High Production Volume (HPV) Initiative.
United Nations Economic Commission for Europe Protocol on Long Range Transboundary Atmospheric Transport UNITED NATIONS
Canada has been promoting SCCPs for consideration under the United Nations Economic Commission for Europe (UNECE) "Protocol on Long Range Transboundary Atmospheric Transport of Persistent Organic Pollutants." CPIA continues to actively contest the data provided by Canada in its Dossier.
UNEP
The United Nations Environment Program (UNEP) has been addressing twelve Persistent Organic Pollutants (POPs) under the "Stockholm Convention." Over the past year, UNEP prepared Regional and Global reports on various Persistent Toxic Substances (PTS) to assist in its research and prioritization of activities. Initially, all CPs were included in the assessment; as a result of the intervention of CPIA and the European CP industry, the Global report now focuses just on an assessment of SCCPs.
For additional information contact:
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
www.regnet.com/cpia