The 19 chemicals included C12-C24 chloroalkenes, which the Environmental Protection Agency said are used in metalworking fluids, along with both sulfated and oxidized forms of castor oil. Castor oil and its derivatives are used in the manufacturing of greases, lubricants and surfactants.
The ruling does impact some Independent Lubricant Manufacturers Association members, ILMA General Counsel Jeffrey Leiter said. Under the ruling, Tier 1 includes manufacturers and importers of the chemicals, and Tier 2A includes some manufacturers, such as those making smaller amounts of the chemical. Tier 2B covers processors.
Most of the members that use these chemicals would be defined as processors, or Tier 2B, and they would not need to do anything unless the companies in Tier 1 or 2A do not perform the testing, he said. However, there may be some ILMA members that import their supply, and they would fall within Tier 1. The companies in Tier 1 must file a letter of intent or request the exemption by Feb. 7. Were in the process of preparing a model letter for ILMA members to send to their suppliers, just asking them to confirm that they have responded appropriately to EPA. If their supplier files, the ILMA member wouldnt have to do anything. If they dont, it would fall on the processor to file.
EPA defines high production volume chemicals as those with a production or import volume equal to or greater than 1 million pounds per year. The rule falls under the under the Toxic Substances Control Act.
The chemical data reporting will provide EPA with critical information to better evaluate any potential risks from these chemicals that are being produced in large quantities in this country, said Steve Owens, assistant administrator for EPAs Office of Chemical Safety and Pollution Prevention.
The agency has also proposed testing for a third group of HPV chemicals, and said it plans to propose testing for additional chemicals as it learns more about the chemical substances.
In April 1998, EPA initiated a national effort to make certain basic information about the environmental fate and potential health and environmental hazards associated with the most widespread chemical substances in commerce available to the public.