In September 2009, the U.S. EPA put in place an action plan for short-chain and other chlorinated paraffins, Canter said. EPA was concerned that certain chlorinated paraffins were not on the Toxic Substances Control Act (TSCA) Inventory, regardless of chain length.

In the United States, CPs are classed by carbon chain length and by degree of chlorination, and are sorted into short-chain (C10 to C13), intermediate-chain (C14-C17), and long-chain products (C18-C30). After the National Toxicology Program designated short-chain CPs as carcinogenic in 1989, many fluid formulators switched to mid- and long-chain products or dropped short-chain entirely.

The U.S. Environmental Protection Agency now is scrutinizing mid-chain CPs for their persistence in the environment and potential bioaccumulation in humans and wildlife. It has estimated that 150 million pounds of CP (all types) are used yearly in the United States, although others say it’s not even half that any more.

The TSCA inventory was created in 1975, and certain products were grandfathered in with specific Chemical Abstracts Service numbers as approved by EPA. A CAS number is a unique numeric identifier that serves as a link to detailed information about a specific chemical substance. However, Canter said, EPA then claimed discrepancies between actual chlorinated paraffins produced and imported into the U.S. and those listed on the TSCA Inventory.

As a result, EPA requested that suppliers of chlorinated paraffins in the U.S. file Pre-Manufacturing Notifications (PMNs), meaning their products were no longer on the Inventory and they had to go through the process of putting them back on. EPAs problem was that the descriptions of products currently on the Inventory were not specific enough, Canter said.

Also in 2012, the two largest producers of chlorinated paraffins were fined by the EPA for selling short-, medium- and long-chain products without first submitting PMNs at least 90 days before manufacture. As part of a resolution to the issue, both companies agreed to stop selling short-chain materials. And both were asked to submit PMNs for medium- and long-chain products as part of the settlement. But most importantly, the companies were allowed to continue shipping these products to their customers, Canter noted.

As Lube Report reported previously, Dover Chemical and Ineos Chlor Americas each settled CP violations with the EPA in 2012.

At the same time, Canada under the Domestic Substances List (DSL) laid out more specific descriptions for chlorinated paraffins. And CAS numbers on the DSL are not on the TSCA Inventory. In 2102, Canter noted, I said that EPA wanted to go to Canadian style CAS numbers. But now, EPA does not want to use these types of CAS numbers and wants to assign totally new numbers.

In January 2013, Environment Canada prohibited the use of short-chain (C10 to C13) chlorinated paraffins. The agency determined that they posed a long-term threat to the environment and aquatic life. Now, Environment Canada is concerned about how to regulate C14 to C20 products.

EPA has now established a new category, very long-chain chlorinated paraffins, in addition to short-, medium-, and long-chain, Canter explained. Short- and medium-chain remain the same (C10 to C13 and C14 to C17). Long-chain is now C18 to C20, and very long-chain is C21 to C30+.

Finally, a third company has submitted PMNs, seeking permission to sell medium-, long- and very long-chain chlorinated paraffins in the U.S. PMNs for three very long-chain products have cleared. And new CAS numbers have been issued for chain lengths above C21. Canter said, These materials are more viscous than currently used medium- and long-chain products and there will be challenges in formulating with them.

Lube Report reported in June that Qualice LLC launched operations in North Carolina in April to manufacture chlorinated paraffins in the United States.

In conclusion, Canter said, EPA has cleared very-long chain chlorinated paraffins and chlorinated olefins for manufacture in the U.S., and it is still figuring out what to do with medium- and long-chain chlorinated materials. My supposition is we will eventually have an answer.