The report, written by EPA Office of Pollution Prevention and Toxics Chemical Control Division director Maria J. Doa, summarizes recent and ongoing EPA activities with respect to specific medium- and long-chain chlorinated paraffins. It emphasizes EPA’s preliminary risk assessment of CPs and opened a 61-day window of opportunity for interested parties to respond by submitting comments and more data for EPA’s ongoing assessment. Instructions for submitting this information to the public docket through Feb. 22 are contained in the report.

The following materials are available for download at no cost:

Doa’s summary report is available on the Federal Register website.

The docket of EPA reports and technical strategy is available from the Federal Regulations website.

Chlorinated paraffins are chlorinated alkanes that have carbon chain lengths ranging from 10 to 38, with varying degrees of chlorination. Those with lengths from C14 to C17 are classed as medium chain; from C18 to C20 as long chain. CPs are used in metalworking fluids as extreme-pressure agents, especially for difficult drawing, forming and removal operations. Metalworking fluids thus fortified are often used to machine titanium alloys, stainless steels and other metals, because they protect tools and components from friction, wear and overheating at high speeds and intense pressures.

According to the EPA report, based on its preliminary risk assessment, the agency expects specific medium- and long-chain chlorinated paraffins to be persistent, bioaccumulative and toxic to aquatic organisms. The risk assessment rests upon data concerning chemical properties and behavior of chlorinated paraffins, and information about release of CPs, their presence in chemical waste, and their accumulation in sediments and surface waters.

EPA activities focus on specific blends of chlorinated hydrocarbons (paraffins and alpha-olefins) defined in Pre-Manufacturing Notices, or PMNs, from three chemical companies: Dover, Ohio-based Dover Chemical Corp., Inovyn Americas (part of Inovyn, a Brussels-based joint venture between Ineos and Solvay), and Qualice, a subsidiary of Hamlet, N.C.-based Trinity Manufacturing. In its initial assessment of data contained in these PMNs, EPA determined that the corresponding medium- and long-chain chlorinated paraffins may present an unreasonable risk to the environment.

In addition to being persistent, bioaccumulative and toxic to aquatic organisms, EPA expects that release of these chemicals may exceed concentrations of concern to aquatic and sediment-dwelling organisms. The agency relied on sediment core studies and environmental fate studies for medium-chain CPs and projected outcomes for long-chain CPs to assess persistence; bioconcentration data to evaluate bioaccumulation; and toxicity data for aquatic organisms.

It also referenced assessments performed by Canada and the European Union. EPA evaluated test results from those organizations, and presumed that CPs were released during processing and all intended uses in the U.S. In particular, the EPA was concerned about the presence of CPs in biosolids (organic matter recycled from sewage and applied to soil used for agriculture), release and spread of CPs in the air, and build-up of CPs in sediments and surface waters.

Based on this preliminary risk assessment, EPA believes that production of these CPs presents unacceptable risk, and said it expects to reject the PMNs and ban the manufacture and import of medium- and long-chain chlorinated paraffins in mid-2017. However, Doa’s report explains that EPA realizes “its assessment of some uses may be improved by more specific information” on the substances described in the PMNs.

Doa noted that the Independent Lubricant Manufacturers Association has already submitted some information, and said EPA would like to receive further information from other sectors that formulate and use CPs as flame retardants and plasticizers, in products such as sealants, adhesives and coatings.

ILMA has been actively involved in a coalition of trade associations that have an interest in the continued availability of CPs. The coalition includes the American Chemistry Council, National Association of Manufacturers and the Vinyl Institute, as well as niche organizations such as the Chlorinated Paraffins Industry Association, the Adhesives and Sealants Council and the Aerospace Industries Association.

The coalition has been pressing for an independent peer review of EPAs risk assessment, and also has suggested that appropriate risk management measures can be adopted that would make an outright ban of MCCPs and LCCPs unnecessary.

The notice in the Dec. 23 Federal Register did not address the possibility of critical use exemptions for medium- and long-chain chlorinated paraffins for metalworking fluid applications where there are no technically and economically feasible alternatives for these critical extreme pressure additives.