Regulations Specs & Testing

EPA Yields Little on Chlorinated Paraffins


More than 250 business and technology leaders recently convened in Chicago for the 5th International Conference on Metal Removal Fluids, sponsored by the Independent Lubricant Manufacturers Association. Attendees packed the main conference room on Sept. 29 for the keynote presentation by Maria J. Doa, Ph.D., director of the Chemical Control Division of the U.S. Environmental Protection Agency.
Those present heard two critical messages: First, EPA has postponed the date when mid- and long-chain chlorinated paraffins will be prohibited from U.S. production and import. Originally slated for May 2016, the ban is being delayed until mid-2017, Doa revealed. Second, although numerous manufacturers and end users have argued that alternatives are lacking and they need more time to adjust to life without chlorinated paraffins, EPA is focused on pursuing its present course.
Doas presentation, Chlorinated Paraffins Risk Assessment, provided a much-anticipated update on EPA activities regarding these chemicals. She announced that the agency was close to completing its risk assessment of specific Premanufacture Notices for certain CPs. This risk assessment may have several profound implications for the lubricant industry and its customers. The most urgent implication is that the EPA is expected to announce that certain CPs currently used in metalworking fluid formulations may no longer be manufactured or imported into the U.S. This relatively narrow regulatory action by the EPA may foreshadow broader bans of CPs in the future.
CPs are linear hydrocarbons that are partially chlorinated. They are classified as short chain (C10-C13), medium chain (C14-C17), long chain (C18-C20) and very long chain (C21-C30+). Known respectively as SCCPs, MCCPs, LCCPs and VLCCPs, these classes share the same chemistry but differ significantly in viscosity, solubility and other physical properties. The numbers assigned to them by the Chemical Abstracts Service correspond to broadly defined chemical compositions, i.e., blends of CPs.
In the past, a number of chlorinated paraffins received CAS numbers and were commercialized for use in metalworking fluids and other applications. Since the 1930s, CPs have been go-to extreme-pressure additives for metalworking fluids used for machining titanium alloys, stainless steels and other metals, because they protect surfaces of tools and parts from friction, wear and overheating at high operating speeds and intense pressures. They are used in high-performance metal drawing, forming and removal operations, and for manufacturing critical components ranging from aviation fasteners and missile components to hypodermic needles, heart stents and surgical staples.
Doa explained that the EPA initially raised concerns about CPs in its December 2009 Action Plan on Short-Chained Chlorinated Paraffins. Short-chain CPs, that plan said, are found worldwide in the environment, wildlife and humans. They are bioaccumulative in wildlife and humans, are persistent and transported globally in the environment, and toxic to aquatic organisms at low concentrations. Based on these factors, as well as the availability of viable substitutes for certain uses of SCCPs, EPA intends to initiate action to address the manufacturing, processing, distribution in commerce, and use of SCCPs.
EPA intends to further evaluate whether the manufacturing, processing, distribution in commerce and/or use of medium chained chlorinated paraffins (MCCPs) and long-chained chlorinated paraffins (LCCPs) should also be addressed, the 2009 plan indicated.
In Chicago, Doa noted that the EPA identified MCCPs and LCCPs for investigation based on their potential for persistence, bioaccumulation and toxicity in the environment. The agencys concern is heightened by the dispersive nature of many end-use applications that lead to transfer and accumulation of CPs in water, soil, plants, fish and humans at sites distant from their release.
According to Doa, the EPA is reviewing Premanufacture Notices for certain MCCPs and LCCPs that are currently available in the U.S. The two largest suppliers of CPs to the United States, Dover Chemical Corp., in Dover, Ohio, and Ineos Chlor Americas (part of the U.K.-based Ineos), filed specific PMNs and agreed to discontinue production of SCCPs in 2012; that agreement came in the context of legal settlements negotiated with the Department of Justice and the EPA.
Additionally, Hamlet, N.C.-based Qualice LLC, a subsidiary of Trinity Manufacturing, in 2013 filed PMNs for approval to make mid-, long- and very-long-chain CPs, prior to commercialization.
Doa explained that the EPA has been reviewing the companies PMNs according to Section 5 of the Toxic Substances Control Act, which sets policy for chemicals with persistent, bioaccumulative and toxic potential. This review includes assessment of human health and environmental toxicity, exposure and risk. She revealed that EPA risk analysis has been focusing on four concerns for CPs:
1. Persistent to very persistent;
2. Bioaccumulative to very bioaccumulative;
3. Toxic to aquatic organisms at low levels;
4. Additional risk to aquatic organisms.
Doa did not present any data, specific findings or explanations of these concerns. The EPA can ban commercialization of very persistent and very bioaccumulative chemicals until certain testing is completed, or can allow commercialization of persistent and bioaccumulative chemicals with testing required to be completed once certain production levels are reached.
As she explained, the EPA bases its decisions on Premanufacture Notices on risk analysis, which balances the probability that harm will occur and the magnitude and severity of that harm against the expected benefits of the chemical substance.
In January 2015, the EPA rejected the PMNs for mid- and long-chain CPs that had been submitted by Qualice, Dover and Ineos. It sent letters to the companies advising that these chain lengths could not be manufactured or imported into the U.S. after May 31, 2016. However, the EPA accepted three of Qualices applications to manufacture very-long-chain chlorinated paraffins and chlorinated olefins.
While conference attendees asked many questions about the EPAs review process of the Premanufacture Notices for CPs, Doa declined to provide experimental or environmental data, results from computer models, or other evidence used by the EPA in its evaluation. She admitted that risk assessments and results are not available to the public and do not undergo peer review.
Doa outlined two potential processes for modifying the original May 31, 2016, deadline for the phase-out of MCCPs and LCCPs.
First, the EPA could modify its decision to allow specific critical uses of these MCCPs and LCCPs. In 2004 for example, the EPA proposed critical use exemptions for methyl bromide for circumstances where there are no technically and economically feasible alternatives. In this case, however, Doa noted that the agency had requested information about critical uses of mid- and long-chain CPs but received inadequate information to pursue this option.
Second, the EPA could consider allowing a period of time for industry to transition to another material or reformulate a product. Doa then disclosed that the EPA was aiming to extend the deadline to an unspecified date in mid-2017.
Since September, ILMA has responded to EPAs efforts by meeting with a broad swath of industries that have a stake in keeping CPs available. The trade association has enlisted the support of the American Coatings Association, the American Chemistry Council, the Motor and Equipment Manufacturers Association, the Auto Alliance, Global Automakers, American Wire Producers Association, Industrial Fasteners Institute, Chlorinated Paraffins Industry Association, the Vinyl Institute, National Association of Manufacturers, the Center for the Polyurethane Industry, the Adhesives and Sealants Council and the Aerospace Industries Association.
This coalition of organizations is continuing to meet with the EPA, the Small Business Association, the Department of Commerce and other government entities, and developing strategies to seek a more favorable outcome regarding production and import of MCCPs and LCCPs.
Regardless of the possible outcome of this consortiums efforts, it seems very likely that short-chain CPs will be banned. IARC, the International Agency for Research on Cancer, has categorized SCCPs as Group 2B, possibly carcinogenic to humans, while the United Nations is considering a global ban in them under the Stockholm Convention on Persistent Organic Pollutants, or POPs. POPs are defined as chemical substances that persist in the environment, bio-accumulate through the food web, and pose a risk of causing adverse effects to human health and the environment.
A worldwide ban on SCCPs may not have much impact on U.S. metalworking fluid formulators, who largely moved away from these chain lengths in the 1990s. The long-term outlook for MCCPs and LCCPs, however, may well depend upon continued research, and whether ILMA and its allies can persuade EPA to modify its current stance.
Meanwhile, others at the Chicago conference suggested that lubricant blenders and metalworking fluid formulators would be well-advised to diversify their extreme-pressure additive options, especially wherever halogenated chemistries are involved.
Mary Moon, Ph.D., is a physical chemist with hands-on R&D and management experience in the lubricating oil and grease industry. Contact her at or (267) 567-7234.