The United States Environmental Protection Agency (EPA) is currently conducting its risk assessment for chlorinated paraffins (CP), a complex group of manmade compounds, primarily used as coolants and lubricants in metal forming and cutting. According to Maria Doa, director of the EPA’s Chemical Control Division, who spoke at the 5th International Conference on Metal Removal Fluids organized by the Independent Lubricant Manufacturers’ Association (ILMA) in Rosemont, Ill., U.S.A., the EPA was planning to finish its assessment by May 2016. However, Doa said that the EPA will probably push this back roughly by one year.
As a result of an enforcement action by one of the two companies in the U.S. who produce chlorinated paraffins, the EPA banned the production and importation of short-chained chlorinated paraffins (SCCP), as they have been found to be persistent, bioaccumulative and toxic. It also responded to the companies’ pre-manufacture notices (PMNs) with a letter, giving the companies the option to cease production of medium- and long-chain chlorinated paraffins immediately, or enter into a consent order under the Toxic Substances Control Act (TSCA) Section 5(e), in which the companies would have to cease all manufacture of chlorinated paraffins by May 31, 2016. As mentioned earlier, this date could be pushed back by a year.
The EPA is also gathering critical use data on medium- and long-chained chlorinated paraffins. Critical use data, Doa said, is needed to answer the following questions about medium- and long-chained chlorinated paraffins: are they a less toxic substitute for something else? Do they have benefits in other uses? Are there substitutes, and do they work? The EPA is mainly trying to find out if users of chlorinated paraffins can explain why CPs are critical to their operation.
Doa said that the U.S. Department of Defense, which is a big user of CPs, asked these kinds of questions of their suppliers, and has not received very much specific information from their suppliers. It did, however, get a feel for how widespread the use of CP is. Doa also said that the EPA has heard from many users that they need more time to provide this information or to transition to non-CP products.
In any case, the window is closing for companies to submit their information. If they do not, the EPA could ban their production of medium- and long-chain chlorinated paraffins sooner. Doa clarified, however, that this ban does not apply to processing stocks that a company may already have on hand; it only applies to import and manufacture. She also said that the EPA is in the process of gathering more information on the use of very long chain chlorinated paraffins, which are not associated with the same environmental or health concerns as their shorter counterparts, as substitutes for the medium- and long-chain varieties. — By Alison Gaines