ILMA Compoundings August 2016 - 34

RULES & REGS

EPA Review of MCCPs
and LCCPs
Andrew Jaques

T

he U.S. Environmental Protection Agency (EPA) has
been reviewing chlorinated paraffins (CPs) since the
1970s. CPs are industrial chemicals used in metalworking,
polymer formulations and specialty coatings. They impart
important chemical characteristics such as flame retardancy
and extreme-pressure lubricity that are not easily substituted in
many cases.
As discussed in my many previous articles in Compoundings
over the years, the EPA took actions starting in
2009 that resulted in all current CP chemicals
going through the premanufacture
notification (PMN) process for new
chemicals. This includes mediumchain CPs (MCCPs), C14-17;
long-chain CPs (LCCPs), C1820; and very long-chain CPs
(vLCCPs), C21+. While these
PMN reviews were agreed to
by two CP manufacturers as
part of consent orders, there
is growing concern among
the processors and users of
CP products that this process
is inappropriate because most
of these are substances have been
in active commerce for many years
and because the PMN process does not
have a mechanism to consider the impacts
to CP processors and users and other affected
stakeholders.
Over a dozen PMNs were submitted to the EPA for CPs
between 2012 and 2014 by three separate companies. The EPA
completed its review on three vLCCP PMNs and approved
them subject to additional environmental fate testing
(described in a February 2016 SNUR (40 CFR 721.10673-75)). All
of the other CP PMNs remain under EPA review.

In January 2015, the EPA sent letters to the PMN submitters
for MCCPs and LCCPs indicating that, based on concerns for
risks to the environment in the agency's draft risk assessments,
the EPA was considering Toxic Substances Control Act (TSCA)
Section 5(e) consent orders that would cease the manufacture
or import of those MCCPs and LCCPs after May 31, 2016. The
PMN submitters did not agree to accept such consent orders,
noting their concerns with the draft risk assessments and
effects on downstream processors and end users relying
upon these chemicals.
Throughout 2015, the EPA received
input from these stakeholders and
their trade associations, including
ILMA and several organizations
representing metal parts
manufacturers. As a result
of this input, the EPA asked
for public comment on the
draft risk assessments of
MCCPs and LCCPs, and that
comment period closed
on March 23, 2016. The EPA
received numerous detailed
comments on the MCCP and
LCCP risk assessments and is now
in the process of reviewing these
comments and potentially revising the
risk assessments.
In September and October 2015, the EPA indicated
during two public presentations - including a presentation
by Maria Doa at the 5th International Conference on Metal
Removal Fluids - that it was now considering the issuance
of consent orders that would require a phaseout of the
manufacture and import of these chemicals by mid-2017.
Recent correspondence from an automotive manufacturer to
its suppliers has mentioned this mid-2017 date as a reason to

Vol. 66 No. 8 * 34 * August 2016 Compoundings
ILMA Compoundings August 2016

Table of Contents for the Digital Edition of ILMA Compoundings August 2016
