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

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

FROM THE CEO
FROM THE PRESIDENT
BOARD BRIEF
NOTES FROM NLGI
THE HEART OF ILMA
In Memoriam Mike Ryterski (1920–2016)
Radco Industries Promotes Brian Finch
Manufacturing Day is Coming! October 7, 2016
THE EVOLUTION OF GROUP II
VOICES & VIEWS
INTERNATIONAL INSIGHT
FOCUS ON ETHICS
FAMILY BUSINESS
RULES & REGS
POWER PLAY
LEGAL EASE Preparing for Brexit
THE WHITE PAPER

ILMA Compoundings August 2016

https://www.nxtbook.com/ygsreprints/ILMA/G119XXX_ILMA_vol70_no6
https://www.nxtbook.com/ygsreprints/ILMA/G118112_ILMA_vol70_no5
https://www.nxtbook.com/ygsreprints/ILMA/G117382_ILMA_vol70_no4
https://www.nxtbook.com/ygsreprints/ILMA/G116888_ILMA_vol70_no3
https://www.nxtbook.com/ygsreprints/ILMA/G115555_ILMA_vol70_no2
https://www.nxtbook.com/ygsreprints/ILMA/G114774_ILMA_vol70_no1
https://www.nxtbook.com/ygsreprints/ILMA/g110500_ILMA_vol69_no12
https://www.nxtbook.com/ygsreprints/ILMA/g110500_ILMA_vol69_no11
https://www.nxtbook.com/ygsreprints/ILMA/g110500_ILMA_vol69_no10
https://www.nxtbook.com/ygsreprints/ILMA/g109884_ILMA_vol69_no9
https://www.nxtbook.com/ygsreprints/ILMA/g109284_ILMA_vol69_no8
https://www.nxtbook.com/ygsreprints/ILMA/g108494_ILMA_vol69_no7
https://www.nxtbook.com/ygsreprints/ILMA/g107507_ILMA_vol69_no6
https://www.nxtbook.com/ygsreprints/ILMA/g106483_ILMA_vol69_no5
https://www.nxtbook.com/ygsreprints/ILMA/g105803_ILMA_vol69_no4
https://www.nxtbook.com/ygsreprints/ILMA/g104743_ILMA_vol69_no3
https://www.nxtbook.com/ygsreprints/ILMA/g103647_ILMA_vol69_no2
https://www.nxtbook.com/ygsreprints/ILMA/g102869_ILMA_vol69_no1
https://www.nxtbook.com/ygsreprints/ILMA/g101930_ILMA_vol68_no12
https://www.nxtbook.com/ygsreprints/ILMA/g100836_ILMA_vol68_no11
https://www.nxtbook.com/ygsreprints/ILMA/g99200_ILMA_vol68_no10
https://www.nxtbook.com/ygsreprints/ILMA/g98468_ILMA_vol68_no9
https://www.nxtbook.com/ygsreprints/ILMA/g97711_ILMA_vol68_no8
https://www.nxtbook.com/ygsreprints/ILMA/G96767ILMA_vol68_no7
https://www.nxtbook.com/ygsreprints/ILMA/G95397ILMA_vol65_no6
https://www.nxtbook.com/ygsreprints/ILMA/G94323ILMA_vol68_no5
https://www.nxtbook.com/ygsreprints/ILMA/G93127_ILMA_vol69_no4
https://www.nxtbook.com/ygsreprints/ILMA/G91785_ILMA_vol68_no3
https://www.nxtbook.com/ygsreprints/ILMA/G90956_ILMA_vol68_no2
https://www.nxtbook.com/ygsreprints/ILMA/G89146_ILMA_vol68_no1
https://www.nxtbook.com/ygsreprints/ILMA/G87981_ILMA_vol67_no12
https://www.nxtbook.com/ygsreprints/ILMA/G85409_ILMA_vol67_no11
https://www.nxtbook.com/ygsreprints/ILMA/G83595_ILMA_vol67_no10
https://www.nxtbook.com/ygsreprints/ILMA/G81672_ILMA_vol67_no9
https://www.nxtbook.com/ygsreprints/ILMA/G80238_ILMA_vol7_no8
https://www.nxtbook.com/ygsreprints/ILMA/G79388_ILMA_vol7_no7
https://www.nxtbook.com/ygsreprints/ILMA/G78361_ILMA_vol7_no6
https://www.nxtbook.com/ygsreprints/ILMA/G77448_ILMA_vol7_no5
https://www.nxtbook.com/ygsreprints/ILMA/G75899_ILMA_vol67_no4
https://www.nxtbook.com/ygsreprints/ILMA/G75036_ILMA_vol67_no3
https://www.nxtbook.com/ygsreprints/ILMA/G72720_ILMA_vol67_no2
https://www.nxtbook.com/ygsreprints/ILMA/G72220_ILMA_vol67_no1
https://www.nxtbook.com/ygsreprints/ILMA/G70970_ILMA_vol66_no12
https://www.nxtbook.com/ygsreprints/ILMA/G69813_ILMA_vol66_no11
https://www.nxtbook.com/ygsreprints/ILMA/G67522_ILMA_vol66_no10
https://www.nxtbook.com/ygsreprints/ILMA/G66343_ILMA_vol66_no9
https://www.nxtbook.com/ygsreprints/ILMA/G64859_ILMA_vol66_no8
https://www.nxtbookmedia.com