Short Chain Chlorinated Paraffins

Track B Review for the UNECE LRTAP Task Force on

Persistent Organic Pollutants – Final Report

May 2006

Reviewed by:

Suzanne Easton

Environment Canada

Timothy Lehman

US Environmental Protection Agency

André Peeters Weem

InfoMil, The Netherlands


SUMMARY

Short chain chlorinated paraffins (SCCPs) are synthetic compounds (n-paraffins having a carbon length between 10 and 13 carbon atoms and a degree of chlorination of more than 48% by weight) that are mainly used in metal working fluids, sealants, as flame retardants in rubbers and textiles, in leather processing and in paints and coatings. Due to risks caused by the substance to the health and environment the marketing and use of these substances has been restricted in the European Union.

The European Commission prepared a dossier dated August 2005 to nominate SCCPs to the UNECE LRTAP Protocol on Persistent Organic Pollutants. The information in this dossier provides a starting point for gathering information necessary to determine possible risk management actions that could be taken. The information provided seems to be accurate, though supplementary information is needed in many of the areas necessary to conduct a complete socio-economic evaluation of various risk management actions.

Overall, supplementary information in the following areas would be needed in order to identify appropriate risk management options for SCCPs and to assess which option(s) would be most appropriate at an international level:

·  global information on production, use and emission scenarios for SCCPs;

·  environmental release measurements (as opposed to estimates);

·  analysis of the efficiency and cost of various alternatives; and

·  cost and technical feasibility of control measures/techniques.

Introduction

SCCPs have been proposed by the European Commission for consideration under the United Nations Economic Commission for Europe (UNECE) Convention for Long-range Transboundary Air Pollution (LRTAP) Persistent Organic Pollutant (POPs) Protocol. The purpose of this Track B review is to present a technical review of the information about release to the environment and socio-economic factors provided in the dossier. Such information will be relevant to developing a strategy for managing risks from SCCPs, if it is decided to pursue such action. This review has been conducted in conformance with Executive Body Decision 1998/2 (EB 1998/2) and subsequent guidance to reviewers prepared under the auspices of the Task Force on Persistent Organic Pollutants.

Information from all reviewers has been utilized in the preparation of this review. It follows the format suggested in February 20, 2006 guidance provided to reviewers by the co-chairs of the UNECE LRTAP Convention Task Force on Persistent Organic Pollutants.

EXTENT OF RELEASE TO THE ENVIRONMENT

Production

The dossier provides little detail on global production quantities of SCCPs. It is noted that two manufacturers located in the European Union (EU) produced less than 15,000 tons per year of SCCPs in 1994, with more recent data from the EU withheld for confidentiality reasons. In order to conduct a comprehensive analysis of costs and benefits of various management options for SCCPs, recent data on production volumes in the EU would need to be made available. At a minimum, it would be useful to indicate whether production had significantly decreased, increased or remained constant. Without this information, a full quantitative assessment would not be possible.

For comparison with EU data, the dossier provides a production volume for China in 1997 of 100,000 tones per year of chlorinated paraffins (including all chain lengths). Using this value does not provide a comprehensive comparison of production as the value presented for China includes short-, medium- and long chain chlorinated paraffins, while that of the EU solely includes SCCPs. In order to present a more useful comparison, an SCCP estimate for China would need to be drawn out of the value provided. Alternatively, MCCP and LCCP estimates for the EU could be presented, if available.

Recognizing that the dossier focuses on impacts within the EU, it is important to understand that any management decision within the EU will have implications on global markets. For this reason, it would be relevant to gather any available production data for other regions of the world where there is potential for substantial production, particularly other parts of Asia and Latin America. In the event that data are not available, a discussion of the likelihood of production in other regions of the world would be pertinent.

The data provided from the questionnaire that was sent to all UNECE countries is not clear. A production estimate of 20,000 metric tons per year is given in what appears to be an aggregated total for the Czech Republic, the UK and the US. Data should be analyzed by country and not combined, if possible.

More specific information on global trade of SCCPs should be gathered. It would be important to identify trends in the amount of export of SCCP from the EU manufacturers to other parts of the world in recent years. As the use of SCCP has been rapidly decreasing in the EU, and recent production data for the EU are not available, it would be relevant to explore whether the exportation of EU manufactured SCCPs is increasing to identify if SCCPs are being fed into global markets where less focus has been given on the reduction in use of the chemical. Any data on exports would be useful to obtain.

USE

Table 1 (Use of SCCPs in Europe) provides the use distribution (by application) of SCCPs within the Europe Union in 1998. The paragraph preceding this table describes a use reduction that occurred between the 1994 and 1998. To provide better context for the discussion in the text, it would be useful to compare consumption data for 1994 with that provided for 1998.

It would be useful to gather quantitative information on consumption in countries other than the EU and US in order to understand SCCP trends in the global market.

EMISSIONS AND PATHWAYS TO THE ENVIRONMENT

The dossier provided a fairly comprehensive description of emissions and pathways of SCCPs to the environment.

It is noted in the dossier that SCCPs are expected to be degraded by incineration at low temperatures because of their low thermal instability, however, data supporting this statement is not provided. In Europe, a large portion of products containing SCCPs (painted material, plastics, leather) will incinerated at the end of their product life. For this reason, it is important to be further study the efficiency of SCCP destruction in waste incinerators. Emissions data for chlorinated hydrocarbons can be measured at many waste incinerators in the north western part of Europe. This data could provide more insight as to SCCP emission levels resulting from the incineration of products after use.

SOCIO-ECONOMIC FACTORS

NATIONAL AND INTERNATIONAL REGULATIONS

United States:

The discussion on the regulation of SCCPs in the United States does not adequately reflect the historical review of the chemical. The following discussion provides a description of the review of SCCPs in the United States:

The US Environmental Protection Agency review of CPs was done in a two step process. In 1991, the EPA published a RM1 screening level risk assessment, designed to determine whether chemicals present an unreasonable risk to human health or the environment. The findings of the RM1 assessment indicated that SCCP was the most toxic of the CPs to aquatic life, and that the greatest potential risk from the release of CPs to the aquatic environment was from use in metalworking. Based on this conclusion, a recommendation was made that CPs be referred to a more in-depth assessment (RM2), for consideration of pollution prevention measures.

Based on the RM2 analysis results, EPA determined that there was no need to impose restrictions on the use of SCCPs. The EPA did decide to require annual reporting on the release of SCCP to the Toxic Release Inventory. Specific guidance on the TRI reporting requirements for polychlorinated alkanes can be found at: www.epa.gov/tri/guidance.htm.

Canada:

Additional information should be provided with respect to actions that have been undertaken in Canada with respect to CPs. The following provides additional details regarding actions respecting CPs in Canada:

A Priority Substances List (PSL) Assessment Report for CPs, published in 1994, concluded that SCCPs are considered to be “toxic” under the Canadian Environmental Protection Act, 1988 (CEPA) and pose a risk in Canada to human life or health. Information available at the time was considered insufficient to conclude whether medium and long chain chlorinated paraffins are also considered to be “toxic” as defined under CEPA.

After further study and the collection of additional information, Environment Canada published a follow-up report to the PSL assessment of chlorinated paraffins (June 2005). This report concluded that SCCPs, MCCPs and certain LCCPs [i.e., C18-20 and C>20 liquid] are considered to be “toxic” under the Canadian Environmental Protection Act, 1999 (CEPA 1999), having immediate or long-term harmful effect on the environment or its biological diversity. Health Canada also prepared a follow-up report on chlorinated paraffins, concluding that there is no reason to revise the PSL conclusion that SCCPs are “toxic”, and that there is reason to suspect that MCCPs and LCCPs are constituting a danger in Canada to human life or health as per criteria set out in CEPA 1999.

In addition, “alkanes C6-18, chloro” and “alkanes 10-13, chloro” have been subject to reporting pursuant to the Canadian National Pollutant Release Inventory (NPRI) since 1999. Specific information on the reporting requirements for the substances can be found at www.ec.gc.ca/pdb/npri.

ALTERNATIVES / SUBSTITUTES

This section of the dossier provides information only on the potential risks of alternatives to SCCPs and does not address issues of efficacy or cost of the identified alternatives. Specific information about the efficacy of alternatives in sectors and products, and costs of those alternatives (both borne by the producers and consumers) needs to be considered in order to understand the socio-economic implications of management options.

The discussion of alternatives is limited to the UK and Sweden. This discussion may apply to other areas of the world as well, but the question about global applicability is not answered for the reader. In addition, it should be ensured that the list of alternatives is comprehensive and includes details on environmental and health impacts of each. Many of the alternatives for SCCPs are also harmful to the environment. It is unclear how the alternatives compare to SCCPs. More data about the alternatives and a more quantitative analysis could benefit a sound assessment.

Understanding that the potential risks of alternatives for SCCP is critical for estimating benefits of management options, some comment on the discussion of risks of SCCP substitutes that was provided in this section of the dossier is included below.

This dossier indicates that the medium chain chlorinated paraffins (MCCPs) are alternatives to SCCPs for many applications. Based on a UK draft risk assessment on MCCPs, the dossier states that “some risk reduction measures may be required for use of MCCPs in the production of PVC, some process formulations of metal cutting fluids, in leather fat liquors, and in carbonless copy paper during recycling”. Elaboration about the potential human health and environmental implications requiring the need for risk reduction measures should considered. Details regarding the type of measures should also be reviewed.

Long chain chlorinated paraffins (LCCPs) appear to have been used in Sweden as alternatives to SCCPs in some of the more demanding metal working applications. LCCPs also appear to have potential as an alternative in the leather, paints and coatings, sealants and rubber applications. There is no discussion in this section as to whether there are health and/or environmental concerns related to using LCCPs for these applications. Information describing any potential concerns for using LCCPs as an alternative should be reviewed.

A number of other potential alternatives, e.g. alkyl phosphate and sulfonated fatty acid esters, are mentioned for specific applications. It is stated that these alternatives are considered less harmful than chlorinated paraffins based on comments from Sweden. More information is required to verify that non-chlorinated paraffins are in fact less harmful in terms of human and environmental health and in which applications these alternatives appear fulfill all technical requirements. Any data from other countries in or outside of the EU would be relevant.

EMISSION CONTROL TECHNIQUES

Little information is provided in the report with respect to abatement techniques. The section pertaining to emission control techniques states that it contains no SCCP specific information is available. It is unclear as to whether this is intended to imply that there are no viable emission control techniques available for SCCP, or that no assessment has been undertaken.

The referred to information about general emission control techniques for the industry sectors does not elaborate on whether these techniques are applicable to SCCPs. In general, the emissions of SCCPs can be reduced by the use of common techniques to control emissions of aerosols or hydrocarbons. These include fabric filters, electrostatic precipitators or scrubbers that will reduce the emission of solids and fluids, or incinerators that will destroy hydrocarbons. A short explanation about these techniques could be useful (the European BREF reference for Waste gas treatment could be considered http://eippcb.jrc.es/pages/FActivities.htm).

Overall, this section fails to provide adequate information for the reader to determine whether other pollution prevention opportunities are available for SCCPs. More exploration of the pollution prevention opportunities is required.

COST AND BENEFITS OF CONTROL

This section seems only to touch on the level of information that would be needed for decision-making on whether a strategy for controlling the risks from SCCPs is warranted. More information about the efficacy and costs of substitutes would be needed in order to conduct a proper socio-economic assessment. While the costs of switching to MCCPs and chlorine-free alternatives are briefly discussed for the metalworking sector, the data is outdated and is not transparent. Several issues would have to be addressed before properly understanding the economic implications of strategies for SCCP, these include the following:

·  More recent estimates on consumption and production in the EU: The estimated increase annual fluid costs for key member states switching to MCCPs or chlorine-free alternatives is provided in section 3.4.2 for the metal workings sector is based on 1995 data. It is clear from statements earlier in the dossier that both production and consumption levels in the EU have dropped dramatically in recent years to an estimated 1,000 metric tons per year. The cost estimates in Table 9 do not reflect the current levels of consumption in the metalworking sector, and may no longer be accurate. Data on current levels of consumption by sector would be needed. In addition to more recent consumption data, recent data on the costs of substitutes would be needed.