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Fuels & Lubes International Quarter Two 2016
How do they affect humans?
Experts aren’t really sure as there are no high quality
epidemiologic studies nor occupational exposure health
studies, let alone randomised controlled human trials
isolating the effect of CPs to clearly establish human
toxicity. Of course, animal in vivo studies have been
extrapolated as to possible effects on humans, which is
what current regulatory and legislative guidelines are
based on.
What is the global stance on the
manufacture and use of CPs?
In the European Union (EU), short, medium and long
chain CPs are all REACH registered. Germany stopped
production of SCCPs as early as 1995. In addition, SCCPs
are considered a substance of very high concern (SVHC) in
the EU and can only be used as dam sealant and in mining
belts. MCCPs are currently not considered a persistent,
bioaccumulative and toxic (PBT) substance but there are
further evaluations being conducted on its environmental
fate. LCCPs are not classified as hazardous to human
health nor the environment.
The EU nominated CPs to be included as a persistent
organic pollutant (POP) about a decade ago and has
reviewed them numerous times. The United Nations
Environment Programme’s (UNEP) Stockholm Convention
(CP) came out with the 2016 draft risk management
evaluation in February that states that “SCCPs are likely, as
a result of their long-range environmental transport, lead
to significant adverse human health and environmental
effects such that global action is warranted.” It remains
to be seen when they will finalise their assessment and
recommendations.
SCCPs, MCCPs and LCCPs are all on the Canadian
Environmental Protection Agency (CEPA) Schedule 1
list (toxic substances managed by CEPA) and are no
longer produced in Canada. Environment Canada and
Health Canada’s report on August 30, 2008 concluded
that “SCCPs and MCCPs are entering the environment
in a quantity or a concentration or under conditions
that constitute or may constitute a danger in Canada to
human life or health.” In addition, LCCPs “are entering
or may be entering the environment in a quantity or
concentration or under conditions that have or may
have an immediate or long-term harmful effect on the
environment or its biological diversity.” vLCCPs were
not discussed in the reports. SCCPs were added to the
prohibited substances list in 2012 and the manufacture,
use, sale or import of short chain chlorinated alkanes
in Canada is banned. Importation of other CPs is still
allowed for use in metalworking fluids, specialised
coatings, plasticisers and flame retardants.
The United States is also following the global
trend, having voiced its concerns through the U.S.
Environmental Protection Agency’s (EPA) 2009 Action
Plan on Short Chained Chlorinated Paraffins. It
subsequently banned manufacture and import of SCCPs.
MCCPs, LCCPs and vLCCPs are also under review. EPA
placed CPs on the Pre-Manufacture Notice (PMN) list
of substances that may present an unreasonable risk
to the environment because they are expected to be
persistent, bioaccumulative and toxic (PBT). In addition,
releases of CPs may exceed concentrations of concern to
aquatic and sediment-dwelling organisms, even without
taking into consideration the expected persistence and
bioaccumulative properties of the PMN substances.
The EPA is supposed to complete its PMNs assessment
by May 2016, but Maria Doa, director of the Chemical
Control Division, Office of Pollution Prevention and Toxics
of the U.S. EPA, has stated that because of the need for
transition, the deadline might be pushed to mid-2017.
In March 2016, EPA closed the comment period for
requesting new available data on certain chlorinated
paraffins in different industries and for different uses.
A Significant New Use Rule on three specific vLCCPs
was also published and will be effective in April 2016.
The EPA clarified that the inclusion of these vLCCPs is
a separate matter from the earlier PMN. This means
that people or companies who intend to manufacture or
import these particular vLCCPs will have to notify the
EPA at least 90 days prior, so that the EPA can evaluate
their intended use and prohibit or limit the use before it
occurs.
Other parts of the world—China, Russia, and Brazil, to
name a few—still produce SCCPs while Australia, South
Korea, Argentina, Ecuador, Mexico and a number of other
countries import it. There is no universal agreement at
present to totally ban or even limit the use of SCCPs,
MCCPs or LCCPs.
Conclusion
After looking into available data on CPs, it is clear
that the scientific community, governmental agencies
and the industry all over the world have a long way to
go to really understand CPs and their health effects
on humans. Although there is general agreement on
SCCPs’ bioaccumulation potential and environmental
persistence, the impact of such is not yet established. In
the last decade or so, a number of the studies into CPs
have come out of China where use and manufacture have
steadily increased, but it also means there is growing
awareness and concern regarding these potentially
harmful substances in Asia. Restrictions on manufacture
and use in North America and Europe have curtailed the
volume of SCCPs, and down the road even MCCPs and
LCCPs might have to be replaced.
There is still a big knowledge gap that exists between
knowing why we think we shouldn’t use CPs and knowing
with certainty why we shouldn’t use them.
