Chlorinated Paraffins in the Hot Seat Again, ILMA Requests Member Input
ILMA members should be aware of two developments related to the regulation of mid-chain chlorinated paraffins (MCCPs) and chloroalkanes. ILMA requests that members submit comments to the appropriate agencies and contribute to the Association’s own comments.
European Chemicals Agency (ECHA)
First, the European Chemicals Agency (ECHA) earlier this week published its request for information to support its proposal to restrict MCCPs and other substances that may contain chloroalkanes with carbon chain lengths from C14 to C17.
ECHA announced its intent last year to designate MCCPs as a “substance of very high concern”, identifying the substances as persistent, bioaccumulative and toxic, as well as very persistent and very bioaccumulative. The agency also cited a parallel proposal by the United Kingdom to designate MCCPs as a persistent organic pollutant under the U.N. Stockholm Convention.
ILMA interprets ECHA’s information request as the next step in an EU-wide ban of MCCPs.
In its request, ECHA asks for data and information on risk management and waste management measures at downstream user sites, the recycling of articles containing MCCPs or chloroalkanes with carbon chain lengths from C14 to C17, and the use of the substances in polyvinyl chloride (PVC).
Comments are due by March 25 and can be submitted through the ECHA website. ILMA will make a submission to ECHA, and it needs assistance from members in preparing the Association’s response. To contribute to ILMA’s comments, contact ILMA Public Policy Counsel Matt Levetown.
U.N. Stockholm Convention
Second, the U.N. Stockholm Convention secretariat is accepting information to further support the development of an Annex E (risk profile) for MCCPs. The U.K.’s nomination of MCCPs (containing at least 45% chlorine) was discussed late last month at a Persistent Organic Pollutants Committee meeting. What the letter does not indicate is the disagreement among Stockholm Convention members over whether MCCPs meet the persistent organic pollutant criteria.
ILMA intends to submit comments to the Stockholm Convention secretariat by its March 14 deadline using the form for submitting Annex E information. This is likely not the last opportunity to submit information, although it appears to be an important early opportunity. ILMA members are encouraged to submit their own comments using the Annex E form, or contact ILMA Public Policy Counsel Matt Levetown to contribute to ILMA’s comments.
This is a high-priority issue for ILMA and its metalworking fluids members. Because of the short deadlines, the Association will be asking members for assistance and information.