In a letter sent October 31 to the U.S. Environmental Protection Agency (EPA), ILMA submitted comments recommending that medium-chain and long-chain chlorinated paraffins (MCCPs and LCCPs) be designated as low-priority substances.
A low-priority designation means that a substance does not pose an unreasonable risk to human health or the environment.
The Association points out in its comments that the “EPA already has determined…that MCCPs and LCCPs, under their conditions of use in MWFs and other applications, do not pose an unreasonable risk to health and the environment.”
Chlorinated paraffins are used in metalworking fluids as extreme pressure additives. The industry has met with challenges in formulating effective products without these additives.
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