

  Short-Chain Chlorinated Paraffins (SCCPs) and Other Chlorinated
Paraffins 

Action Plan  

 

I. Overview 

 

SCCPs are found world-wide in the environment, wildlife and humans. They
are bioaccumulative in wildlife and humans, are persistent and
transported globally in the environment, and toxic to aquatic organisms
at low concentrations. Based on these factors, as well as the
availability of viable substitutes for certain uses of SCCPs, EPA
intends to initiate action to address the manufacturing, processing,
distribution in commerce, and use of SCCPs. 

 

EPA intends to further evaluate whether the manufacturing, processing,
distribution in commerce and/or use of medium chained chlorinated
paraffins (MCCPs) and long-chained chlorinated paraffins (LCCPs) should
also be addressed. 

 

As part of the Agency's efforts to address SCCPs, EPA also intends to
evaluate the potential for disproportionate impact on children and other
sub-populations. 

 

II. Introduction 

 

As part of EPA’s efforts to enhance the existing chemicals program
under the Toxic Substances Control Act (TSCA)1, the Agency identified an
initial list of widely recognized chemicals, including SCCPs, for action
plan development based on their presence in humans; persistent,
bioaccumulative, and toxic (PBT)2 characteristics; use in consumer
products; production volume; or other similar factors. This Action Plan
is based on EPA’s initial review of readily available use, exposure,
and hazard information on SCCPs. EPA considered which of the various
authorities provided under TSCA and other statutes might be appropriate
to address potential concerns with SCCPs in developing the Action Plan.
The Action Plan is intended to describe the courses of action the Agency
plans to pursue in the near term to address its concerns. The Action
Plan does not constitute a final Agency determination or other final
Agency action. Regulatory proceedings indicated by the Action Plan will
include appropriate opportunities for public and stakeholder input,
including through notice and comment rulemaking processes. 

 

III. Scope of Review 

 

For the purposes of this action plan, SCCPs include the chlorinated
paraffins that meet the following definition: 

CxH(2x-y+2)Cly 

where x = 10-13; 

y = 3-12; and 

the average chlorine content ranges from approximately 40 to 70 percent
with the limiting molecular formulas set at C10H19Cl3 and C13Hl6Cl12.
Any individual chemical meeting this definition is considered an SCCP
and is covered by this action plan. Furthermore, this action plan covers
any chemical substance or mixture that contains a chemical that meets
the definition. For example, CAS registry number (CASRN) 63449-39-8
(Paraffin waxes and hydrocarbon waxes, chlorinated) denotes chlorinated
paraffin waxes of unspecified carbon chain length and unspecified degree
of chlorination. If a portion of that chemical substance falls within
the definition of SCCPs then the entire substance would be subject to
this action plan. Likewise, CASRN 71011-12-6 named (Alkanes, C12-13,
chloro) would only contain chemicals that meet the alkyl range described
in the definition and would be subject to the action plan if any of the
chlorine content were consistent with the 40 to 70 percent criteria.  

1 15 U.S.C. 2 Information on PBT chemicals can be found on the EPA
website at      http://www.epa.gov/pbt/.  

 

Medium chained chlorinated paraffins (MCCP; C14-17 alkyl chain) and
long-chained chlorinated paraffins (LCCP; generally C18 - 28) are also
discussed in this action plan. 

 

Only four chlorinated fractions are on the TSCA Inventory [Alkanes,
C6-18, chloro (CASRN 68920-70-7); Alkanes, C12-13, chloro (CASRN
71011-12-6); Alkanes, chloro (CASRN: 61788-76-9); Paraffin waxes and
Hydrocarbon waxes, chloro (CASRN 63449-39-8)] (EPA, 2006). Other CASRNs
associated with SCCPs are not on the TSCA Inventory. The CASRNs
associated with certain MCCPs and LCCPs are also not on the TSCA
Inventory. 

 

IV. Uses and Substitutes Summary 

 

The current use of chlorinated paraffins (SCCP, MCCP, and LCCP) in the
United States is on the order of 150 million pounds per year. Production
of short-chain and medium-chained chlorinated paraffins (C9 to C17) was
100 million pounds in 2007. A very small fraction of that number is
attributable to import/export business. According to the Chlorinated
Paraffins Industry Association, MCCPs represent the largest production
and use of chlorinated paraffins in North America while SCCPs is only
half that volume (CPIA, 2009). Marketing and use of SCCP has been
restricted in the European Union (ECHA 2008a). In Canada, SCCPs are not
currently manufactured and use was approximately 3000 metric tons in
2000 and 2001, the latest figures reported (Environment Canada, 2008).
In the United States, Dover Chemical Corp. is the sole manufacturer of
chlorinated paraffins and several companies import SCCPs (EPA, 2006). 

 

The largest use of SCCPs in the United States is as a component of
lubricants and coolants in metal cutting and metal forming operations.
The second-largest use is as both a secondary plasticizer and a flame
retardant in plastics, especially PVC. Other minor domestic SCCP uses
are as a plasticizer and a flame-retardant additive to a variety of
products including: rubber formulations, paints and other coatings, and
adhesives and sealants (CPIA, 2009). For safety reasons, other countries
(those in the European Union and Canada) have allowed SCCPs to be used
as a flame retardant in underground mining conveyor belts (rubber
formulations) and fire retardants in dam sealants (ECHA 2008a). 

 

MCCPs are alternatives to SCCPs for many applications. Based on their
physical-chemical properties, MCCPs are also expected to be persistent
in the environment and several field surveys have shown they are present
in sediments and biota, demonstrating their release to and persistence
in the environment. Field-measured bioaccumulation factors (BAFs) that
are greater than 5000 and biomagnification factors (BMF) greater than 1
indicate that MCCPs are bioaccumulative in biota and can biomagnify in
food chains (UNEP, 2009). MCCPs have toxicity to sensitive aquatic
organisms that is similar to SCCPs. Canada has concluded that MCCPs are
“toxic” as defined by the Canadian Environmental Protection Act
(CEPA) (Government of Canada 2008). The European Union’s 2005 Risk
Assessment Report and 2007 draft update conclude that there is a need
for limiting the risks posed by certain uses of MCCPs in the production
of PVC and metal cutting (EC, 2005, 2007). 

 

LCCPs appear to have been used as alternatives to SCCPs in some of the
more demanding metal working applications (HELCOM, 2002). LCCPs also
appear to have potential as an alternative in leather, paints and
coatings, sealants and rubber applications. LCCPs are expected to be
persistent and bioaccumulative in the environment based on their
physical-chemical properties and bioaccumulation modeling, respectively.
Canada has concluded that LCCPs up to C20 are “toxic” as defined by
CEPA (Government of Canada 2008).Canada has not made a determination of
whether LCCPs greater that C20 are toxic. 

 

A number of other potential alternatives, e.g. nitroalkanes, alkyl
phosphate and sulfonated fatty acid esters and vegetable oil based
products, are available for specific applications. It is stated that
these alternatives are considered less harmful than chlorinated
paraffins (UNECE, 2006). These non-chlorinated paraffin alternatives are
often more expensive and may require special handling. A UK estimated
cost for completely converting SCCPs to non-SCCPs in metal working was
predicted to be four million  

V. Hazard Identification Summary 

 

Human Health Effects 

 

Acute toxicity of SCCPs (C10-13) is very low (EC, 1999; UNEP, 2009).
SCCPs may cause skin and eye irritation upon repeated application, but
do not appear to induce skin sensitization (EC, 1999; UNEP, 2009). There
was no evidence of developmental effects in prenatal developmental
toxicity studies in rats and rabbits (EC, 1999; UNEP, 2009). 

 

The liver, kidney and thyroid are major target organs in repeated-dose
studies with rats and mice. When administered by gavage, chlorinated
paraffins (C12, 60 percent chlorine) are carcinogenic in rats and mice
of both sexes (NTP, 1986a; 2005). The underlying mechanisms for the
carcinogenicity of SCCP in rats and mice are not clearly known. SCCPs
were not mutagenic to bacteria with or without metabolic activation (NTP
1986a, b). There are some indications that the SCCP-induced kidney
tumors in male rats are associated with alpha 2μ 

There is no experimental evidence using human data that demonstrates the
carcinogenicity of SCCPs. In the 11th Report on Carcinogens, NCI lists
chlorinated paraffins (C12, 60 percent chlorine) as reasonably
anticipated to be human carcinogens based on sufficient evidence of
carcinogenicity in experimental animals (NTP, 2005). They are classified
by the IARC as Group 2B - possibly carcinogenic to humans based on
sufficient evidence of carcinogenicity in experimental animals and
mechanistic considerations (IARC, 1990). 

 

Health Canada and Environment Canada have characterized all chlorinated
paraffins (SCCPs, MCCPs and LCCPs) as “toxic” under CEPA (Government
of Canada 2008). 

 

A recent compilation of toxicity data indicates the acute toxicity of
MCCPs is low and they are not genotoxic. Prenatal developmental toxicity
studies in rats and rabbits showed reduced fetal body weight. A
reproductive toxicity study also showed postnatal developmental toxicity
as demonstrated by reduced pup body weight, as well as reduced pup
survival at higher doses; there was no evidence of reproductive
toxicity. Repeated-dose studies in rats and dogs showed effects on the
liver (ECHA, 2008a). 

 

Environmental Effects 

 

SCCPs are highly toxic to aquatic invertebrates following acute (48-hr
EC50 = 0.043 to 11 mg/L) and chronic (NOEC = 0.005 to 2 mg/L) exposures.
In fish high toxicity is associated with chronic exposures, but not for
acute exposures (96-hr LC50 = 300 to 10,000 mg/L and NOEC = 0.0096 to
0.05 mg/L). For aquatic plants, there is high toxicity associated with
both acute and chronic exposures to SCCPs (96-hr EC50s range from 0.043
to 0.39 mg/L and NOEC ranges from 0.012 to 0.39 mg/L) (UNEP, 2009). 

 

Both Health Canada and Environment Canada have characterized all
chlorinated paraffins (SCCPs, MCCPs and LCCPs) as “toxic” under CEPA
(Government of Canada 2008). 

 

VI. Physical-Chemical Properties and Fate Characterization Summary 

 

EPA has gathered information on the water solubility, vapor pressure,
Henry’s Law constant, and partition coefficient (log Kow) data for
several different SCCP molecular formulae to characterize the SCCPs
category (Environment Canada, 2008; HSDB, 2008; UNEP, 2009). In general,
water solubility decreases and Henry’s Law Constant and log Kow of
SCCPs increase with increasing carbon chain length and increasing
chlorine content. Short- and medium- chain length chlorinated paraffins
are liquids while longer chain, higher chlorinated paraffins are solids.
The SCCPs are viscous liquids at room temperature and normal pressure.
Vapor pressure of chlorinated paraffins generally decreases with
increasing MW (a function of number of chlorine atoms). All chlorinated
paraffins have low to negligible water solubility but the lower
molecular weight chlorinated paraffins can be emulsified by adding an
organic co-solvent. The octanol-water partition coefficients (log Kow)
of chlorinated paraffins range from 4.5 to 12, with SCCPs log Kows
ranging from approximately 4.5 to 7.4. The log Kows are generally above
5, the criteria used by many national and international authorities to
indicate potential for bioaccumulation because it can be readily
measured and calculated on the basis of structure (UNEP, 2009). 

 

SCCPs are persistent and bioaccumulative in the environment. The
Persistence Organic Pollutant Review Committee (POPRC) of the Stockholm
Convention has concluded that SCCPs fulfill the persistence and
bioaccumulation criteria put forth in Annex D of the Stockholm
Convention on Persistent Organic Pollutants (UNEP, 2009). The EU has
concluded that SCCPs meets its criteria for both persistent and
bioaccumulative (PB) substance and a very persistent, very
bioaccumulative (vPvB) substance (ECHA 2008b). Canada has also concluded
SCCPs are persistent and bioaccumulative (Environment Canada 2008). 

 

SCCPs released to the atmosphere are expected to exist in the vapor and
particulate phase in the ambient atmosphere given the range of vapor
pressures reported for these substances. Vapor phase constituents are
degraded in air by reaction with hydroxyl radicals with half-lives of
less than one to slightly greater than ten days. A half-life greater
than about two days in the atmosphere can be a significant factor in
facilitating long-range transport of persistent chemicals. 

 

SCCPs released to water are expected to adsorb to sediment and suspended
particulate matter based on log Koc values. They are stable to
hydrolysis and photolysis. Volatilization from water is expected to be
moderate based on estimated Henry’s Law constants of the individual
congeners; however, adsorption to suspended solids and sediment in the
water column may attenuate the rate of volatilization. No degradation
was observed in sediments under anaerobic conditions. Detection of SCCPs
in sediment cores dating back to the 1940s provides evidence that SCCPs
are persistent (UNEP, 2009). 

 

SCCPs released to soil are expected to have low mobility given their log
Koc. Volatilization from moist soil surfaces is expected to be moderate
based on estimated Henry’s Law constants of the individual congeners;
however, adsorption may attenuate the rate of volatilization. 

 

Measured data indicate SCCPs bioaccumulate in biota. High
bioconcentration factors (BCFs) have been measured, ranging from 1,000
to 50,000 for whole body and/or individual tissues in a variety of
freshwater and marine organisms (Environment Canada, 2008; UNEP, 2009).
Field-derived bioaccumulation factors (BAFs) over one million were
measured for vertebrate species collected from the Great Lakes and in
arctic marine mammals (Environment Canada, 2008; UNEP, 2009). 

 

The Henry’s Law constant values for SCCPs imply partitioning from
water to air or from moist soils to air, depending on environmental
conditions and prevailing concentrations in each compartment. Evidence
that SCCPs undergo such transport is provided by findings that they are
globally dispersed in the environment and appear in the Arctic (H 

VII. Exposure Characterization Summary 

 

Releases 

 

SCCPs have the greatest potential for environmental release and exposure
of the chlorinated paraffins. The likely sources of releases for SCCPs
are identified as manufacturing and lubricant applications. In 2000 and
2001, nearly all usage of SCCPs was reported to be in metalworking
applications. Losses from the use of SCCPs in paint and sealants are
generally regarded as much lower than those from metalworking. Releases
of SCCPs may occur during production, storage, transportation,
industrial and consumer use of chlorinated paraffin-containing products,
disposal and burning of waste, leaching, runoff or volatilization from
landfills, and sewage sludge or other waste disposal sites (Tomy et al.,
1998). 

 

Major sources of releases of chlorinated paraffins into the environment
are likely the formulation and manufacturing of products containing
chlorinated paraffins and use in metalworking fluids as an extreme
pressure additive. EPA estimated releases of SCCPs during metalworking
fluid use using generic scenario methodology. Releases to wastewater
were estimated to be approximately 2,400 kg/site-yr from container
cleaning, dragout (fluid that remains on the part after shaping),
disposal of filter media and spent metalworking fluid. Releases to
landfill and incineration from these same release sources were estimated
to be approximately 900 kg/site-yr using the generic site methodology.
Incinerators would not be as significant a source. 

 

The possible sources of releases to water from manufacturing include
spills, facility wash down and drum rinsing/disposal. Chlorinated
paraffins in metalworking/metal cutting fluids may also be released to
aquatic environments from drum disposal, carry-off and spent bath. These
releases often ultimately end up in the effluents of sewage treatment
plants. In comparison to river and lake sediments, concentrations of
SCCPs/MCCPs in sewage sludge are much higher, especially from waste
water treatment plants serving industrial areas. 

 

Human Exposure 

 

The primary non-occupational routes of exposure to SCCPs include
ingestion, both directly and through contaminated food, and dermal
contact with products. Chlorinated paraffins have been isolated from
human liver, kidneys, adipose tissue and breast milk. Due to their
potential for environmental transport, SCCP exposure may occur from
sources far from their use and release. For example, SCCPs have been
found in breast milk samples taken from Inuit women (UNEP, 2009). 

 

There is potential for inhalation exposure to SCCPs in metalworking
fluids from mists generated during metal shaping operations. EPA
estimated that potential inhalation exposure ranges from 1.8 to 8.3
mg/day for this scenario. There is also potential inhalation exposure to
mists in uses where products containing SCCPs are spray applied such as
in paints, adhesives and sealants. 

 

EPA estimated the potential for occupational dermal exposure for various
manufacturing, formulation and use scenarios to range up to 1800 mg/day.
These exposures could be mitigated by the use of personal protection
equipment, such as gloves that have been demonstrated to be effective in
preventing permeation by SCCPs and formulations containing SCCPs. 

 

Environmental Exposure 

 

In 1986, EPA/OPPT conducted a monitoring study of Sugar Creek near the
Dover Chemical manufacturing facility in Dover, Ohio (Murray et al.,
1988). SCCP concentrations of 0.21  

As summarized in a draft Risk Profile prepared by the POPs Review
Committee of the Stockholm Convention, SCCPs have been measured in a
variety of environmental media including air, sediment, surface waters,
and wastewater in North America, Europe, Japan, and/or the Arctic (UNEP,
2009). 

 

SCCPs have also been measured in a variety biota, including freshwater
aquatic species from North America, Europe and the Arctic, marine
mammals from several locations in Canada and the Arctic, and avian and
terrestrial wildlife in Europe. In addition, SCCPs have been detected in
samples of human breast milk from Canada and the United Kingdom, as well
as in a variety of food items from Japan and various regions of Europe
(UNEP, 2009). 

 

VIII. Risk Management Considerations 

 

SCCPs continue to be manufactured, imported, processed and used in
industrial applications in the United States. SCCPs are persistent,
bioaccumulative, and toxic to aquatic organisms at low concentrations.
The persistence and bioaccumulative properties of SCCPs increase the
probability and duration of exposure such that even relatively small
releases from individual facilities that manufacture, import, process or
use them or from waste management facilities have the potential to
accumulate over time to levels that cause significant adverse impacts on
the environment. Thus, a snapshot of industrial and other releases of
SCCPs will underestimate the environmental loadings and burden in biota,
and thus potential risks. Indeed, SCCPs have been measured in biota and
various environmental media, including in terrestrial as well as aquatic
organisms. 

 

Other chlorinated paraffins such as MCCPs and LCCPs can be used as
substitutes for SCCPs. They are also persistent and bioaccumulative
although they have lower water solubilities than SCCPs. They have also
been measured in environmental media and biota. The toxicity of MCCPs
and LCCPs may appear to be lower based on their lower solubility and
bioavailability, however, their toxicity is generally not as well
characterized as for the SCCPs. 

 

There are no specific impacts on children associated with chlorinated
paraffins. 

 

IX. Next Steps 

 

EPA is addressing the discrepancy between the specific chlorinated
paraffins companies are actually manufacturing or importing and those
listed on the TSCA Inventory. Only some of the chlorinated paraffin
fractions being manufactured or imported are on the TSCA Inventory. EPA
intends to require companies to submit Pre-Manufacture Notices for the
SCCPs, MCCPs, and LCCPs fractions that are not on the TSCA Inventory. 
If appropriate, EPA will initiate action under TSCA section 5 to address
the risks posed by such SCCPs, and potential risks associated with MCCPs
and LCCPs.  EPA plans to explore these questions in the near future. 

 

Concurrently, EPA intends to consider initiating action under TSCA
section 6(a) to ban or restrict the manufacture, import, processing or
distribution in commerce, export, and use of SCCPs based on the
persistence, bioaccumulation and toxicity of SCCPs and their presence in
the environment.  EPA will develop more detailed assessments to support
the TSCA section 6(a) “presents or will present an unreasonable
risk” findings.  If these more detailed assessments indicate that a
different approach to risk management is appropriate, EPA will consider
additional approaches. 

 

EPA intends to further evaluate whether the manufacturing, processing,
distribution in commerce, use and/or disposal of MCCPs and LCCPs should
also be addressed under TSCA section 6(a). 

 

As part of the Agency's efforts to address these chemicals of concern,
EPA intends to evaluate the potential for disproportionate impact on
children and other sub-populations. 

 

X. References 

 

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H 

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