Consultation document on chlorinated paraffins: chapter 2

Proposed Risk Management Path Forward

3.1 Objectives

The objectives of the proposed risk management actions for chlorinated paraffins are to:

1. Reduce releases of chlorinated paraffins to the lowest level possible, from all sources and prevent the re-introduction of their manufacture in Canada;
2. Minimize human exposure to the extent practicable; and
3. Achieve virtual elimination (VE) as specified under subsection 77(4) of CEPA 1999 for chlorinated paraffins with up to 20 carbon atoms.

3.2 Proposed Risk Management Actions

Given these objectives, it is proposed that the risk management actions for chlorinated paraffins comprise the following:

1. Addition of chlorinated paraffins with chain lengths between 10 and 20 carbon atoms to the Prohibition of Certain Toxic Substances Regulations, 2005 with potential specific exemptions. This will result in a prohibition, with potential exemptions, on the manufacture, use, sale, offer for sale and import of chlorinated paraffins with chain lengths between 10 and 20 carbon atoms or formulations containing them.
2. Options for risk management of long chain chlorinated paraffins with chain lengths > 20 carbon atoms are currently under consideration. Input on the approach to manage risks posed by long chain chlorinated paraffins is being sought from interested stakeholders.

3.3 The Addition of Chlorinated Paraffins With Chain Lengths Between 10 and 20 Carbon Atoms to the Prohibition of Certain Toxic Substances Regulations, 2005

3.3.1 Identification of Alternatives

Metalworking Fluids

The Government of Canada believes that the most effective means of minimizing the releases of chlorinated paraffins from the metalworking industry is through the transition to alternatives.

Information gathered by the Government of Canada indicates that substitutes to chlorinated paraffins are available to metalworking fluid formulators and certain formulators and end-users have indicated that they would like to move away from the production and use of chlorine based metalworking fluids. However for certain applications, the following issues have been identified:

• Some substitutes may not be technically suitable for all applications;
• Some substitutes may be more costly.

Through extensive research, Environment Canada has identified the following class of alternatives for metalworking fluids:

• Sulphur based substitutes
• Phosphorus based compounds
• Nitrated compounds
• Overbased calcium sulphonates
• Other potential substitutes such as alkanolamides and diisopropyl oleate

Polyvinyl Chloride

In the manufacturing of PVC, chlorinated paraffins are used primarily in applications where moderate plasticizing and flame retardant properties are required at low cost. It is not anticipated that there would be many technical obstacles to the use of alternatives to chlorinated paraffins for use as plasticizers and/or flame retardants. Analysis of alternatives to chlorinated paraffins suggests that, in many cases, the overall technical characteristics of the PVC product including flexibility and stability would improve with the use of alternatives. Although technically feasible, the use of these alternatives may increase the raw material costs for manufacturers.

Paints and Coatings, Adhesives and Sealants, and Rubber and Elastomers

Very small quantities of chlorinated paraffins are used annually in Canada in the formulation of paints and coatings, adhesives and sealants, and rubber and elastomers in comparison to metalworking fluids. Approximately 100 tonnes of both medium chain chlorinated paraffins and long chain chlorinated paraffins were reported for these applications for the year 2001 in Canada.

Based on information gathered by the Government of Canada, alternatives exist and companies have indicated that they are ready to phase-out chlorinated paraffins for these applications.

3.3.2 Path Forward

3.3.2.1 Chlorinated Paraffins Which Have Chain Lengths Between 10 and 13 Carbon Atoms

As concluded in the final risk assessment report, short chain chlorinated paraffins which have chain lengths between 10 and 13 carbon atoms are "toxic" as defined under paragraphs 64(a) and (c) of CEPA 1999. Furthermore, the Executive Body to the United Nations Economic Commission for Europe (UNECE) Convention on Long-range Transboundary Air Pollution (LRTAP) Protocol on Persistent Organic Pollutants (POPs Protocol) has concluded that short chain chlorinated paraffins satisfy the criteria for a Persistent Organic Pollutant under the Protocol. International actions under the LRTAP POPs Protocol are currently being discussed for these substances.

The Government of Canada is proposing a prohibition of the manufacture, use, sale, offer for sale and import of short chain chlorinated paraffins. However, evidence indicates that short chain chlorinated paraffins used in the manufacture of rubber conveyor belt for mining purposes is still needed because short chain chlorinated paraffins provide specific flame retardant characteristics to meet certain safety requirements. The Government of Canada recognizes that currently there are no available alternatives for this use of short chain chlorinated paraffins and is therefore proposing to exempt this use. No other exemptions are being considered at this time for short chain chlorinated paraffins.

3.3.2.2 Chlorinated Paraffins Which Have Chain Lengths Between 14 and 20 Carbon Atoms

As concluded in the final risk assessment report, chlorinated paraffins which have chain lengths between 14 and 20 carbon atoms are "toxic" as defined under paragraphs 64(a) and (c) of CEPA 1999.

The Government of Canada is aware that in most applications using chlorinated paraffins which have chain lengths between 14 and 20 carbon atoms, alternatives are either available or currently being assessed. Therefore, the Government of Canada will promote the substitution of chlorinated paraffins which have the chain lengths between 14 and 20 carbon atoms.

The manufacture, use, import, sale and offer for sale of chlorinated paraffins which have chain lengths between 14 and 20 carbon atoms in rubber, paints and coating or adhesives and sealants and in the PVC sector is proposed to be prohibited since current information suggests that these sectors can transition out of the use of chlorinated paraffins.

The Government of Canada is proposing to phase-out the use of chlorinated paraffins which have chain length between 14 and 20 carbon atoms in the formulation of metalworking fluids over a specified period to provide adequate time for metalworking formulators to transition out of chlorinated paraffins. Time-limited specific use exemptions may still be considered for application where it can be demonstrated that there are no technically or economically feasible available alternatives. Stakeholders are encouraged to present such information to the Government.

3.3.2.3 Mixtures, Formulations and Manufactured Items

Information available indicates that losses during the service life of mixtures and formulations containing chlorinated paraffins (e.g. mixtures such as paints, and sealants) may contribute to environmental releases of these substances. As such, mixtures and formulations are proposed to be included in the scope of the prohibition of chlorinated paraffins with chain lengths between 10 and 20 carbon atoms.

Evidence suggests that releases of chlorinated paraffins to the environment as a result of leaching or volatilization from manufactured articles such as vinyl tiles containing chlorinated paraffins may not be significant. Therefore, the Government of Canada will not be considering restrictions on manufactured items containing chlorinated paraffins which have chain lengths between 10 and 20 carbon atoms at this time. The Government of Canada will continue to monitor this issue as part of the Chemical Management Plan Monitoring Program and may propose additional actions for manufactured articles at a later date.

3.3.2.4 Summary of Proposed Actions under the Prohibition of Certain Toxic Substances Regulations, 2005

The Government of Canada is proposing to add chlorinated paraffins with chain lengths between 10 and 20 carbon atoms to the Prohibition of Certain Toxic Substances Regulations, 2005, which will result in a prohibition on the manufacture, use, sale, offer for sale and import of chlorinated paraffins with chain lengths between 10 and 20 carbon atoms or formulations containing such substances. Specific exemptions are proposed for:

• The import of manufactured articles;
• The manufacture, use, sale, offer for sale and import of chlorinated paraffins with chain lengths between 10 and 13 carbon atoms, as well as formulations containing such substances, for use in rubber conveyor belts for mining purposes; and,
• The manufacture, use, sale, offer for sale and import of chlorinated paraffins with chain lengths between 14 and 20 carbon atoms, as well as formulations containing such substances, for use in metalworking applications for a specific period.