Richard Denison, Ph.D., is a Lead Senior Scientist. Stephanie Schwarz, J.D., is a Legal Fellow.
This story is about chemicals known as chlorinated paraffins. They are used as flame retardants, plasticizers and lubricants, among other things. They come in three main versions: short, medium, and long-chain. Short-chain chlorinated paraffins (SCCPs) have been banned or are set to be banned in a number of jurisdictions and are listed for elimination under the Stockholm Convention. The U.S. is not a party to Stockholm and has not banned SCCPs. However, in 2012 EPA secured agreement from their leading domestic manufacturer, Dover Chemical Corporation, and their leading importer, INOVYN (formerly INEOS Chlor Americas, Inc.), to phase them out in consent decrees issued to settle enforcement actions EPA had brought against the companies (more on that later).
Concern over the medium and long-chain variants (MCCPs and LCCPs) has been significant and growing, however. This is because they, like SCCPs, are expected to be very persistent and very bioaccumulative (vPvB) and, given evidence of systemic toxicity as well as toxicity to aquatic and terrestrial organisms, are also expected to be PBTs (persistent, bioaccumulative, and toxic chemicals).
The regulatory history of chlorinated paraffins under TSCA has been long and taken numerous, often troubling, turns. We’ll only touch on some highlights here. Read More