Science report 

Environmental risk assessment: longchain chlorinated paraffins 

SCHO0109BPGR-E-E
ii Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

The Environment Agency is the leading public body 

protecting and improving the environment in England and 

Wales. 

It’s our job to make sure that air, land and water are looked 

after by everyone in today’s society, so that tomorrow’s 

generations inherit a cleaner, healthier world. 

Our work includes tackling flooding and pollution incidents, 

reducing industry’s impacts on the environment, cleaning up 

rivers, coastal waters and contaminated land, and improving 

wildlife habitats. 

This report is the result of research commissioned and 

funded by the Environment Agency’s Science Programme. 

Published by: 

Environment Agency, Rio House, Waterside Drive, Aztec 

West,Almondsbury, Bristol, BS32 4UD

Tel: 01454 624400 Fax: 01454 624409 

www.environment-agency.gov.uk 

ISBN: 978-1-84432-977-9 

© Environment Agency January 2009 

All rights reserved. This document may be reproduced with prior 

permission of the Environment Agency. 

The views expressed in this document are not necessarily those 

of the Environment Agency. 

This report is printed on Cyclus Print, a 100% recycled stock, 

which is 100% post consumer waste and is totally chlorine free. 

Water used is treated and in most cases returned to source in 

better condition than removed. 

Further copies of this report are available from: 

The Environment Agency’s National Customer Contact Centre by 

emailing enquiries@environment-agency.gov.uk or by 

telephoning 08708 506506. 

Authors: 

D N Brooke, M J Crookes 

and D Merckel 

Dissemination Status: Publicly available 

Keywords: long-chain chlorinated paraffins, 

LCCPs, risk, bioaccumulation, ecotoxicity, 

persistence, toxicity

Research Contractor: 

Building Research Establishment, Garston, 

Watford WD25 9XX 

Tel: +44 (0)1923 664862 

Environment Agency’s Project Manager: 

Daniel Merckel, Science Department, 

Chemicals Assessment Unit, Wallingford 

OX10 8BD 

Tel: +44(0)1491 828 429
Science Report: Environmental risk assessment: long-chain chlorinated paraffins iii

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The work of the Environment Agency’s Science Department is a key ingredient in the 

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appropriate products available to our policy and operations staff. 

Steve Killeen 

Head of Science 
iv Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Acknowledgments 

The Environment Agency has relied heavily on tonnage and use information submitted 

voluntarily by Euro Chlor and the Chlorinated Paraffins Industry Association. We wish to 

formally acknowledge their helpful assistance. Additional useful information has also 

kindly been supplied by the following organisations: 

• British Coatings Federation; 

• British Lubricants Federation; 

• British Rubber Manufacturers Association; 

• British Adhesives and Sealants Association. 

Peter Ridgway at the Health & Safety Executive produced the review of mammalian 

toxicity data. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins v

Executive summary

This Risk Assessment Report has been produced by the Environment Agency to 

complement the reviews of short-chain chlorinated paraffins and medium-chain 

chlorinated paraffins that have been carried out under Council Regulation (EEC) 793/31

on the evaluation and control of the risks of “existing” substances. The purpose of this 

risk assessment is to inform risk management decisions for the whole chlorinated 

paraffin group and to allow the United Kingdom to comment on OSPAR proposals to 

take priority action on long-chain chlorinated paraffins (LCCPs). Further information on 

hazards may be forthcoming from the International Council of Chemical Associations 

High Production Volume (ICCA HPV) initiative in the near future; findings from this 

work will need to be taken into account in any revision of this assessment. 

The term long-chain chlorinated paraffin covers a large group of compounds which vary 

in terms of carbon chain length, uses, physico-chemical properties and ecotoxicological 

properties. In order to try to take some of these differences into account, and in order to 

carry out a more meaningful exposure assessment, the LCCPs were subdivided into 

three groups for which representative data could be derived. The subgroups chosen 

were: 

• C18–20 liquid products; 

• C>20 liquid products; 

• C>20 solid products. 

These groups were chosen because significant differences were found between the 

uses (and hence their potential for release to the environment) and physico-chemical 

properties (and hence their environmental behaviour) of these products. The risk 

characterisation considers the risks from these three subgroups individually and the 

combined risk from the LCCP group as a whole. 

The methodology used in this assessment follows that given in the EU Technical 

Guidance Document2

 for risk assessment of existing substances. 

PBT Assessment 

An assessment of the PBT (persistent, bioaccumulative and toxic) status of LCCPs has 

been made using the available measured and calculated data. The available data 

suggest that these substances do not meet the screening criteria for PBT classification. 

Persistence

Based on the laboratory studies and other data available, LCCPs are unlikely to be 

readily or inherently biodegradable. Although there is some evidence that they may 

biodegrade in the environment, it is thought likely that this process will be sufficiently 

slow that LCCPs meet the P or vP (very persistent) criteria. 

Bioaccumulation

Although the bioconcentration of LCCPs has been investigated in laboratory studies, 

 

1

 O.J. No L084, 05/04/1993, p. 0001 - 0075 

2

 Technical Guidance Document, Part i-V, ISBN 92-827-801[1234] 
vi Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

none of the available data are considered sufficiently robust to allow a reliable 

bioconcentration factor (BCF) to be determined. Based on estimates of BCF – and 

taking the known accumulation properties of structurally similar substances into 

account – the BCF for LCCPs is considered to be <2,000 l/kg. Thus it is concluded that 

LCCPs are unlikely to meet the B or vB (very bioaccumulative) criteria. 

Toxicity

The available data indicate that the chronic NOEC for LCCPs is 0.029 mg/l. This value 

was obtained from tests with Daphnia magna with a C18–20 liquid chlorinated paraffin. 

Other data suggest that the C>20 liquid and C>20 solid chlorinated paraffins are not toxic 

to aquatic organisms. Therefore, based on these data, LCCPs do not meet the toxicity 

criterion from the marine risk assessment guidance. 

“Quantitative” risk assessment: comparison of exposure with effects 

The risks from the normal use of LCCPs to water, sediments, soil and predators have 

been assessed by the application of standard models to the information available. The 

dataset is reasonably complete for this purpose, but there are some areas of 

uncertainty where further information could be valuable. This assessment therefore 

makes recommendations about the significance of the data gaps/data uncertainties, 

and suggests where further research should be focused. 

The research involved searching publicly-available sources, and also extensive 

consultation with producers and users of LCCPs. The main uses of these substances 

are as additives in PVC, rubber, sealants and adhesives, paints and coatings, metal 

cutting/working fluids, leather fat liquors and textile treatments. Finished products 

containing LCCPs (e.g. PVC products and rubber products etc.) can act as sources of 

emission of LCCPs over the products’ lifetime. 

The potential emissions to the environment for the key life-cycle stages were estimated 

based on information from industry research, Emission Scenario Documents or, in the 

absence of any other information, worst case default assumptions. Using the available 

information, risk characterisation ratios (also known as PEC/PNEC ratios) greater than 

1 (indicating an unacceptable risk for the environment) were identified for some uses 

(see below). 

It should be noted that the available toxicity data for aquatic organisms are difficult to 

interpret and the choice of a suitable PNEC for protection of surface water and marine 

water is problematic. A conservative approach has been taken in the assessment to 

determine whether further research is needed in this area. The suitability of the 

equilibrium partitioning method for determining the PNEC for sediment (and also soil) is 

also unclear. 

Some information provided by industry has been treated as confidential and is not 

included in the report, although the data have been used to inform the development of 

appropriate emission scenarios. These data are included in a confidential annex 

supporting the assessment, which is available via the Project Manager where 

appropriate. 

The overall conclusions of the risk assessment are: 

1. There are risks associated with certain life-cycle stages, as indicated below. 

These risks are identified using the best information available. There are many data 

gaps, and where these occur, estimates have been made, which inevitably 

increase the uncertainty in any risk identified and conclusion drawn. It is recognised 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins vii

that further information on both the intrinsic properties of LCCPs, their pattern of 

use and their emissions may help reduce this level of uncertainty. 

Life-cycle stage Compartment at possible risk 

Use in emulsifiable metal cutting/ working 

fluids – intermittent release 

Freshwater sediment 

Terrestrial predators 

 Marine water 

 Marine sediment 

Use in textiles Terrestrial predators 

 Marine sediment 

 

 

2. Further information would be useful to revise the PECs for these scenarios

The uncertainty about these findings above could be reduced with: 

• clarification of whether LCCPs are used in emulsion metal cutting/working 

fluids; 

• clarification of the current disposal practices of emulsion metal 

cutting/working fluids containing LCCPs. 

• information on the emissions to the environment from textile processes 

using LCCPs. 

3. There are uncertainties associated with the PNEC for sediment.

Some PEC/PNEC ratios are >1 for sediment. Toxicity testing with sediment 

dwelling organisms could be considered to reduce the uncertainties in the PNEC for 

sediment. 

4. The are some uncertainties with the PNEC and PEC for secondary poisoning. 

Some PEC/PNEC ratios are >1 for secondary poisoning for terrestrial predators 

(earthworm food chain). An earthworm bioaccumulation test with a C18–20 liquid 

chlorinated paraffin could be considered to reduce the uncertainties in the PEC for 

secondary poisoning. However, the need for such testing is considered a low 

priority at present. 
viii Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Contents

1. GENERAL SUBSTANCE INFORMATION ...................................................................... 1

1.1 IDENTIFICATION OF THE SUBSTANCE 1

1.2 PURITY/IMPURITY, ADDITIVES 2

1.2.1 Purity/Impurities ................................................................................................... 2

1.2.2 Additives .............................................................................................................. 5

1.3 PHYSICO-CHEMICAL PROPERTIES 5

1.4 PHYSICAL STATE (AT N.T.P.) 8

1.4.1 Melting point......................................................................................................... 8

1.4.2 Boiling point ......................................................................................................... 9

1.4.3 Density................................................................................................................. 9

1.4.4 Vapour pressure ................................................................................................ 10

1.4.5 Water solubility................................................................................................... 13

1.4.6 n-Octanol-water partition coefficient .................................................................. 15

1.4.7 Hazardous physico-chemical properties ............................................................ 16

1.4.7.1 Flash point ................................................................................................. 16

1.4.7.2 Autoignition................................................................................................ 16

1.4.7.3 Explosivity.................................................................................................. 16

1.4.7.4 Oxidising properties................................................................................... 17

1.4.8 Other relevant physico-chemical properties....................................................... 17

1.4.8.1 Granulometry............................................................................................. 17

1.4.8.2 Surface tension.......................................................................................... 17

1.4.8.3 Henry’s Law constant ................................................................................ 17

1.4.9 Summary of physico-chemical properties used in the risk assessment............. 21

2. GENERAL INFORMATION ON EXPOSURE ................................................................ 23

2.1 PRODUCTION 23

2.2 USES 23

2.2.1 Use in PVC ........................................................................................................ 25

2.2.2 Use in rubber ..................................................................................................... 27

2.2.3 Use in textiles..................................................................................................... 28

2.2.4 Use in paints ...................................................................................................... 28

2.2.5 Use in sealants .................................................................................................. 32

2.2.6 Use in metalworking/cutting fluids...................................................................... 32

2.2.7 Use in leather fat liquors .................................................................................... 33

2.2.8 Other uses ......................................................................................................... 34

2.2.8.1 Plastics other than PVC............................................................................. 34

2.2.8.2 Printing inks ............................................................................................... 35

2.3 TRENDS 35

2.4 LEGISLATIVE CONTROLS 37

3. ENVIRONMENTAL EXPOSURE ................................................................................... 39
Science Report: Environmental risk assessment: long-chain chlorinated paraffins ix

3.1 ENVIRONMENTAL RELEASES 39

3.1.1 Releases from production .................................................................................. 39

3.1.1.1 Default release estimate............................................................................ 40

3.1.1.2 Industry-specific release information ......................................................... 40

3.1.1.3 Transportation losses ................................................................................ 40

3.1.2 Release from use in PVC................................................................................... 41

3.1.2.1 Default release estimate............................................................................ 41

3.1.2.2 Industry-specific release information ......................................................... 42

3.1.3 Release from use as a plasticiser/flame retardant in rubber.............................. 50

3.1.3.1 Default release estimation ......................................................................... 50

3.1.3.2 Industry-specific release information ......................................................... 51

3.1.4 Release from use as a plasticiser/flame retardant in sealants/adhesives ......... 53

3.1.4.1 Default release estimation ......................................................................... 53

3.1.4.2 Industry-specific information...................................................................... 53

3.1.5 Release from use as a plasticiser/flame retardant in paints .............................. 54

3.1.5.1 Default release estimation ......................................................................... 55

3.1.5.2 Industry-specific information...................................................................... 56

3.1.6 Release from use as an extreme pressure additive in metal cutting/working 

 fluids................................................................................................................... 59

3.1.6.1 Default release information........................................................................ 59

3.1.6.2 Industry-specific release information ......................................................... 61

3.1.7 Release from use in leather fat liquors .............................................................. 68

3.1.7.1 Default release estimation ......................................................................... 68

3.1.7.2 Industry-specific release estimation .......................................................... 70

3.1.8 Release from use in textiles............................................................................... 71

3.1.9 Release from articles over their service life ....................................................... 72

3.1.9.1 Volatilisation .............................................................................................. 72

3.1.9.2 Leaching .................................................................................................... 74

3.1.9.3 Waste in the environment and ultimate disposal ....................................... 77

3.1.10 Summary of release estimates .......................................................................... 78

3.2 ENVIRONMENTAL FATE AND DISTRIBUTION 88

3.2.1 Atmospheric degradation................................................................................... 88

3.2.2 Aquatic degradation........................................................................................... 88

3.2.2.1 Abiotic degradation.................................................................................... 88

3.2.2.2 Biodegradation .......................................................................................... 88

3.2.2.3 Degradation products ................................................................................ 93

3.2.3 Degradation in soil ............................................................................................. 94

3.2.4 Evaluation of environmental degradation data................................................... 94

3.2.5 Environmental partitioning ................................................................................. 95

3.2.6 Adsorption.......................................................................................................... 97

3.2.6.1 Experimental data...................................................................................... 97

3.2.6.2 Predicted data ........................................................................................... 97

3.2.6.3 Summary of adsorption data ..................................................................... 98

3.2.7 Volatilisation....................................................................................................... 98

3.2.8 Precipitation ....................................................................................................... 98

3.2.9 Bioaccumulation and metabolism ...................................................................... 98

3.2.9.1 Bioconcentration from water...................................................................... 98

3.2.9.2 Accumulation from sediment and soil...................................................... 105

3.2.9.3 Dietary/oral accumulation ........................................................................ 111

3.2.9.4 Summary of accumulation ....................................................................... 116

3.3 ENVIRONMENTAL CONCENTRATIONS 118

3.3.1 Aquatic compartment (surface water, sediment and waste water treatment 

plant)................................................................................................................ 118
x Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

3.3.1.1 Calculation of PEClocal.............................................................................. 118

3.3.1.2 Calculation of PECregional and PECcontinental................................................ 127

3.3.1.3 Measured levels in water and sediment .................................................. 128

3.3.1.4 Comparison of predicted and measured levels ....................................... 136

3.3.2 Terrestrial compartment................................................................................... 136

3.3.2.1 Predicted levels ....................................................................................... 136

3.3.2.2 Comparison of predicted and measured levels ....................................... 141

3.3.3 Atmospheric compartment ............................................................................... 141

3.3.3.1 Predicted levels ....................................................................................... 141

3.3.3.2 Measured levels ...................................................................................... 144

3.3.3.3 Comparison of predicted and measured levels ....................................... 144

3.3.4 Food chain exposure ....................................................................................... 144

3.3.4.1 Predicted levels ....................................................................................... 144

3.3.4.2 Measured data......................................................................................... 158

3.3.4.3 Comparison of predicted and measured levels ....................................... 162

3.3.5 Marine compartment ........................................................................................ 163

3.3.5.1 Predicted environmental concentrations.................................................. 163

3.3.5.2 Measured data......................................................................................... 173

3.3.5.3 Comparison of predicted and measured levels ....................................... 174

4. EFFECTS ASSESSMENT: HAZARD IDENTIFICATION AND DOSE 

(CONCENTRATION) – RESPONSE (EFFECT) ASSESSMENT ....................................... 175

4.1 AQUATIC COMPARTMENT (INCLUDING SEDIMENT) 175

4.1.1 Toxicity to fish .................................................................................................. 176

4.1.2 Toxicity to aquatic invertebrates ...................................................................... 183

4.1.3 Toxicity to algae and plants ............................................................................. 196

4.1.4 Quantitative structure-activity relationships (QSARs) ...................................... 196

4.1.5 Overall summary of standard endpoint toxicity data ........................................ 198

4.1.6 Endocrine disruption ........................................................................................ 199

4.1.7 Waste water treatment plant (WWTP) microorganisms................................... 199

4.1.8 Toxicity to sediment organisms........................................................................ 200

4.1.9 Derivation of PNEC for the aquatic compartment ............................................ 200

4.1.9.1 PNEC for surface water........................................................................... 200

4.1.9.2 PNEC for sediment.................................................................................. 205

4.1.9.3 PNEC for WWTP ..................................................................................... 206

4.2 TERRESTRIAL COMPARTMENT 207

4.2.1 Terrestrial toxicity data..................................................................................... 207

4.2.2 PNEC for the soil compartment ....................................................................... 207

4.3 ATMOSPHERE 208

4.3.1 Toxicity data relevant to the atmospheric compartment .................................. 208

4.3.2 PNEC for the atmospheric compartment ......................................................... 208

4.4 NON-COMPARTMENT-SPECIFIC EFFECTS RELEVANT FOR THE FOOD CHAIN 

(SECONDARY POISONING) 208

4.4.1 Avian toxicity.................................................................................................... 208

4.4.2 Mammalian toxicity .......................................................................................... 209

4.4.2.1 Toxicokinetics .......................................................................................... 210

4.4.2.2 Acute toxicity ........................................................................................... 211

4.4.2.3 Irritation.................................................................................................... 211

4.4.2.4 Corrosivity................................................................................................ 212

4.4.2.5 Sensitisation ............................................................................................ 212

4.4.2.6 Repeated dose toxicity ............................................................................ 213
Science Report: Environmental risk assessment: long-chain chlorinated paraffins xi

4.4.2.7 Mutagenicity ............................................................................................ 217

4.4.2.8 Carcinogenicity ........................................................................................ 219

4.4.2.9 Toxicity for reproduction .......................................................................... 220

4.4.2.10 Summary of mammalian toxicity.............................................................. 222

4.4.3 PNEC for secondary poisoning........................................................................ 225

4.5 CLASSIFICATION 226

4.5.1 Current classification........................................................................................ 226

4.5.2 Proposal........................................................................................................... 226

4.5.2.1 Environment ............................................................................................ 226

4.5.2.2 Human health .......................................................................................... 226

5. RISK CHARACTERISATION....................................................................................... 227

5.1 AQUATIC COMPARTMENT 227

5.1.1 Risk characterisation ratios for surface water .................................................. 227

5.1.2 Risk characterisation ratios for waste water treatment plant (WWTP) microorganisms ........................................................................................................ 228

5.1.3 Risk characterisation ratios for sediment ......................................................... 228

5.1.4 Uncertainties and possible refinements ........................................................... 235

5.1.5 Conclusions for the aquatic compartment........................................................ 237

5.2 TERRESTRIAL COMPARTMENT 238

5.2.1 Risk characterisation ratios.............................................................................. 238

5.2.2 Uncertainties and possible refinements ........................................................... 242

5.2.3 Conclusions for soil.......................................................................................... 243

5.3 ATMOSPHERE 243

5.3.1 Conclusions for the atmosphere ...................................................................... 243

5.4 NON-COMPARTMENT SPECIFIC EFFECTS RELEVANT FOR THE FOOD CHAIN 

(SECONDARY POISONING) 243

5.4.1 Risk characterisation ratios.............................................................................. 243

5.4.2 Uncertainties and possible refinements ........................................................... 250

5.4.3 Conclusions for predators................................................................................ 250

5.5 MARINE COMPARTMENT 251

5.5.1 Risk characterisation ratios.............................................................................. 251

5.5.2 Assessment against PBT criteria ..................................................................... 259

5.5.2.1 Persistence.............................................................................................. 259

5.5.2.2 Bioaccumulation ...................................................................................... 259

5.5.2.3 Toxicity .................................................................................................... 260

5.5.3 Uncertainties and possible refinements ........................................................... 260

5.5.4 Conclusions for the marine compartments ...................................................... 260

5.6 MAN EXPOSED VIA THE ENVIRONMENT 261

5.6.1 Risk characterisation ratios.............................................................................. 261

5.6.2 Uncertainties and possible refinements ........................................................... 262

5.6.3 Conclusions for man exposed via the environment ......................................... 262

5.7 OTHER ISSUES 263

5.7.1 Presence of other chlorinated paraffin impurities in LCCPs ............................ 263

5.7.2 Waste disposal................................................................................................. 264
xii Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

REFERENCES.................................................................................................................... 265

GLOSSARY OF TERMS .................................................................................................... 274

ABBREVIATIONS .............................................................................................................. 275

APPENDIX A EUSES MODELLING.......................................................................... 280

APPENDIX B ESTIMATED VAPOUR PRESSURE OF LCCPS................................ 283

APPENDIX C GENERIC LEVEL III FUGACITY MODELLING.................................. 290 

APPENDIX D ANALYTICAL METHODS USED TO DETERMINE LCCP IN 

ENVIRONMENTAL MEDIA ......................................................297 

APPENDIX E EFFECTS OF UNCERTAINTY IN THE PHYSICO-CHEMICAL 

PROPERTIES,DEGRADATION RATE AND EMISSIONS ON THE 

MODELLING OF LCCPs...........................................................301

APPENDIX F ESTIMATION OF WASTE REMAINING IN THE ENVIRONMENT AND 

FUTHER CONSIDERATION OF DIFFUSIVE EMISSIONS FROM 

ARTICLES........................................................................................... 309

APPENDIX G ASSESSMENT OF C16–17 IMPURITIES PRESENT IN LCCPS ....... 324

APPENDIX H CHLOROALKENES (CHLORINATED OLEFINS).............................. 336

APPENDIX I COMPARISON OF THE MAMMALIAN TOXICITY OF SHORT-, 

MEDIUM- AND LONG-CHAIN CHLORINATED PARAFFINS............ 339
Science Report: Environmental risk assessment: long-chain chlorinated paraffins xiii

Tables

Table 1.1 Alternative CAS numbers for LCCPs ................................................................... 2

Table 1.2 Theoretical chlorine contents of some long-chain chlorinated paraffins............... 3

Table 1.3 Chlorinated paraffin impurities present in the long-chain chlorinated paraffins.... 4

Table 1.4 Measured physico-chemical properties of LCCPs ............................................... 6

Table 1.5 Subgroups of commercial LCCPs ........................................................................ 8

Table 1.6 LCCP boiling point values calculated using the Syracuse Research 

Corporation MPBPWIN (version 1.28) computer program................................... 9

Table 1.7 LCCP densities..................................................................................................... 9

Table 1.8 Vapour pressures for example LCCPs calculated using the Syracuse 

Research Corporation MPBPWIN (version 1.28) computer program................. 11

Table 1.9 Representative vapour pressure values for LCCP subgroups, as used in this 

assessment ........................................................................................................ 11

Table 1.10 Weight loss on heating chlorinated paraffins...................................................... 13

Table 1.11 Evaporation rates of various LCCPs (Howard et al., 1975)................................ 13

Table 1.12 Estimated log Kow values for several example LCCPs from chemical structure, 

using the Syracuse Research Corporation Log Kow (version 1.6) estimation 

program.............................................................................................................. 15

Table 1.13 Representative log Kow values for LCCP subgroups, as used in this 

assessment ........................................................................................................ 16

Table 1.14 Estimated Henry's Law constants for LCCPs..................................................... 19

Table 1.15 Representative values of Henry’s Law constant (H) for LCCP subgroups, as 

used in this assessment..................................................................................... 21

Table 1.16 Summary of selected physico-chemical properties............................................ 21

Table 2.1 Exhaust air treatment in Western Europe by process in 1990 (Kirk-Othmer, 

1996) .................................................................................................................. 27

Table 2.2 Results of survey of chlorinated paraffin use in rubber in the United Kingdom.. 28

Table 2.3 Example long-chain chlorinated paraffin contents of paints and varnishes........ 29

Table 2.4 Chlorinated paraffin content of paints and coatings (BCF, 1999)....................... 30

Table 2.5 Treatment methods currently recommended by Euro Chlor .............................. 38

Table 3.1 Estimated amounts of LCCPs used at flexible PVC processing sites................ 42

Table 3.2 Comparison of estimates for the daily worst case amounts of LCCPs used on 

a PVC processing site........................................................................................ 43

Table 3.3 Weight loss on heating plasticisers and LCCPs for four hours at 180°C ........... 44

Table 3.4 Estimated worst case emissions of C18–20 liquid chlorinated paraffins to air from 

PVC processing sites ......................................................................................... 49

Table 3.5 LCCP emission factors for formulation of solvent-borne coatings (from 

Environment Agency ESD, 2003)....................................................................... 57

Table 3.6 Total losses of oil-based cutting fluids in large and small metalworking shops.. 64

Table 3.7 Potential losses to the environment of emulsifiable metalworking/cutting fluids 66

Table 3.8 LCCP rates of volatilisation ................................................................................ 72

Table 3.9 Estimated volatilisation losses of LCCPs from polymeric materials over their 

lifetimes .............................................................................................................. 74

Table 3.10 Estimated leaching losses of LCCPs from polymeric materials over their 

lifetime................................................................................................................ 76

Table 3.11 Summary of environmental release estimates for LCCPs.................................. 82

Table 3.12 Estimated atmospheric half-lives for LCCPs...................................................... 88

Table 3.13 BOD values for LCCPs (Madeley and Birtley, 1980).......................................... 89

Table 3.14 Biodegradation results of Hildebrecht (1972)..................................................... 90

Table 3.15 BOD5 and COD values for various LCCPs (Hoechst AG, 1976 and 1977)........ 91

Table 3.16 Results of dechlorination experiments (Omori et al., 1987) ............................... 92
xiv Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.17 Biodegradation in sediments (Zitko and Arsenault, 1974 and 1977).................. 93

Table 3.18 Atmospheric half-lives of LCCPs........................................................................ 95

Table 3.19 Results of level III fugacity modelling for LCCPs................................................ 96

Table 3.20 Estimated Koc values for LCCPs from structure................................................ 97

Table 3.21 Results of the 60-day rainbow trout bioconcentration studies (Madeley and 

Maddock (1983a and 1983b) ........................................................................... 101

Table 3.22 Summary of the 60-day mussel bioconcentration studies (Madeley and 

Thompson (1983a and 1983b)......................................................................... 103

Table 3.23 Approximate chlorine contents resulting in a molecular weight of 800 g/mole. 105

Table 3.24 Estimated LCCP earthworm BAF..................................................................... 107

Table 3.25 Estimates for BAFearthworm using alternative TGD method................................. 108

Table 3.26 BAFroot and Kplant-water estimates for LCCP subgroups obtained using equation 

from Brooke et al. (2007).................................................................................. 110

Table 3.27 Values for the plant-water partition (Kplant-water) to be used in the assessment.. 111

Table 3.28 Tissue concentrations of 14C in fish fed a diet of 14C-labelled 42% wt. Cl LCCP 

(Madeley and Birtley, 1980) ............................................................................. 112

Table 3.29 Uptake of 14C-labelled long-chain (42% wt. Cl) chlorinated paraffin by mussels 

(Madeley and Birtley, 1980) ............................................................................. 113

Table 3.30 Uptake of LCCPs by juvenile Atlantic salmon (Zitko, 1974)............................. 114

Table 3.31 Excretion of a C18, 50–53% wt. chlorinated paraffin in rats (Yang et al., 1987) 115

Table 3.32 Predicted behaviour during waste water treatment.......................................... 119

Table 3.33 Summary of PECs estimated for a generic production site.............................. 120

Table 3.34 PEClocal for water and sediment for use in PVC (plastisol processes).............. 121

Table 3.35 PEClocal for water and sediment for use in PVC (extrusion/other – open 

systems)........................................................................................................... 121

Table 3.36 PEClocal for water and sediment for use in PVC (extrusion/other – partially 

open systems).................................................................................................. 122

Table 3.37 PEClocal for water and sediment for use in PVC (extrusion/other – closed 

systems)........................................................................................................... 122

Table 3.38 PEClocal for water and sediment for use in rubber ............................................ 123

Table 3.39 PEClocal for water and sediment for formulation and use in paints ................... 124

Table 3.40 Type PEClocal for water and sediment for use in metal cutting/working fluids... 125

Table 3.41 PEClocal for water and sediment for the formulation and use of leather fat 

liquors............................................................................................................... 126

Table 3.42 PEClocal for water and sediment for use in textile applications ......................... 127

Table 3.43 Estimated PECregional and PECcontinental for the aquatic compartment................. 127

Table 3.44 Concentration of chlorinated paraffins in marine waters in and around the 

UK (Campbell and McConnell, 1980)............................................................... 129

Table 3.45 Concentration of chlorinated paraffins in fresh waters remote from industry 

in the UK (Campbell and McConnell, 1980)..................................................... 130

Table 3.46 Concentration of chlorinated paraffins in waters in industrialised areas in the 

UK (Campbell and McConnell, 1980)............................................................... 131

Table 3.47 Measured levels of LCCPs near a production site in the United States 

(Murray et al., 1988a and 1988b)..................................................................... 132

Table 3.48 Concentration of chlorinated paraffins in marine sediments around the UK 

(Campbell and McConnell, 1980)..................................................................... 133

Table 3.49 Concentration of chlorinated paraffins in fresh and other non-marine 

sediments remote from industry in the UK (Campbell and McConnell, 1980).. 134

Table 3.50 Concentration of chlorinated paraffins in sediments in industrialised areas 

in the UK (Campbell and McConnell, 1980)..................................................... 134

Table 3.51 Concentration of chlorinated paraffins in marine sediment close to a 

chlorinated paraffin production site in Australia................................................ 135

Table 3.52 Estimated concentrations in soil....................................................................... 138

Table 3.53 Predicted regional and continental soil concentrations .................................... 141

Table 3.54 Estimated air concentrations of LCCPs............................................................ 142
Science Report: Environmental risk assessment: long-chain chlorinated paraffins xv

Table 3.55 Estimated concentrations in fish for secondary poisoning ............................... 146

Table 3.56 Estimated concentrations in earthworms for secondary poisoning .................. 148

Table 3.57 Estimated concentrations in food for human consumption............................... 150

Table 3.58 Estimated total human food intake of LCCPs................................................... 156

Table 3.59 Concentration of chlorinated paraffins in marine mussels and crab close to a 

chlorinated paraffin production site in Australia................................................ 158

Table 3.60 Concentrations of chlorinated paraffins in aquatic organisms (Campbell and 

McConnell, 1980) ............................................................................................. 159

Table 3.61 Concentration of chlorinated paraffins in birds (Campbell and McConnell, 

1980) ................................................................................................................ 159

Table 3.62 Concentration of chlorinated paraffins in seabirds' eggsa

 (Campbell and 

McConnell, 1980) ............................................................................................. 160

Table 3.63 Concentration of chlorinated paraffins in human foodstuffs (Campbell and 

McConnell, 1980) ............................................................................................. 160

Table 3.64 Concentration of chlorinated paraffins in sheep from areas near to and remote 

from a chlorinated paraffin production plant (Campbell and McConnell, 1980) 161

Table 3.65 Concentrations of chlorinated paraffins (unspecified chain length) in pooled 

samples from in and around Sweden (Jansson et al., 1993) ........................... 162

Table 3.66 Predicted concentrations in marine water ........................................................ 165

Table 3.67 Predicted concentrations in marine sediment .................................................. 167

Table 3.68 Predicted concentrations for marine predators ................................................ 170

Table 3.69 Predicted concentrations for marine top predators .......................................... 172

Table 4.1 Toxicity to fish .................................................................................................. 180

Table 4.2 Toxicity to invertebrates ................................................................................... 184

Table 4.3 Summary of survival and reproduction in the 21-day study with Daphnia 

magna (TNO, 1993) ......................................................................................... 190

Table 4.4 Summary of survival, adult length and reproduction data from in the 21-day 

study with Daphnia magna using a C>20, 43% wt. Cl chlorinated paraffin 

(Sharpe and Penwell, 2007)............................................................................. 194

Table 4.5 Summary of critical body burdens for lethality (taken from the draft 

Reference Technical Guidance Document being developed for REACH) ....... 197

Table 4.6 Summary of toxicity data for microorganisms .................................................. 200

Table 4.7 Comparison of long-term NOEC data for chlorinated paraffins........................ 204

Table 5.1 Estimated PEC/PNEC ratios for surface water ................................................ 229

Table 5.2 Estimated PEC/PNEC ratios for sediment ....................................................... 232

Table 5.3 PEC/PNEC ratios for soil.................................................................................. 239

Table 5.4 PEC/PNEC ratios for secondary poisoning via the fish food chain .................. 244

Table 5.5 PEC/PNEC ratios for secondary poisoning via the earthworm food chain....... 246

Table 5.6 PEC/PNEC ratios for marine water .................................................................. 251

Table 5.7 PEC/PNEC ratios for marine sediment ............................................................ 253

Table 5.8 PEC/PNEC ratios for marine predators............................................................ 255

Table 5.9 Predicted concentrations for marine top predators .......................................... 257

Table 5.10 Estimated amounts of C16–17 chlorinated paraffin released to the environment 263

Table B1 Estimated vapour pressure for LCCPs (C18–C30) ............................................. 283

Table C1 Properties of LCCPs used in fugacity modelling .............................................. 290

Table E1 Input data for EUSES model for the various scenarios considered ................. 303

Table E2 Resulting concentrations for the various scenarios considered ....................... 304

Table E3 Resulting PEC/PNEC ratios for the various scenarios considered .................. 305

Table E4 Effects of varying the biodegradation half-life on predicted regional 

concentrations.................................................................................................. 308

Table F1 Estimated DEHP emitting surface area and lifetime of outdoor PVC 

products containing DEHP ............................................................................... 313

Table F2 Estimated LCCP emission for outdoor PVC products...................................... 313

Table F3 Estimated LCCP leaching losses from outdoor PVC products......................... 316

Table F4 Estimation of waste remaining in the environment........................................... 320
xvi Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table F5 Summary of diffusive losses of LCCPs from PVC during product lifetimes 

and disposal ..................................................................................................... 321

Table F6 Summary of waste remaining in the environment during product lifetimes and 

disposal ............................................................................................................ 322

Table G1 n-Paraffin impurities present in feedstocks used to manufacture LCCPs ........ 324

Table G2 Summary of environmental release estimates for C18–20 chlorinated paraffins 

and C16–17 impurities......................................................................................... 325

Table G3 Data used for EUSES modelling of C16–17 impurities........................................ 330

Table G4 Estimated PEC/PNEC ratios for surface water ................................................ 331

Table G5 Estimated PEC/PNEC ratios for sediment ....................................................... 332

Table G6 Estimated PEC/PNECPNEC ratios for agricultural soil.................................... 333

Table G7 Estimated PEC/PNEC ratios for secondary poisoning..................................... 334

Table H1 Former commercial chlorinated alkenes of relevance to chain chlorinated 

paraffins ........................................................................................................... 337

Table I1 Summary of the available physico-chemical and toxicity data for the three 

categories of chlorinated paraffins ................................................................... 341
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 1

1. General substance information 

1.1 Identification of the substance 

This assessment covers chlorinated paraffins with carbon chain lengths ≥C18. These are 

known as long-chain chlorinated paraffins (LCCPs). The IUCLID database contains 

information under the following two CAS numbers that is relevant to this assessment: 

The commercially supplied products can be considered as complex mixtures as they 

contain components with different carbon chain lengths and different degrees of 

chlorination, although all have a common structure in that no secondary carbon atom 

carries more than one chlorine atom. The complex nature of the products reflects the 

nature of the starting materials and production process and does not arise as a result of 

the deliberate mixing together of different chlorinated paraffin products. In this report the 

substances will be identified by carbon chain length range and degree of chlorination 

wherever possible. 

Two other groups of chlorinated paraffins are made commercially. These are known as 

short-chain (typically C10–13, also known as SCCPs) and medium-chain (typically C14–17, 

also known as MCCPs) chlorinated paraffins. Information on these other types of 

chlorinated paraffins is only included in this report when it is considered to be relevant to 

the assessment of the long-chain chlorinated paraffins. 

CAS No: 85422-92-0 63449-39-8 

EINECS No: 287-196-3 264-150-0 

EINECS Name: Paraffin oils, chloro Paraffin waxes and 

hydrocarbon waxes, chloro 

Molecular formula: CnH2n+2-yCly, where n ≥18 CnH2n+2-yCly, where n=18–32 

and y=4–30 

Example structural 

formulae: 

Molecular weight: see Section 1.2.1 

Synonyms (see also 

below) 

Chlorinated paraffin wax; chloroparaffin; chlorinated paraffin 

waxes and hydrocarbon waxes; hydrocarbon waxes, 

chlorinated; chlorparaffin; paraffin oils and hydrocarbon oils, 

chloro; long-chain chlorinated paraffins; LCCPs. 
2 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

There are many different CAS numbers that can apply to chlorinated paraffins (Back et 

al., 1994; IARC, 1990). Some of these CAS numbers would also potentially be 

applicable to, or may also cover, long-chain chlorinated paraffins, although the main 

CAS numbers used in the IUCLID database are those reported above. These alternate 

CAS numbers are shown in Table 1.1 below. 

Table 1.1 Alternative CAS numbers for LCCPs 

CAS Number Identity EINECS Number 

61788-76-9 

68920-70-7 

84082-38-2 

84776-06-7 

84776-07-8 

85049-26-9 

85535-86-0 

97659-46-6 

97553-43-0 

106232-85-3 

106232-86-4 

108171-27-3 

Alkanes, chloro 

Alkanes, C6–18, chloro 

Alkanes, C10–21, chloro 

Alkanes, C10–32, chloro 

Alkanes, C16–27, chloro 

Alkanes, C16–35, chloro 

Alkanes, C18–28, chloro 

Alkanes, C10–26, chloro 

Paraffins (petroleum), 

normal C>10, chloro 

Alkanes, C18–20, chloro 

Alkanes, C22–40, chloro 

Alkanes, C22–26, chloro 

263-00-4 

272-924-4 

281-985-6 

283-930-1 

283-931-7 

285-195-2 

287-478-6 

307-451-5 

307-202-0 

not on EINECS 

not on EINECS 

not on EINECS 

In the literature, similar LCCPs may often be referred to in different ways with regard to 

the carbon chain length, for example C>20 and C22–26 are frequently used. The fact that 

these different terms are used does not necessarily mean that they are referring to 

different substances. The actual chain length composition of most LCCPs appears to fall 

into two categories, those centring on a carbon chain length of around C18 or C19, 

(usually termed C18–20 products) and those centring on a carbon chain length of around 

C24 or C25 (usually termed C>20 products). The composition of these products is 

discussed further in the following sections. 

It is possible that related substances called chloroalkenes have been available in the 

recent past or are still in production. These are considered further in Appendix H. 

1.2 Purity/impurity, additives 

1.2.1 Purity/impurities 

Table 1.2 shows the theoretical percentage by weight chlorine contents (% wt. Cl) of 

several compounds that can be considered as LCCPs. 

The amount of chlorine present in the commercial products is usually expressed as an 

average percentage by weight. The commercial products contain many components 

with different carbon chain lengths and different numbers of chlorine atoms. Standard 

analytical methods do not permit separation and identification of these individual 

components and so it is not possible to identify exactly which compounds are present 

within the product, although Table 1.2 can be used as a guide to indicate the possible 

components present. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 3

Work by Könnecke and Hahn (1962) provides a basis for estimation of the distribution of 

chlorine contents present in a given product. This work gives a prediction of 

approximately 80 per cent of the isomers present lying within ±10 per cent of the stated 

average chlorine content and 90 per cent within ±15 per cent. Thus in a long-chain 50% 

wt. Cl product, there is likely to be only around 5 per cent of mono- and dichlorinated 

isomers present, with a correspondingly low amount of highly chlorinated isomers 

present. The work was carried out with C26 chlorinated paraffins, but it is thought that a 

similar distribution will apply to chlorinated paraffins of other carbon chain lengths. 

Table 1.2 Theoretical chlorine contents of some long-chain chlorinated 

paraffins 

Formula Molecular 

weight 

% Cl by 

weight 

Formula Molecular 

weight 

% Cl by 

weight 

C18H36Cl2 323 22.0% C24H40Cl10 683 52.0% 

C18H33Cl5 427 41.6% C24H29Cl21 1,063 70.2% 

C18H30Cl8 530 53.6% 

C18H22Cl16 806 70.5% C25H49Cl3 456 23.4% 

 C25H45Cl7 594 41.9% 

C19H38Cl2 337 21.1% C25H41Cl11 732 53.4% 

C19H35Cl5 441 40.3% C25H30Cl22 1,111 70.3% 

C19H32Cl8 544 52.2% 

C19H23Cl17 855 70.6% C26H51Cl3 470 22.7% 

 C26H46Cl8 642 44.2% 

C20H40Cl2 351 20.2% C26H43Cl11 746 52.4% 

C20H36Cl6 489 43.6% C26H30Cl24 1,194 71.4% 

C20H33Cl9 593 53.9% 

C20H24Cl18 903 70.8% C27H53Cl3 484 22.0% 

 C27H48Cl8 656 43.3% 

C21H41Cl3 400 26.7% C27H24Cl12 794 53.7% 

C21H38Cl6 503 42.3% C27H31Cl25 1,243 71.4% 

C21H35Cl9 607 52.7% 

C21H25Cl19 952 70.9% C28H55Cl3 498 21.4% 

 C28H50Cl8 670 42.4% 

C22H43Cl3 414 25.8% C28H46Cl12 808 52.7% 

C22H39Cl7 552 45.1% C28H33Cl25 1,257 70.6% 

C22H36Cl10 655 54.2% 

C22H26Cl20 1,000 71.0% C29H56Cl4 546 26.0% 

 C29H51Cl9 719 44.5% 

C23H45Cl3 428 24.9% C29H47Cl13 857 53.9% 

C23H41Cl7 566 43.9% C29H33Cl27 1,340 71.6% 

C23H38Cl10 669 53.1% 

C23H27Cl21 1,049 71.1% C30H59Cl3 526 20.3% 

 C30H53Cl9 733 43.6% 

C24H47Cl3 442 24.1% C30H49Cl13 871 53.0% 

C24H43Cl7 580 42.9% C30H35Cl27 1,354 70.8% 

Zitko and Arsenault (1977) analysed the distribution of paraffin chain lengths after 

dechlorination of a C>20, 42% wt. Cl product. These are shown in Figure 1.1. As can be 

seen the chain length distribution centres on around C24–25 for this type of product. 

The purity of the chlorinated paraffin is related to the purity of the n-paraffin used as 

feedstock. In Western Europe, chlorinated paraffins are made from purified n-paraffin 
4 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

feedstocks containing no more than 1–2 per cent isoparaffins and <100 mg 

aromatics/kg (the aromatics are removed by treatment of the n-paraffin with sulphuric 

acid). For some high stability applications, n-paraffins with <1 per cent isoparaffins and 

<10–100 mg aromatics/kg are used (BUA, 1992). 

Information has been provided by industry on the levels of chlorinated paraffins, other 

than long-chain, that might be present in the commercial products. The data are based 

on the known impurities present in the two main paraffin feedstocks used to make the 

various products. These are shown in Table 1.3. 

0

5

10

15

20

Percentage composition

C21 C22 C23 C24 C25 C26 C27 C28

Carbon chain length

Figure 1.1 Carbon chain length distribution for C>20 products 

Table 1.3 Chlorinated paraffin impurities present in the long-chain chlorinated 

paraffins 

Feedstock Impurities 

C18–20 <1% C16

typically 17% C17 (possible range 10–20%) 

C>20 0% C19

<0.2% C20

As can be seen from Table 1.3, the C18–20 chlorinated paraffin products are likely to 

contain a significant amount of C16–17 chlorinated paraffin, which is also a constituent of 

medium-chain chlorinated paraffin products. The C>20 chlorinated paraffin products are 

virtually free from other chlorinated paraffin impurities. The presence of C16–17

chlorinated paraffins in the C18–20 product is considered in Appendix G and the risk 

characterisation. 

It is also possible that chlorinated paraffins with carbon chain lengths of C18 and above 

may be present in other types of chlorinated paraffins, such as the medium-chain 

chlorinated paraffins. The purity of a typical 52% wt. Cl medium-chain chlorinated 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 5

paraffin was reported to be with 0.16 per cent C18 chlorinated paraffins and <0.1 per 

cent C19 chlorinated paraffins (Thompson et al., 2001). Thus the amounts of C>18

chlorinated paraffins present in short- and medium-chain chlorinated paraffins can be 

considered to be negligibly small. 

1.2.2 Additives 

It is known that additives/stabilisers such as long-chain epoxidised soya oil or glycidyl 

ether are added to some chlorinated paraffins to inhibit the release of hydrogen chloride 

at elevated temperatures (BUA, 1992). These are used at concentrations <0.05 per cent 

by weight (Campbell and McConnell, 1980). For some high thermal stability formulations 

other additives, such as organophosphorus compounds, have been reported to be used 

in conjunction with these at <1 per cent by weight (BUA, 1992). 

1.3 Physico-chemical properties 

The physico-chemical properties of LCCPs are discussed below and the available 

experimental data are summarised in Table 1.4. 

The substances under consideration in this assessment contain components covering a 

wide range of carbon chain lengths (from C18 to around C30) and chlorine contents. This 

variety means that a range of values for each physico-chemical property is to be 

expected, reflecting the complex nature of the products. The assessment methods 

outlined in the Technical Guidance Document (TGD) generally assume that a single 

value for certain key properties (e.g. water solubility, vapour pressure, Henry’s Law 

constant and the log Kow value) will be available. For LCCPs, this assumption may 

oversimplify the environmental modelling and hence the assessment. Therefore, as well 

as outlining the available measured data, the following sections also consider estimated 

data and trends, and indicate the value or values that will be used in the assessment for 

these important properties. 

In order to carry out the environmental risk assessment for this group of substances, a 

balance has to be struck between: 

• the level of detail required to describe representatively the various products 

supplied in terms of their uses, environmental exposure, fate, behaviour and 

effects; 

• overcomplicating the assessment so that no conclusion can be drawn from the 

available data. 

To this end, the assessment will assume that the entire group of LCCPs can be broken 

down into essentially three subgroups (see Section 1.4). These subgroups reflect: 

• the differences in the starting materials used (which determine the carbon chain 

length distribution in the final product); 

• the physico-chemical properties (for example, some products are liquids and 

some are solids); 

• the different uses between the main types of LCCPs supplied. 
6 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

The properties appropriate to these three subgroups are discussed in the following 

sections and are summarised in Section 1.4.9. It should be remembered that these 

three subgroups still contain components with widely varying physico-chemical 

properties and so the approach taken is still an approximation. For this reason the 

physico-chemical properties for these subgroups have been selected with a view to 

carrying out a "realistic worst case" risk assessment, as outlined in the TGD. 

Table 1.4 Measured physico-chemical properties of LCCPs 

Property Substance Value Reference Remarks 

C18–20. 20% wt. Cl -26°C Ineos Chlor, 2005 

C18–20, 40% wt. Cl -15°C Ineos Chlor, 2005 

C18–20, 44% wt. Cl -25°C IUCLID, 2000a 

C18–20, 47% wt. Cl -9°C Ineos Chlor, 2005 

C18–20, 50% wt. Cl 2°C Ineos Chlor, 2005 

C18–20, 52% wt. Cl 0°C IUCLID, 2000a 

C>20, 42% wt. Cl -30°C IUCLID, 2000a 

-15°C Ineos Chlor, 2005 

C>20, 46% wt. Cl 4°C Ineos Chlor, 2005 

C>20, 48% wt. Cl -15°C IUCLID, 2000a 

10°C Ineos Chlor, 2005 

Melting point 

C>20, 70% wt. Cl 95–105°C; 

100°C 

IULICD, 2000a 

The commercial 

products do not 

have a distinct 

melting point. The 

values quoted 

refer to the pour 

point or softening 

point. 

Boiling point 

(at ntp) 

 

>200°C IUCLID, 2000a Decomposition 

occurs with 

liberation of HCl at 

temperatures 

below their boiling 

point. 

Table 1.4 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 7

Table 1.4 continued 

Property Substance Value Reference Remarks 

C18–20, 20% wt. Cl 0.92 g/cm3 Ineos Chlor, 2005 

C18–20, 35% wt. Cl 1.1 g/cm3 IUCLID, 2000a 

C18–20, 40% wt. Cl 1.13 g/cm3

 Ineos Chlor, 2005 

C18–20, 47% wt. Cl 1.21 g/cm3

 Houghton, 1993 

Ineos Chlor, 2005 

1.27 g/cm3 C18–20, 50% wt. Cl Houghton, 1993 

1.28 g/cm3

 Ineos Chlor, 2005 

C18–20, 52% wt. Cl 1.3 g/cm3

 IUCLID, 2000a 

Density (at 20–

25°C) 

C>20, 42% wt. Cl 1.16 g/cm3

 Houghton, 1993 

Ineos Chlor, 2005 

The density 

decreases with 

increasing 

temperature. 

 C>20, 46% wt. Cl 1.22 g/cm3

 Ineos Chlor, 2005 

 C>20, 48% wt. Cl 1.26 g/cm3

 Houghton, 1993 

 1.24 g/cm3

 Ineos Chlor, 2005 

 C>20, 70% wt. Cl 1.63 g/cm3

 IUCLID, 2000a 

Vapour pressure C23, 42% wt. Cl 2.67×10-3 Pa at 

65°C 

Howard et al., 

1975 

Few details are 

available on how 

the values were 

determined. 

 C>20, 42% wt. Cl 2.67×10-4 Pa at 

80°C 

IUCLID, 2000a; 

BUA, 1992 

 C23, 48% wt. Cl 2.67×10-3 Pa at 

65°C 

Howard et al., 

1975 

 C23, 54% wt. Cl 2.67×10-3 Pa at 

65°C 

Howard et al., 

1975 

Water solubility C25, 42% wt. Cl 0.003 mg/l at 16–

20°C 

Campbell and 

McConnell, 1980 

Seawater, 

radiochemical 

measurement 

 C25, 43% wt. Cl 0.0066 mg/l at 

25°C 

Madeley and 

Gillings, 1983 

Radiochemical 

measurement 

 C25, 70% wt. Cl 0.0059 mg/l at 

25°C 

Madeley and 

Gillings, 1983 

Radiochemical 

measurement. 

Log octanolwater partition 

coefficient 

C21.5, 42% wt. Cl 

C22–26, 42% wt. Cl 

C18–26, 44% wt. Cl 

C22–26, 49% wt. Cl 

7.63–12.83 

9.29–>12.83 

7.46–11.48 

8.69–12.83 

Renberg et al., 

1980 

Determined by a 

high performance 

thin layer 

chromatography 

method. 

Flash point C≥18, >42% wt. Cl >210°C IUCLID, 2000a 

Autoflammability not stated IUCLID, 2000a 

Explosivity not applicable IUCLID, 2000a 

Oxidising 

properties 

 no oxidising 

properties 

IUCLID, 2000a 
8 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Appendix E considers the effects of the uncertainty in some of these key physicochemical properties on the outcome of the risk assessment. 

1.4 Physical state (at n.t.p.) 

The actual physical form of the chlorinated paraffins can vary from free-flowing mobile 

liquids to highly viscous, glassy liquids, to waxy solids and powders (BUA, 1992; 

Houghton, 1993). 

The commercial products supplied can be broadly divided into the subgroups outlined in 

Table 1.5 based on their carbon chain length distributions, chlorine contents, uses and 

physical state. 

Table 1.5 Subgroups of commercial LCCPs 

Carbon chain Chlorine contents Physical state 

C18–20 ca. 30–35% wt. Cl 

ca. 44% wt. Cl 

ca. 48–52% wt. Cl 

LIQUIDS 

C>20 ca. 40–43% wt. Cl 

ca. 48–54% wt. Cl LIQUIDS 

ca. 70–72% wt. Cl SOLID 

These three subgroups will be considered in the assessment. This approach allows the 

differences in the physico-chemical properties and uses, and hence environmental 

releases and exposures of these three subgroups, to be taken into account. 

It is also possible that some other LCCPs could be supplied with chlorine contents 

outside these ranges, for example a C>20, 12% wt. Cl solid product was reported in BUA 

(1992), but these are likely to be produced for specialist applications and will account for 

only a very small proportion of the total use of LCCPs. The above subgroups are 

believed to cover the major long-chain chlorinated paraffin products currently used in the 

EU.

1.4.1 Melting point 

As the commercially supplied products contain many components, they do not have a 

distinct melting point. Pour points or softening points for several LCCPs are reported in 

IUCLID (2000a). These give values in the range -30 to -10°C for products with chlorine 

contents of 42–48% by weight, values around 0°C for products with chlorine contents 

around 50–52% by weight and around 100°C for products with chlorine contents around 

70 per cent by weight. Similar values are also reported in BUA (1992) and Ineos Chlor 

(2005). 

For this assessment, the melting point will be assumed to be around -30°C for LCCP 

products with chlorine contents in the 40–50% wt. Cl range, 0°C for products with 

chlorine contents in the 50–60% wt. Cl range and 100°C for products with chlorine 

contents around 70% wt. Cl. In terms of the procedures used in the TGD, the actual 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 9

value for the melting point is not important, but it is necessary to distinguish between 

solids and liquids at room temperature. 

1.4.2 Boiling point 

It is not possible to determine the actual boiling point of the various commercial products 

as they generally decompose with evolution of hydrogen chloride at temperatures of 

>210°C. 

The Syracuse Research Corporation MPBPWIN (version 1.28) computer program has 

been used to estimate the boiling points of several LCCPs from some example chemical 

structures. The values which were obtained are given in Table 1.6. 

Table 1.6 LCCP boiling point values calculated using the Syracuse Research 

Corporation MPBPWIN (version 1.28) computer program 

Formula % wt. Cl Boiling point 

C18H33Cl5 41.6 ~413°C 

C18H30Cl8 53.6 ~467°C 

C20H36Cl6 43.6 ~454°C 

C20H33Cl9 53.9 ~508°C 

C25H45Cl7 41.9 ~530°C 

C25H42Cl10 50.9 ~583°C 

C25H29Cl23 71.3 ~827°C 

C30H53Cl9 43.6 ~623°C 

C30H49Cl13 53.0 ~695°C 

C30H35Cl27 70.8 ~956°C 

These values are very uncertain, as the same program consistently overestimated the 

melting points of these substances (this may relate to the fact that the estimates are for 

pure substances rather than complex products). The predictions indicate that the boiling 

points of LCCPs are likely to increase with increasing carbon chain length and 

increasing degree of chlorination. 

In terms of the risk assessment, the actual value for the boiling point is not important. 

The available data clearly indicate that all products will be either liquids or solids at room 

temperature. 

1.4.3 Density 

Houghton (1993), IUCLID (2000a) and Ineos Chlor (2005) give the densities of various 

LCCPs at 20–25°C (Table 1.7). 

Table 1.7 LCCP densities 

Carbon chain length Chlorine content Density 

C18–20 20% wt. Cl 

35% wt. Cl 

40% wt. Cl 

47% wt. Cl 

0.92 g/cm3

1.1 g/cm3 

1.13 g/cm3 

1.21 g/cm3 
10 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Carbon chain length Chlorine content Density 

50% wt. Cl 

52% wt. Cl 

1.27–1.28 g/cm3 

1.3 g/cm3

C>20 42% wt. Cl 

48% wt. Cl 

70% wt. Cl 

1.16 g/cm3 

1.22 g/cm3 

1.24–1.26 g/cm3

1.63 g/cm3

 

As can be seen from the available data, the density of the product increases with 

increasing chlorine content. 

1.4.4 Vapour pressure 

Howard et al. (1975) reported that the vapour pressures of C23 chlorinated paraffins 

containing 42%, 48% or 54% wt. Cl were all around 2×10-5 mmHg (2.67×10-3 Pa) at 

65°C. Few details of how these were measured appear to be available. 

Several values for the vapour pressure have been reported in IUCLID (2000a). These 

include a value of 2.66 at 80°C for a C>20, 42% wt. Cl product (no units for the vapour 

pressure are given, but the value was apparently calculated from an effusiometric 

technique) and a value of 2.67×10-6 hPa (2.67×10-4 Pa) at 80°C, again for a C>20, 42% 

wt. Cl product (no details of method). 

Ineos Chlor (2005) gives the vapour pressure of a C>20, 42% wt. Cl product as <2.0×10-6 

mmHg (<2.67×10-3 Pa) at 80°C, determined using an effusiometric technique. This value 

is undoubtedly the same value as referred to above. 

As the measurements have been carried out on commercial products that contain many 

components, it is likely that the vapour pressures measured represent those of the most 

volatile components of the product. 

Drouillard et al. (1998a) determined the sub-cooled liquid vapour pressures of a series 

of short-chain (C10–13) chlorinated paraffins at 25°C using a vapour pressure gas-liquid 

chromatography technique. They found that vapour pressures of the short-chain 

chlorinated paraffins decreased with both increasing carbon chain length and degree of 

chlorination. They derived the following equation relating vapour pressure (in Pa at 

25°C) to the number of carbon and chlorine atoms present in a molecule: 

log (vapour pressure) = -(0.353×no. of C atoms) - (0.645×no. of Cl atoms) + 4.462 

Using this equation, vapour pressures for an LCCP can be estimated. Estimates are 

shown in Appendix B for all possible combinations of carbon and chlorine numbers. It 

should be noted that the reliability of this equation for the LCCPs is unknown. The 

highest predicted vapour pressure for an LCCP is 2.9×10-3 Pa at 25°C for C18H37Cl1

(12.3% wt. Cl) and the lowest estimated vapour pressure is 3.3×10-26 Pa at 25°C for 

C30H32Cl30 (73.1% wt. Cl). Vapour pressures clearly cover an exceptionally wide range. 

A further estimate of vapour pressure for LCCPs has been obtained using the Syracuse 

Research Corporation MPBPWIN (version 1.28) program. This program estimates the 

vapour pressure at 25°C from chemical structure. The values obtained for some 

example LCCPs are shown in Table 1.8 (in the calculations the melting point was set to 

-25°C for the 42–44% wt. Cl substances, 0°C for the 51–54% substances and 100°C for 

the 71% wt. Cl substances). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 11

Table 1.8 Vapour pressures for example LCCPs calculated using the 

Syracuse Research Corporation MPBPWIN (version 1.28) computer program 

Formula Chlorine content (% wt. Cl) Vapour pressure 

C18H33Cl5 41.6 5.3×10-4 Pa (3.9×10-6

mmHg) 

C18H30Cl8 53.6 2.5×10-5 Pa (1.9×10-7

mmHg) 

C20H36Cl6 43.6 5.1×10-5 Pa (3.9×10-7

mmHg) 

C20H33Cl9 53.9 2.3×10-6 Pa (1.8×10-8

mmHg) 

C25H45Cl7 41.9 6.3×10-7 Pa (4.8×10-9

mmHg) 

C25H42Cl10 50.9 2.7×10-8 Pa (2×10-10 mmHg)

C25H29Cl23 71.3 1.4×10-15 Pa (1.1×10-17 

mmHg) 

C30H53Cl9 43.6 2.4×10-9 Pa (1.8×10-11 

mmHg) 

C30H49Cl13 53.0 3.1×10-11 Pa (2.3×10-13

mmHg) 

C30H35Cl27 70.8 6.1×10-19 Pa (4.6×10-21

mmHg) 

The vapour pressure is an important physico-chemical property for the TGD risk 

assessment methodology. It is used, along with water solubility, to define the Henry's 

Law constant, which is necessary to estimate the transport of the substance to air in the 

environment. The vapour pressure also plays a part in the estimation of releases. The 

available measured vapour pressure data for LCCPs are limited in their coverage of the 

products available (and in themselves are not consistent) and so the estimated data 

have to be considered. These estimates show a very wide range of values which makes 

it extremely difficult to select values to represent the three subgroups considered in this 

assessment. Based on the estimated data reported above and in Appendix B, the 

following values at 25°C will be used in the assessment where appropriate (Table 1.9). 

Table 1.9 Representative vapour pressure values for LCCP subgroups, as 

used in this assessment 

Subgroup Best represenmtative 

value 

Approximate range 

C18–20 liquids 

(typically 40–52% wt Cl) 2.5×10-4 Pa 5×10-4 – 2×10-8 Pa 
12 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Subgroup Best represenmtative 

value 

Approximate range 

C>20 liquids 

(typically 40–54% wt. Cl) 2.5×10-5 Pa 5×10-5 – 3×10-15 Pa 

C>20 solids 

(typically 70% wt. Cl) 1.5×10-14 Pa 3×10-14 – 1×10-23 Pa 

For comparison, a vapour pressure of 1.3 – 2.7×10-4 Pa at 20°C was determined for a 

medium-chain chlorinated paraffin (C14–17, 52% wt. Cl) product (Campbell and 

McConnell, 1980), and the values selected here are reasonably consistent with this 

measurement, and also with the information reported below on the relative volatility of 

these compounds. 

For the environmental assessment, the key property derived from the vapour pressure is 

the Henry's Law constant (H), which is discussed in Section 1.4.8. Here, since the value 

of H depends on both vapour pressure and water solubility (and both these appear to 

vary in roughly the same way with carbon chain length and chlorine content), the 

variation in H for each component of the various commercial products is much less than 

is predicted for the vapour pressure (and water solubility) alone, and so representative 

values of H can be defined more easily than representative values for the vapour 

pressures. 

In addition to the vapour pressure estimates, information is available on the volatility of 

various LCCPs (Houghton, 1993; BUA, 1992; Ineos Chlor, 2005). The standard method 

for determining the volatility of these products is to measure the weight loss on heating 

at 180°C for four hours under a flow of nitrogen of 12 litres per hour (Ineos Chlor, 2005), 

but data are also available for heating at 90°C for 24 hours. These data are shown 

below in Table 1.10. Data on a medium-chain chlorinated paraffin (C14–17, 52% wt. Cl) 

are also included for comparison. This method only provides an indirect indication of the 

actual volatility of the chlorinated paraffin as they are known to release chlorine on 

heating. The thermal stability (in terms of loss of hydrogen chloride) for some of these 

products has also been determined over four hours, at a slightly lower temperature of 

175°C, and these data are also shown in Table 1.10 for comparison. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 13

Table 1.10 Weight loss on heating chlorinated paraffins 

Substance Weight loss on 

heating at 90°C for 

24 hour 

(% w/w) 

Weight loss on 

heating at 180°C 

for four hours 

(% /w)a, b, c 

Weight loss of HCl 

on heating at 175°C 

for four hours 

(% w/w)b 

[C14–17, 52% wt. Cl]d [ca. 0.5]d [ca. 1.4]d [0.2]d 

C18–20, 20% wt. Cl 8.3 

C18–20, 35% wt. Cl 0.7 - - 

C18–20, 40% wt. Cl 3.3 

C18–20, 44% wt. Cl 0.2 - - 

C18–20, 47–48% wt. Cl 0.2 0.8–1.6 0.2 

C18–20, 50–52% wt. Cl 0.2 0.7–1.3 0.2 

C18–27, 42% wt. Cl 0.3c

 - - 

C>20, 42% wt. Cl - 0.4–0.50 0.2 

C>20, 46% wt. Cl 0.4 

C>20, 48% wt. Cl - 0.3–0.4 0.2 

C>20, 70% wt. Cl no detectable loss - 0.2 

Notes: a Data from BUA (1992). 

b

 Data from Houghton (1993). 

c

 Value refers to weight loss on heating at 130°C for two hours. 

d

 Information on medium-chain chlorinated paraffin included for comparative 

purposes only. 

Howard et al. (1975) reports the evaporation rate at 100°C of various LCCPs. These 

data are shown in Table 1.11. Again, these data indicate a similar relative volatility as 

shown in Table 1.10. 

Table 1.11 Evaporation rates of various LCCPs (Howard et al., 1975) 

Substance (average carbon chain 

length) 

Evaporation rate at 100°C 

C20, 37–38% wt. Cl 80×10-6 g/cm2

/hour 

C22, 42% wt. Cl 2.5×10-6 g/cm2

/hour 

C24, 43% wt. Cl 60×10-6 g/cm2

/hour 

C>20, 48–54% wt. Cl 40×10-6 g/cm2

/hour 

C22, 50–52% wt. Cl 2.5×10-6 g/cm2

/hour 

C20, 69–72% wt. Cl 1.5×10-6 g/cm2

/hour 

1.4.5 Water solubility 

A detailed investigation of the water solubility of two radiolabelled LCCPs has been 

carried out by Madeley and Gillings (1983). The substances tested were an npentacosane-13-14C that was chlorinated to either 43% wt. Cl or 70% wt. Cl. The 

radiochemical purity of the n-pentacosane was 98 per cent and the chemical purity was 

around 90 per cent (the major impurity was n-tetracosane). This radiolabelled n-paraffin 

was diluted with a non-radiolabelled n-paraffin feedstock (CWX40) before chlorination. 

The tests were carried out by weighing 50 mg of the test substance onto a glass slide 

and placing the glass slide substance-side up into the test vessel containing five litres of 
14 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

water. The vessel was then stirred gently (100 rpm) in the dark for 91 days at 19±0.7°C. 

After this period, the test system was maintained for a further 87 days with no stirring. 

Samples were taken at approximately seven-day intervals for analysis. Both 14C and 

parent compound analyses (by a relatively crude TLC procedure) were carried out. 

During the stirring phase of the experiment, the measured concentrations were not 

consistent, possibly owing to the presence of chlorinated paraffin droplets/suspensions. 

The non-stirring phase of the experiment allowed for settlement of any 

droplets/suspensions and for equilibrium to become established. By the end of this 

phase, the 14C measurements indicated that the concentration had reached steady state 

(the measured concentration remained constant for at least 7–24 days). 

The mean concentrations determined at steady state were 6.4 μg/l in the experiments 

with the C25, 43% wt. Cl substance and 5.9 μg/l with the C25, 70% wt. Cl substance. The 

mean concentration determined by parent compound analysis was <5 μg/l (i.e. below 

the detection limit of the method used). In experiments with C11 and C15 chlorinated 

paraffins under similar conditions, there was evidence for chemical change during the 

test or preferential dissolution of 14C-labelled impurities (the solubility by parent 

compound analysis was lower than that obtained by 14C measurements). For the 

LCCPs, the detection limit for the parent compound analysis is very close to the 

solubility values obtained by 14C measurements and so it is not clear if this was a 

complicating factor in these tests. 

Campbell and McConnell (1980) gave the water solubility of a C25, 42% wt. Cl 

chlorinated paraffin as 3 μg/l at a temperature of 16–20°C in seawater. The value is 

reportedly based on radioactive tracer measurements but few other details of the study 

are available. 

An estimate of water solubility can be obtained from log Kow. The Syracuse Research 

Corporation WSKOW (version 1.30) program has been used to estimate the water 

solubility for a C18H33Cl5, 41.6% wt. Cl chlorinated paraffin, a C25H45Cl7, 41.9% wt. Cl 

chlorinated paraffin and a C25H29Cl23, 71.3% wt. Cl chlorinated paraffin. The estimates 

were carried out twice, once using the log Kow value predicted by the program from 

chemical structure (log Kow of 10.16, 13.96 and 16.92 respectively) and once using a 

log Kow value of around 7.5, 7.6 and 14 (the lower limit of the measured data; see 

Section 1.4.6) for the three chlorinated paraffins respectively. The water solubility 

estimates obtained were: 

• C18H33Cl5 0.017 – 6.1 μg/l 

• C25H45Cl7 1.6×10-6 – 2.0 μg/l 

• C25H29Cl23 1.6×10-11 – 1.0×10-8 μg/l 

The upper limits of the estimates for both the C18H33Cl5 and C25H45Cl7 chlorinated 

paraffins are reasonably consistent with the available measured data for LCCPs. 

For the risk assessment, the water solubility will be taken to be around 5 μg/l for all 

LCCPs, based on the experiments of Madeley and Gillings. Theoretical calculations 

indicate that the water solubility would be expected to be similar to this value for C18–20

products and to decrease with both increasing carbon chain length and chlorine 

contents. However, the available experimental data gave similar values for two LCCPs 

of differing chlorine contents. In addition, Drouillard et al. (1998b) found a trend of 

increasing water solubility for several short chain chlorinated paraffins with increasing 

chlorine content, up to five chlorine atoms per molecule. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 15

The water solubility is used in the TGD methodology mainly to determine the Henry's 

Law constant. Suitable values for this constant are discussed in Section 1.4.8 and so 

the actual value for the water solubility chosen here is not expected to have a large 

influence on the overall assessment3

. However, it is important to consider the water 

solubility when interpreting the aquatic toxicity data. 

The limited available data indicate that the solubility in salt water is similar to, but slightly 

lower than, in freshwater. 

1.4.6 n-Octanol-water partition coefficient 

Renberg et al. (1980) determined the octanol-water partition coefficients for various 

commercial LCCPs using a high performance thin layer chromatography (HPTLC) 

method. The partition coefficients determined (log values) were 7.46–11.84 for a C18–26, 

44% wt. Cl product, 7.63–12.83 for a C21.5, 42% wt. Cl product, 9.29–>12.83 for a C22–26, 

42% wt. Cl product and 8.69–12.83 for a C22–26, 49% wt. Cl product. The range quoted 

reflects the different HPTLC retention times, and hence octanol-water partition 

coefficients, of the various components of the commercial products. 

The Syracuse Research Corporation Log Kow (version 1.6) estimation program has 

been used to estimate log Kow values for several example LCCPs from chemical 

structure using a fragment constant method. The values obtained are shown in Table 

1.12. 

Table 1.12 Estimated log Kow values for several example LCCPs from 

chemical structure, using the Syracuse Research Corporation Log Kow (version 

1.6) estimation program 

Formula Chlorine content (% wt. Cl) Log Kow 

C18H33Cl5 41.6 10.2 

C18H30Cl8 53.6 10.7 

C20H36Cl6 43.6 11.3 

C20H33Cl9 53.9 11.9 

C25H45Cl7 41.9 14.0 

C25H42Cl10 50.9 14.5 

C25H29Cl23 71.3 16.9 

C30H53Cl9 43.6 16.8 

C30H49Cl13 53.0 17.5 

C30H35Cl27 70.8 20.1 

BUA (1992) reported log Kow values for several LCCPs estimated using the CLOGP 3.4 

computer program. The values calculated were 9.1 for C18H34Cl4, 36.2% wt. Cl.; 7.9 for 

C18H30Cl8 53.6% wt. Cl; 10.1 for C20H38Cl4, 33.7% wt. Cl; 8.7 for C20H33Cl9, 53.9 % wt. 

Cl; and 11.6 for C26H44Cl10, 49.9% wt. Cl. It is interesting to note from these values that 

 

3 It is probably incorrect to assume that all LCCPs have the same water solubility. Although it 

would be useful to have reliable data on the water solubilities of the various groups of LCCPs, 

such determinations would be extremely difficult to carry out practically, and the analysis carried 

out in Appendix E indicates that the importance of the actual water solubilities to the overall 

conclusions of the risk assessment is minimal. Therefore more reliable determination of the water 

solubilities is not considered to be a priority at present. 
16 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

the log Kow value appears to decrease with increasing chlorine content, which is the 

opposite trend to that found in the above estimates (Table 1.12). It is possible that the 

values reported in BUA (1992) have been transposed – if this is the case then the two 

sets of estimated values are comparable. 

Overall, it is clear that LCCPs have very high log Kow values. The agreement between 

the measured and predicted data is reasonable, given the inherent problems in 

determining log Kow values for this type of substance. The range of values measured 

for a given commercial product reflects the fact that they contain many components, 

with different components having different log Kow values. The following log Kow values 

will be taken to be appropriate for use in this assessment (based on the Renberg et al.

(1980) measurements and estimated data). 

Table 1.13 Representative log Kow values for LCCP subgroups, as used in this 

assessment 

Subgroup Approx. mid-range log 

Kow value 

Approximate range 

C18–20 liquids 

(typically 40–52% wt Cl) 9.7 7.5–11.8 

C>20 liquids 

(typically 40–54% wt. Cl) 10.3 7.6–13 

C>20 solids 

(typically 70% wt. Cl) 17 14–20 

In terms of the risk assessment, the log Kow value is important for determining the 

partitioning behaviour of the substance (i.e. it is used to estimate partition coefficients for 

adsorption onto solids, bioconcentration etc.). For LCCPs, other data are available that 

allow appropriate estimates for most of these to be made. These are discussed in 

Section 3.2.6 and 3.2.9. 

1.4.7 Hazardous physico-chemical properties 

1.4.7.1 Flash point 

A flash point of >210°C is reported in IUCLID (2000a) for LCCPs with chlorine contents 

>42% wt. Cl. 

1.4.7.2 Autoignition 

Decomposition starts to occur at temperatures of 200°C and above, with liberation of 

hydrogen chloride. This decomposition forms the basis of the gas-phase flame retardant 

activity of some LCCPs. 

1.4.7.3 Explosivity 

The substance is not expected to be explosive. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 17

1.4.7.4 Oxidising properties

The substance is not expected to have oxidising properties. 

1.4.8 Other relevant physico-chemical properties 

1.4.8.1 Granulometry 

No information is available. 

1.4.8.2 Surface tension 

No information is available. 

1.4.8.3 Henry’s Law constant 

No measured values for the Henry's Law constant (H) are available. Henry's Law 

constants can be determined from the ratio of the vapour pressure to water solubility. 

For LCCPs, water solubilities of 6.6 μg/l and 5.9 μg/l have been measured for a C25 

chlorinated paraffin with chlorine contents of 43% wt. and 70% wt. respectively. The only 

measured vapour pressure data available have been determined at elevated 

temperatures, and so it is not possible to calculate a Henry’s Law constant at 

temperatures relevant for the environment. 

Estimates are available for the vapour pressures at 25°C for these substances (see 

Section 1.4.4) and the values obtained are around 6.3×10-7 Pa (using the MPBPWIN 

program) or 1.3×10-9 Pa (Appendix B) for a C25, 41.9% wt. Cl substance and around 

1.4×10-15 Pa (using the MPBPWIN program) or 6.3×10-20 Pa (Appendix B) for a C25, 

71.3% wt. Cl substance. Using these values, the Henry’s Law constant can be 

estimated as 1.3×10-4–0.062 Pa m3

/mol for a C25, ~42–43% wt. Cl substance and 

1.2×10-14–2.7×10-10 Pa m3

/mol for a C25, ~70–72% wt. Cl substance. It should be noted 

that these values depend on the water solubility (the actual solubility could be lower than 

assumed here) and an estimated vapour pressure, and so are inherently uncertain. 

Estimates of Henry's Law constant have also been obtained using the Syracuse 

Research Corporation Henry (version 3.00) program. This estimates the Henry's Law 

constant at 25°C from chemical structure using a bond contribution method, a group 

contribution method, and an "Experimental Value Adjusted" (EVA) method. The program 

indicates that the bond contribution method is able to estimate values for many different 

types of structures, but the group contribution method estimates are generally preferred 

for substances when all the fragment values are available. The EVA method is based on 

the bond contribution method, but takes into account the known Henry's Law constant 

for a substance with a similar structure and so should provide a more reliable estimate. 

In this case Henry’s Law constants have been determined for the following specific 

short-chain chlorinated paraffins (Drouillard et al., 1998a) and these have been used in 

the EVA estimates: 
18 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

• 1,10-dichlorodecane - H = 499 Pa m3

/mole; 

• 1,2,9,10-tetrachlorodecane - H = 17.7 Pa m3

/mole; 

• 1,2,10,11-tetrachloroundecane - H = 6.32 Pa m3

/mole; 

• 1,12-dichlorododecane - H = 648 Pa m3

/mole. 

The results of these estimates for several example structures are shown in Table 1.14. 

The Drouillard et al. (1998a) paper also gives values for H for a pentachlorodecane, a 

pentachloroundecane and a mixture of penta- and hexachlorododecane, all of unknown 

structure. These data are also reported in Table 1.14 along with the values estimated 

using the above methods for comparison purposes. These show that the bond 

contribution method appears to consistently overestimate the value for H, whereas the 

group contribution method generally appears to underestimate the value for H, 

particularly for the substances with higher chlorine contents (of around 48% wt. and 

above). The EVA method, however, does appear to provide reasonably reliable 

estimates for H. In particular, the lower end of the range of values estimated agree very 

well with the known values of H. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 19

Table 1.14 Estimated Henry's Law constants for LCCPs 

Estimated Henry’s Law constant (Pa m3 Formula Chlorine /mole

content (% wt. Cl) 

Bond contribution method 

Group contribution method 

EVA method (four est

Substances used to generate the EVA estimates C10H20Cl2

(1,10-dichlorodecane)a 

33.5 11,855 312 Not applicable 

C10H18Cl4

(1,2,9,10-tetrachlorodecane)a 

50.7 1,469 0.19 Not applicable 

C11H20Cl4

(1,2,10,11-tetrachloroundecane)a 

48.3 1,956 0.27 Not applicable 

C12H24Cl2 (1,12-

dichlorodecane)a 

29.7 20,873 622 Not applicable 

Estimates for LCCPs C18H33Cl5 41.6 5,005 0.084 210, 60, 16 and 155 

mean = 110±88 

C18H30Cl8 53.6 219 1.2×10-6 9.2, 2.6, 0.7 and 6.7 

mean = 4.8±3.9 

C20H36Cl6 43.6 3,101 0.004 131, 37, 10 and 96 

mean = 69±55 

C20H33Cl9 53.9 136 6.1×10-8 5.7, 1.6, 0.4 and 4.2 

mean = 3.0±2.4 

C25H45Cl7 41.9 4,509 5.7×10-4 189, 54, 15 and 140 

mean = 100±79 

C25H42Cl10 50.9 198 8.4×10-9 8.3, 2.4, 0.6 and 6.1 

mean = 4.4±3.5 

C25H29Cl23 71.3 2.5×10-4 8.6×10-30 1.06×10-5, 3.0×10-6, 8.2

7.9×10-6

mean = 5.6×10-6 ±4.5×

C30H53Cl9 43.6 2,310 1.9×10-6 97, 28, 7.5, and 72 

mean = 51±41 

Table 1.14 continued overleaf.
20 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 1.14: continued 

Estimated Henry’s Law constant (Pa m3 Chlorine /mole

content (% wt. Cl) 

Bond contribution method 

Group contribution method 

EVA method (four est

C30H49Cl13 53.0 35.6 7.0×10-13 1.5, 0.4, 0.1, and 1.1 

mean = 0.8±0.6 

C30H35Cl27 70.8 1.6×10-5 1.8×10-35 6.8×10-7, 1.9×10-7, 5.2×

5.0×10-7 

mean = 3.6×10-7 ±2.9×

Estimates for other chlorinated paraffins with known Henry’s Law constants C10H17Cl5a 56.4 390 3.7×10-3 22, 6.2, 1.7, and 16 

mean = 11.5±9.2 

C11H19Cl5a 54.0 518 5.3×10-3 29, 8.3, 2.2 and 21 

mean = 15.1±12.1 

Penta – 51.8 Penta – 932 Penta – 0.011 Penta – 38, 11, 3.0 and 

mean = 20±16 

C12H21Cl5/ 

C12H20Cl6a, b Hexa – 56.5 Hexa – 322 Hexa – 2.6×10-4 Hexa – 14, 3.9, 1.0 and 

mean = 7.2±5.9 

Notes: a Estimates provided for comparative purposes only. 

b The substance was reported to be a mixture of penta- and hexachlorododecane - separate estimates a

components. 

c Values taken from Drouillard et al. (1998a). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 21

For the risk assessment, the EVA estimates will be considered as the best available 

data because they are estimated from data on other chlorinated paraffins, and the 

method appears to work reasonably well for those chlorinated paraffins for which the 

Henry's Law constant is known. The best estimates appear to be at the lower end of 

the range of values obtained for each compound using this method. However, it should 

still be born in mind that the extrapolation from the short-chain chlorinated paraffin data 

to the estimated data for LCCPs is uncertain. 

The values that will be considered to be representative in the assessment are outlined 

in Table 1.15. 

Table 1.15 Representative values of Henry’s Law constant (H) for LCCP 

subgroups, as used in this assessment 

Subgroup Best representative 

estimate for Henry’s Law 

constant (H) 

Approximate range 

C18–20 liquids 

(typically 40–52% wt Cl) 16 Pa m3

/mole 10–210 Pa m3/mole 

C>20 liquids 

(typically 40–54% wt. Cl) 15 Pa m3

/mole 1–190 Pa m3/mole 

C>20 solids 

(typically 70% wt. Cl) 1×10-6 Pa m3

/mole 5×10-8–1×10-5 Pa m3/mole 

1.4.9 Summary of physico-chemical properties used in the risk 

assessment 

The physico-chemical properties selected for use in the risk assessment for the three 

groups of LCCPs considered are summarised in Table 1.16. 

Table 1.16 Summary of selected physico-chemical properties 

Physico-chemical 

property 

C18–20 liquids C>20 liquids C>20 solids 

Melting point (°C) -30a 

0b

-30a 

0b 

100c

Boiling point (°C) >210 (decomp) >210 (decomp) >210 (decomp) 

Density (g/cm3

 at 

20–25°C) 

0.92–1.3 1.16–1.26 1.63 

Vapour pressure 

(Pa at 25°C) 

2.5×10-4 2.5×10-5 1.5×10-14

Water solubility (μg/l 

at ca. 20°C) 

5 5 5 

n-Octanol-water 

partition coefficient 

(log Kow) 

9.7 10.3 17 

Henry’s Law 

constant (Pa m3

/mol 

at 25°C) 

16 15 1×10-6
22 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Notes: a

 For products with chlorine contents of 42–48% by wt.

b For products with chlorine contents of 50–52% by wt. 

c

 For products with chlorine contents of around 70% by wt. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 23

2. General information on 

exposure 

2.1 Production 

Chlorinated paraffins are produced by the direct chlorination of n-paraffin feedstocks. 

The n-paraffin fractions used as feedstocks are C18–20 and C>20 (for example C24–30

feedstock), although the precise composition may vary depending on the petroleum oil 

source (Houghton, 1993). The C18–20 feedstock is not thought to be currently used by 

producers in the United States (CPIA, 2001). 

The reaction is carried out by passing chlorine gas through the liquid paraffin – or a 

solution of the paraffin if the product is highly viscous (Howard et al., 1975) – at a 

temperature of around 80–100°C. The reaction is exothermic and so cooling is required 

to maintain the correct temperature. Ultra-violet light may be used as a catalyst in some 

production processes. The reaction is terminated once the desired degree of 

chlorination has been obtained, by stopping the flow of chlorine into the reaction 

vessel. The degree of chlorination is monitored during the reaction by density, viscosity 

or refractive index measurements. The excess chlorine and hydrogen chloride gas 

(formed as a by-product in the reaction) is then removed by purging with air or nitrogen; 

stabilisers (typically epoxidised vegetable oil) may also be added (Houghton, 1993). 

No contact with water is reported to occur during the production process (Howard et al., 

1975). 

The global production of total chlorinated paraffins was estimated to be above 300,000 

tonnes/year in the late 1980s (Omori et al., 1987). Production of total chlorinated 

paraffins in Western Europe was estimated to be about 140,000 tonnes/year in 1993 by 

BUA (1992). The European consumption of total chlorinated paraffins for 1993 was 

estimated as 100,000–120,000 tonnes/year, and it was estimated that around 15 per 

cent of this was LCCPs (Willis et al., 1994). 

2.2 Uses 

About 5,000–10,000 tonnes of LCCPs were used in the EU each year for the years 

1998–2004. The main current areas of use are as a secondary plasticiser in PVC, as a 

flame retardant in rubber, as a plasticiser/flame retardant in sealants/adhesives and 

paints, as an extreme pressure additive to metal cutting/working fluids, as a component 

of leather fat liquoring treatments and for waterproofing textiles. The actual usage 

figures are considered as confidential information (Euro Chlor, 2000 and 2005), but the 

relative use in each application for 2004 is shown in Figure 2.1. The actual raw data 

are summarised in a confidential Annex. 

In very general terms, the chlorinated paraffins with chlorine contents in the range 40–

50% wt. Cl are used in plasticising applications, whereas the chlorinated paraffins with 

very high chlorine contents (e.g. 70% wt. Cl) are used mainly as flame retardants (Zitko 

and Arsenault, 1974). 
24 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

For use in PVC it is possible that pellets (masterbatch) containing LCCPs could be 

manufactured outside the EU and then imported into the EU for further processing to 

give the final product. Similarly, such pellets could be manufactured within the EU and 

exported for subsequent processing. A similar situation may also exist for finished PVC 

products, or other products such as sealants, paints etc., which contain LCCPs. The 

actual amounts of LCCPs imported into and exported from the EU in this way are very 

difficult, if not impossible, to estimate. For the purposes of this assessment it will be 

assumed that the net import into the EU of these products will be small compared with 

the amount assumed to be used in the EU. 

It is also possible that LCCPs themselves may be imported into the EU, however, the 

amounts involved, although unknown, are thought to be relatively small. 

Similar to the case with medium-chain chlorinated paraffins (ECB, 2005a), it is possible 

that some of the leather fat liquor formulations containing LCCPs produced in the EU 

are exported for use outside the EU, thus the actual quantity of LCCPs applied to 

leather in the EU may be lower than indicated by the Euro Chlor figures. 

The "other" category in Figure 2.1 represents sales to distributors etc., who most likely 

then supply the substance for use in the same areas outlined above, although it cannot 

be excluded that other, as yet unidentified, uses of LCCPs may exist. In this 

assessment, this "other" tonnage will be taken into account by assuming that it is 

redistributed amongst the other known uses. 

The actual amounts of chlorinated paraffins used in the various applications, based on 

the known sales from Western European producers, are considered as confidential and 

so do not appear in this report (they are summarised in a confidential Annex). 

However, the assessment has been based on these known figures. The assessment 

considers the main types of LCCPs used in each application. It is possible that other 

types of LCCPs may be used in some applications but these will only be very minor 

uses. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 25

Textiles

Rubber

PVC

Leather

Metal 

cutting/working

Other

Paints

Sealants/adhesives

s

Figure 2.1 Uses of long-chain chlorinated paraffins in the EU 

2.2.1 Use in PVC 

LCCPs are used in PVC. The main types currently thought to be used in this area are 

the C18–20 liquid chlorinated paraffins, although small amounts of the C>20 liquid 

chlorinated paraffins may have been used in the past. Examples of applications include 

high temperature cables, and plastisol applications such as flooring and PVC leather 

cloth. 

The chlorinated paraffins are used mainly as secondary plasticisers. The primary 

plasticisers are generally phthalates or phosphate esters (Houghton, 1993). The 

phosphate esters are generally only used when flame retardant benefits are needed. 

Primary plasticisers in PVC are used to increase the elongation properties and softness 

of the polymer. Secondary plasticisers, when used in combination with primary 

plasticisers, cause an enhancement of the plasticising effect, and so are also known as 

extenders. 

There are two main types of PVC produced: suspension and paste forming (emulsion) 

PVC. The methods for incorporation of the plasticisers into the two types are different. 

World-wide, approximately 70 per cent of the total PVC resin is suspension PVC, 20 

per cent is emulsion PVC and the remaining 10 per cent consists of bulk PVC (9 per 

cent of total resin production; produces irregular particles with little or no impurities) 

and solution PVC (1 per cent of total resin production; used to make specialised resins 

for metal coatings, record manufacture, powder coatings and surface coatings) (Rubin, 

1990). 

Polymers of suspension PVC (also known as pearl, bead or granular) are produced by 

suspending vinyl chloride monomer in water and carrying out the polymerisation using 
26 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

a monomer-soluble initiator. This technique forms PVC particles with a relatively large 

particle size (e.g. 100–150 μm). These particles are highly porous and so can absorb 

large amounts of plasticiser. 

The PVC particles are typically processed using a dry-blend cycle. In this cycle, all the 

polymer formulation ingredients, including plasticisers, are heated to around 70–110°C 

and mixed to form a dry powder product. This can be either stored or further processed 

immediately. Processing of the dry powder can take the form of extrusion, injection 

moulding or calendering (a process for producing sheets or films). The powder can also 

be extruded and chipped to form pellets of PVC compound which can subsequently be 

further processed to give the final product. Many producers of PVC products purchase 

PVC compound as it is easy to store and similarly many companies exist that produce 

PVC compound (Kirk-Othmer, 1996). 

Paste-forming (plastisol) PVC polymers are produced as a paste or plastisol rather 

than a dry powder. A plastisol is a suspension of a solid in a liquid in which it does not 

dissolve, but does form an homogenous mixture at elevated temperatures; the term 

organosol is used for a plastisol that contains more than 10 parts of a solvent per 100 

parts of resin (Rubin, 1990). 

Microsuspension polymerisation or emulsion polymerisation is usually used to form the 

PVC for these paste-forming applications. Both these processes result in the formation 

of much smaller PVC particles compared with those produced by suspension 

polymerisation processes. The small particle size means that the initial product has low 

porosity and so formulation with additives (e.g. plasticisers) is not possible using a dryblending cycle, and instead a paste is formed. This paste or plastisol can then be 

spread, coated, rotationally cast or sprayed onto the desired item, or may be semigelled for storage (i.e. heat is applied to convert it into a semi-solid form). A wide range 

of plasticisers are used in these applications as the choice affects the viscosity of the 

plastisol, which is important in the further processing steps, and it is common for two or 

three different plasticisers to be used in a single formulation to achieve the desired final 

properties (Kirk-Othmer, 1996). 

During the formation of finished products, the PVC formulation may be exposed to 

temperatures of 180°C for up to several minutes. In some processes, for example 

sheet and film production by calendering or spread coating, there is the potential for 

volatilisation of the plasticiser as the hot plastic is exposed to the surrounding air. 

Processes involving injection moulding and extrusion are carried out in closed 

equipment and little exposure of the hot product to air occurs; the potential for 

volatilisation of the plasticiser is reduced. 

In some facilities filtering or incineration of the exhaust gas is used to reduce the air 

emissions from the process. It has been reported that concentrations of primary 

plasticiser (e.g. di-(2-ethylhexyl) phthalate (DEHP)) are typically 500 mg/m3

 in air 

extracted from spread coating ovens, which can be reduced to <20 mg/m3

 by the use 

of filtration equipment, with exhaust air incineration reducing the emission to practically 

zero. The use of filters and/or incinerators in calendering and spread coating plants has 

been steadily increasing in recent years (Kirk-Othmer, 1996). Figures for 1990 are 

shown in Table 2.1. The figures refer to the percentage of the total phthalate plasticiser 

processed in each application. Of the processes listed in Table 2.1, LCCPs are used 

mainly in spread coating (e.g. PVC leather cloth) and calendered flooring. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 27

Table 2.1 Exhaust air treatment in Western Europe by process in 1990 (KirkOthmer, 1996) 

Process Amount of 

phthalate 

plasticiser used in 

process 

Percentage of phthalate use 

undergoing exhaust air treatment 

 (tonnes/year) Filter treatment Incineration 

Spread coating 192,000 53% 22% 

Slush, dip and 

rotational moulding 

17,000 26% 6% 

Automotive 

underseal 

67,000 100% 

Calendered sheet 

and film 

138,000 23% 25% 

Calendered flooring 31,000 15% 56% 

As the figures in Table 2.1 refer to the percentage of phthalate use, it is not possible to 

determine the percentage of processing sites using LCCPs that have exhaust air 

treatment. If it is assumed that the distribution is the same as for phthalates, then it 

appears that at least 50 per cent of sites using LCCPs will have exhaust air treatment. 

The properties and compatibility of the chlorinated paraffin with both PVC and the 

primary plasticiser vary with both the carbon chain length and the degree of 

chlorination. Generally, as the chain length of the chlorinated paraffin is increased, its 

volatility decreases and so the potential for migration from the finished PVC is reduced. 

At the same time, however, the compatibility with PVC and the primary plasticiser is 

reduced. On the other hand, the compatibility of chlorinated paraffins with PVC and the 

primary plasticiser increases with increasing chlorination, and so the potential for 

migration is reduced, but the flexibility of the final product is also reduced. As a result of 

these properties, chlorinated paraffins with varying degrees of chlorination are used in 

PVC applications (BUA, 1992). 

2.2.2 Use in rubber 

Chlorinated paraffins with high chlorine contents (e.g. 70% wt. Cl) can be used as 

flame retardants in natural and synthetic rubbers (Zitko and Arsenault, 1974). 

Chlorinated paraffins with lower chlorine contents may also be used in rubber. Here 

they have a plasticising and flame retarding function. An important use for flame 

retarded rubber appears to be in conveyor belts for mining applications, but the rubber 

is also used in other applications. 

The amount of chlorinated paraffin added is generally in the range 1–4 per cent by 

weight (Zitko and Arsenault, 1974), but can be up to 15 per cent by weight for some 

applications (BUA, 1992). 

A survey of the use of chlorinated paraffins amongst members of the British Rubber 

Manufacturers' Association Ltd. has been carried out (BRMA, 2001). The survey 

included three main sectors within the rubber industry: the new tyre sector; the general 

rubber goods sector; and the polyurethane foam sector. In all, responses were 

received from 25 companies (around 30 per cent of the membership). Of these, 15 

companies reported using chlorinated paraffins of one type or another. The main area 
28 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

of use of chlorinated paraffins in general was in the general rubber goods sector. The 

results of the survey are summarised in Table 2.2. 

Table 2.2 Results of survey of chlorinated paraffin use in rubber in the 

United Kingdom 

Chlorinated 

paraffin type 

Application Amount of 

chlorinated paraffin 

present in rubber 

Amount of chlorinated 

paraffin used at a site 

Short-chain (C10–13) Conveyor belting 10.1–16.8% 48–51 tonnes/year 

Cable cover 3.8% 25 tonnes/year 

Rubber hose 6.2% 1 tonne/year 

Pipe seals 4% 35 tonnes/year 

Industrial roller 

coverings 

up to 20% 2 tonnes/year 

Medium-chain 

(C14–17) 

Flame retardant 

items for railway use 

7.2% 4.2 tonnes/year 

Various fire resistant 

rubber products 

10% 4.8 tonnes/year 

Manufacture of 

flexible ducting 

7% 1.5 tonnes/year 

Long-chain (C>20) 

Rubber belting 4.6% 0.1 tonnes/year 

Unidentified Shoe soles 6.5% 6 tonnes/year 

(probably shortchain (C10–13)) 

Industrial sheeting 13% 1.2 tonnes/year 

For the LCCPs, the survey indicated that both C>20 liquid and C>20 solid products are 

used in rubber (and this is confirmed based on the confidential EU consumption figures 

for LCCPs provided by Euro Chlor (2005)). No use of chlorinated paraffins in car tyres 

was found in the survey. 

The survey results show that the amount of chlorinated paraffin present in rubber 

products is generally in the range of 4–17 per cent, with a maximum of 20 per cent. 

These figures agree well with those reported in the literature. The LCCPs appear to be 

used at loadings of around 5–10 per cent. 

2.2.3 Use in textiles 

Fire proofing of cellulosic textiles was reported to have been one of the major 

applications for chlorinated paraffins in this area in the past. The chlorinated paraffin 

could be added to the fibres prior to spinning, or used to treat the finished fabric (Zitko 

and Arsenault, 1974). 

Information on the current uses of LCCPs in this area is sparse. The amounts used are 

very small and the main current use appears to be for waterproofing of textiles rather 

than as a flame retardant for cellulosic textiles. 

2.2.4 Use in paints 

Information from the literature on the LCCP contents of paints and varnishes are shown 

in Table 2.3. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 29

Table 2.3 Example long-chain chlorinated paraffin contents of paints and 

varnishes 

Paint typec Chlorinated 

paraffin 

Content of 

paint 

Reference 

Marine paint C>20, 70% wt. Cla, b 5% Back et al., 1994 

Marine paint – high 

build primer 

C>20, 42% wt. Cl 

C>20, 70% wt. Cl 

4% 

7% 

Bowerman, 1971 

Varnish (outdoor) C>20, 70% wt. Cla 11.7% von Eckhardt and Grimm, 

1967 

Alkyd resin varnish 

(outdoor) 

C>20, 70% wt. Cla 8.9% von Eckhardt and Grimm, 

1967 

Alkyd resin varnish 

(low flammability) 

C>20, 70% wt. Cla

 10.0% von Eckhardt and Grimm, 

1967 

Chemical and water 

proof paint 

C18–20, 45–47% wt. 

Cl 

C>20, 70% wt. Cl 

1.7% 

15.6% 

von Eckhardt and Grimm, 

1967 

Paint for concrete C18–20, 45–47% wt. 

Cl 

C>20, 70% wt. Cl 

5% 

9% 

von Eckhardt and Grimm, 

1967 

Weather resistant 

paint for iron and 

concrete 

C18–20, 45–47% wt. 

Cl 

C>20, 70% wt. Cl 

6.8% 

5.5 

von Eckhardt and Grimm, 

1967 

Weather resistant 

paint for iron, concrete 

and asbestos cement 

C>20, 70% wt. Cl 10% von Eckhardt and Grimm, 

1967 

Weather resistant 

paint for concrete and 

facades 

C18–20, 45–47% wt. 

Cl 

C>20, 70% wt. Cl 

5.5% 

1.5% 

von Eckhardt and Grimm, 

1967 

Road markings C18–20, 45–47% wt. 

Cl 

C>20, 70% wt. Cl 

5% 

8% 

von Eckhardt and Grimm, 

1967 

Notes: a The references frequently refer to a solid 70% wt. Cl chlorinated paraffin 

without specifically giving the carbon chain length. This is taken here to be a 

C>20, 70% wt. Cl product. 

b

 The paint may also contain short- or medium-chain chlorinated paraffins. 

c

 Paint assumed to be solvent-based unless otherwise stated. 

Chlorinated paraffins in general are used as plasticisers, binders and flame retardants 

in paints. The concentrations used are usually in the range 5–15 per cent by weight. 

They are reported to be used in marine paints based on chlorinated rubber. Such 

paints may contain chlorinated paraffins with 70% wt. Cl as binder and chlorinated 

paraffins with around 40% wt. Cl as plasticiser (Zitko and Arsenault, 1974). 

Previously, a survey of the use of chlorinated paraffins in paints and coatings in the 

United Kingdom was carried out by the British Coatings Federation (BCF, 1999). The 

survey principally covered medium-chain chlorinated paraffins, but the responses also 

included some information on LCCPs. A total of 141 companies were contacted and 

initial responses were obtained from 106 of these. Of the companies responding, 22 

(~21 per cent) indicated that they used medium-chain chlorinated paraffins or other 

chlorinated paraffins. More detailed information on the use of chlorinated paraffins was 

obtained from 12 (~55 per cent) of the 22 companies. The chlorine content of the 
30 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

chlorinated paraffins used range from around 40% wt. Cl to 70% wt. The types of 

paint/coating and the typical chlorinated paraffin contents are shown in Table 2.4. 

Table 2.4 Chlorinated paraffin content of paints and coatings (BCF, 1999) 

Coating type Chlorinated paraffin content 

(% by weight) 

Organic solvent-borne chlorinated rubber primers and 

topcoats 

1–5 

Organic solvent-borne chlorinated rubber systems for 

swimming pools/fishponds 

5–20 

Organic solvent-borne zinc rich (epoxy) primers 2–5 

Organic solvent-borne acrylic container coatings 2–10 

Organic solvent-borne chemical and water resistant 

coatings 

5–20 

Organic solvent-borne vacuum metallising lacquers 1–5 

Organic solvent-borne flame retardant coating for wood 1–5 

Organic solvent-borne intumescent coating for structural 

steel 

20–30 

Organic solvent-borne floor paints 5–10 

Organic solvent-borne water-proofing coatings for walls 5 

In tonnage terms, the amount of chlorinated paraffins used in the United Kingdom in 

paints/coatings appears to be small, with a total of up to around 34 tonnes/year being 

identified in the 1999 BCF survey (it is not possible to extrapolate this figure to give the 

total United Kingdom or EU usage). Further, it was found that paints containing 

chlorinated paraffins make up only a very small proportion of the total paint 

manufactured at a site (typically <1–2 per cent of the total, up to five per cent in some 

cases). The total number of sites in the United Kingdom manufacturing paints and 

coatings containing chlorinated paraffins is estimated at around 30 (BCF, 1999). 

The BCF (1999) survey also tried to identify the number of sites where coatings 

containing chlorinated paraffins might be used in the United Kingdom, but this did not 

prove to be possible. The major users of the paints are professional painters and 

specialist applicators, but some DIY paints containing chlorinated paraffins may be 

used by the general public. In the United Kingdom, it was estimated that there would be 

around 40,000 users of coatings containing chlorinated paraffins for water-proofing of 

walls, with around 1,000–1,500 users of paints and coatings for other uses. 

In addition, another survey has recently been undertaken (BCF, 2001), this time 

focusing on the use of LCCPs in coatings in the United Kingdom. The results from this 

survey indicated that only small quantities of these substances are used in coatings, 

and the quantities involved appear to be falling, primarily due to a move away from 

chlorinated rubber-based products to lower VOC coatings. The survey revealed an 

LCCP usage of around 10 tonnes/year in paints, with the typical content in paint being 

<1–6 per cent. It was not possible to determine the total usage in paints from this 

survey. The main types and applications of paints containing LCCPs were identified as: 

• chlorinated rubber-based chemical/moisture resistant steel protection coatings; 

• chlorinated rubber-based floor paints; 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 31

• chlorinated rubber-based line marking coatings; 

• chlorinated rubber-based finishes for metal substrates; 

• vinyl primers and finishes for metal substrates; 

• acrylic clear coatings for masonry. 

The number of sites of use for these types of paints and coatings in the United 

Kingdom was estimated to be more than 200. 

Several paint companies in the United Kingdom have also been contacted 

independently. One company has indicated that they use C>20 liquid chlorinated 

paraffins mainly in chlorinated rubber and modified vinyl paints, whereas the C>20 solid 

chlorinated paraffin is used in intumescent paints. Another company indicated that both 

C>20 liquid and C>20 solid chlorinated paraffins are used in professional marine products 

and protective coatings (e.g. for land-based and offshore structures such as oil 

refineries and oil rigs), with the C>20 liquid chlorinated paraffins also being used in 

speciality DIY paints. The typical chlorinated paraffin content of the paint is 2–6 per 

cent in marine products, 3–10 per cent in protective coatings and 1–5 per cent in 

speciality DIY paints. 

Another survey of the use of LCCPs in paints and coatings in the United Kingdom was 

undertaken in 2007 (BCF, 2007). This identified seven companies that were using 

LCCPs in the manufacture of paints and coatings, but it was thought that around 10 

companies actually used LCCPs in these products. The amount used at each company 

was generally around five tonnes per year but could be up to eight tonnes per year. 

The long-chain chlorinated paraffin content in the paints and coatings ranged between 

one per cent and 15 per cent but was generally in the range 4–10 per cent. The main 

uses identified were in marine coatings, protective coatings, single pack anti-corrosion 

coatings, masonry/swimming pool coatings, intumescent coatings and marking paints 

for roads. The survey reported that the use of LCCPs in intumescent paints is a 

growing area of use, and that the use in chlorinated rubber-based paints was 

decreasing mainly as a result of a general decline in the use of this type of paint 

resulting from legislation on VOCs. The main types of LCCPs used were the C>20 liquid 

and C>20 solid products, with the C>20 solid products being used mainly in intumescent 

coatings. No use of the C18–20 liquid products was identified in this survey. 

Other information from industry indicates that acrylic and acrylic copolymer masonry 

paints are now the paint types most likely to contain LCCPs. 

Although no use of the C18–20 liquid chlorinated paraffins in paints and coatings was 

identified in the United Kingdom in the BCF (2007) survey, information provided by 

Euro Chlor (2007) indicate that there is use of this type of LCCP in paints and coatings 

within the EU. 

Overall, although some of the available data concerns use of chlorinated paraffins in 

general, it is clear that C18–20 liquid, C>20 liquid and C>20 solid LCCPs are used in 

various types of paints, mainly in the professional area. The available information 

indicates that the use of LCCPs in formulation of paints in the UK is relatively small, but 

in terms of the EU as a whole, use of LCCPs in paints appears to be the second largest 

application of LCCPs in general (see Figure 2.1 earlier). 
32 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

2.2.5 Use in sealants 

Chlorinated paraffins, including the long-chain ones, are used as plasticisers/flame 

retardants in adhesives and sealants. Examples include polysulphide, polyurethane, 

acrylic and butyl sealants used in building and construction, and in sealants for double 

and triple glazed windows. The chlorinated paraffins are typically added at amounts of 

10–15 per cent by weight of the final sealant, but could be added at amounts up to 20 

per cent by weight in exceptional cases (BUA, 1992). 

The difference between an adhesive and sealant can be difficult to define as some 

sealants are used as adhesives and vice versa. Generally, sealants are considered to 

be materials that are installed into a gap or joint to prevent water, wind, dirt or other 

contaminants from passing through the joint or crack. Adhesives, on the other hand, 

are used to transfer loads and are typically designed with much higher tensile and 

shear strength than sealants (Palmer and Klosowski, 1997). 

Of the LCCPs, it is thought that mainly the C18–20 and C>20 liquid chlorinated paraffins 

are used in this area, mainly in sealants. Emissions from adhesives over their lifecycle 

are likely to be similar to those for sealants. 

A small use of LCCPs has been identified in the United Kingdom in specialist primers 

and adhesives, where flame retardancy is important. The quantities involved in this 

application appear to be very small. 

2.2.6 Use in metalworking/cutting fluids 

Generally, only the liquid chlorinated paraffins are used in lubricants (Howard et al., 

1975). Information provided by the EU suppliers of LCCPs indicates that the major 

types of chlorinated paraffin used in this application are the C>20 liquid products, with 

only a very minor usage of the C18–20 chlorinated paraffins. 

For oil-based fluids, the chlorinated paraffin content of the fluid ranges from about 5% 

wt. for light machining up to 70% wt. for heavy drawing processes (metal forming fluids) 

(BUA, 1992). 

Chlorinated paraffins in general are used in a wide variety of cooling and lubricating 

fluids used during metal cutting, grinding and forming operations. The two main types 

of lubricants used are water-based emulsions, whose function is mainly cooling, and 

oil-based lubricants. The chlorinated paraffins used generally have a chlorine content 

of between 40 and 55% wt. Cl. The amount of chlorinated paraffin present in a given 

fluid depends on the final application (BUA, 1992). 

The market for metal forming fluids in the United Kingdom is around 500 tonnes per 

year. These contain up to 70% by weight of chlorinated paraffin, but the average 

content is around 50 per cent by weight. (Euro Chlor, 1998). The main type of 

chlorinated paraffin used in these applications used to be short-chain (C10–13), but 

suitable alternatives are now available. 

The amount of chlorinated paraffin present in the water-based cooling lubricant 

concentrate is up to four per cent as chlorine (i.e. up to around eight per cent as 

chlorinated paraffin). This is diluted with water to give a 3–5 per cent aqueous emulsion 

that is used in grinding, rough machining and sawing applications (BUA, 1992). Thus 

the concentration of chlorinated paraffin in the final water-based fluid is around 0.2–

0.4% by weight. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 33

An analytical method for determining the presence of chlorinated paraffins in cutting 

fluids and lubricants is available (Randegger-Vollrath, 1998). Among the 37 cutting 

fluids analysed, eight were found to contain short-chain length chlorinated paraffins in 

the concentration range 1–70 per cent, 11 were found to contain medium-chain 

chlorinated paraffins and two were found to contain LCCPs. The cutting fluids analysed 

were obtained from Swiss manufacturers or importers. The type of long-chain 

chlorinated paraffin present could not be identified with the method used. 

A survey of the use of LCCPs by the formulators of metalworking lubricants and cutting 

fluids in the United Kingdom has been carried out (BLF, 2001). The response from the 

survey was low, possibly indicating that the substances are not in widespread use in 

this area. The amounts reported to be used by individual companies ranged between 

one and 20 tonnes per year, and it was estimated that the total usage in the United 

Kingdom would be less than 100 tonnes per year. The main area of application was 

thought to be in die lubricants in the more difficult deep drawing operations. There is, 

however, some uncertainty in this information due to the low response rate in the 

survey. 

A further survey was carried out in 2007 among members of the United Kingdom 

Lubricants Association that were formulators of metalworking lubricants and cutting 

fluids (UKLA, 2007). No use of LCCPs was identified from the replies received in this 

survey. 

For the present assessment it will be assumed that LCCPs are, or could be, used in 

both oil-based and water-based fluids. Recent information from industry has indicated 

that LCCPs are not used in emulsifiable metalworking fluids (Euro Chlor, 2008) 

however, the coverage of the survey is unclear (it is based on the customers of 

members of Euro Chlor but the percentage of customers responding is unclear). 

2.2.7 Use in leather fat liquors 

Chlorinated paraffins are used in fat liquors for leather. They are used in conjunction 

with sulphated or sulphonated oils (Houghton, 1993), chlorosulphonated paraffins, 

natural fats and oils (Euro Chlor, 1998). Typically, chlorinated paraffins with a relatively 

low chlorine content (e.g. ≤40% wt. Cl) are used in these applications. 

In general the chlorinated paraffins are used in leathers for the top end of the quality 

range and give the following advantages (Euro Chlor, 1998): 

• high light-fastness; 

• strong binding to the leather compared to other additives (low migration); 

• dry feel surface finish with excellent suppleness. 

The formulation of leather fat liquors is by a simple mixing process using an enclosed 

system at ambient temperature. The main components of the fat liquor are water, 

natural fats (e.g. fish oils), surfactants and the chlorinated paraffin. The chlorinated 

paraffin accounts for about 10 per cent (range 5–15 per cent) by weight of the 

formulated fat liquor. 

The fat liquor is applied to the leather as a diluted solution. The fat liquoring step is the 

last stage of leather preparation. The amount of fat liquor used in this step is around 7–

12 per cent, based on the shaved weight of the leather to be treated (i.e. around 70–

120 g of fat liquor/kg of leather). Since the fat liquor typically contains around 10 per 

cent (range 5–15 per cent) chlorinated paraffin, the amount of chlorinated paraffin used 
34 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

in this step is around 7–12 g chlorinated paraffin/kg leather (range 3.5–18 g chlorinated 

paraffin/kg leather). The process itself takes place in enclosed rotating drums at 

temperatures in the region of 40–60°C, with each batch taking around 1–4 hours 

depending on the end-product being produced. The pH of the reaction is carefully 

controlled throughout the process by the addition of formic acid to the emulsion (pH is 

changed from around 5.5 at the start to 3.6 at the end of the process). The pH is used 

to affect the nature of the leather surface, the rate of absorption of the fat liquor and the 

stability of the emulsion. The high binding efficiency of the leather for the chlorinated 

paraffin means that the relative composition of the additives in the fat liquor solution 

changes with time during the process. It is believed that not more than two per cent of 

the original amount of chlorinated paraffin is present in the spent fat liquor solution at 

the end of the process (industry estimate based on experience of the process (Euro 

Chlor, 1998)). 

Of the LCCPs, both C18–20 liquid and C>20 liquid chlorinated paraffins are thought to be 

used in leather fat liquors. 

2.2.8 Other uses 

There are several other uses of chlorinated paraffins mentioned in the literature. In 

most of these reports the types of chlorinated paraffins used are not clear, and many 

may refer to historic uses. Some of these are outlined below. If LCCPs are currently 

used in any of these applications then the amounts are likely to be very small. 

2.2.8.1 Plastics other than PVC 

It has been reported that other plastics, such as polyolefins (for example polyethylene 

and polypropylene) may be flame retarded with chlorinated paraffins containing around 

70% wt. Cl. They are used at a concentration of around 3–8 per cent by weight, 

together with antimony trioxide as synergist or in combination with other flame 

retardants (Zitko and Arsenault, 1974; Howard et al., 1975). 

Chlorinated paraffin concentrations of around 4–35 per cent by weight have been 

reported as being suitable for flame retarding plastics based on polystyrene (Zitko and 

Arsenault, 1974). 

Other reported applications of chlorinated paraffins include flame retarding acrylics and 

modacrylics, polyesters, phenolic resins and polyurethane products (Zitko and 

Arsenault, 1974). 

It has been confirmed that European chlorinated paraffin producers do not currently 

supply LCCPs for use in plastics other than PVC, but it is thought that historically, solid 

grades of LCCPs were made in the EU for flame retardant use in electrical equipment 

cases (Euro Chlor, 2001b). 

Most of the available information on these uses refers to chlorinated paraffins in 

general, rather than specifically LCCPs. If there is any current use of LCCPs in these 

applications then they are most likely to be highly chlorinated 70% wt. Cl products that 

are imported into the EU, and the quantity used is likely to be small. The emissions are 

likely to be similar to those associated with PVC and rubber, and so the assessment of 

these uses should also be applicable to any other uses that may occur in polymers. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 35

2.2.8.2 Printing inks 

The European Confederation of Paint, Printing Ink and Artists' Colours Manufacturers' 

Associations (CEPE) operates a voluntary recommendation for the exclusion of certain 

raw materials from printing inks and related products. As part of this, they publish an 

Exclusion List, which has the full support of all its manufacturing members for printing 

inks. Chlorinated paraffin plasticisers are on this exclusion list and so it is very unlikely 

that LCCPs are currently used in this application in the EU. 

2.3 Trends 

About 5,000–10,000 tonnes of LCCPs are used in the EU each year for the years 

1998–2004. A small upward trend in EU consumption is evident over this time period 

but it is possible that at least some of this increase in EU consumption in more recent 

years is related to the expansion of the EU to 25 countries. The main current areas of 

use are as: 

• a secondary plasticiser in PVC; 

• a flame retardant in rubber; 

• a plasticiser/flame retardant in sealants/adhesives and paints; 

• an extreme pressure additive to metal cutting/working fluids; 

• a component of leather fat liquoring treatments; 

• a waterproofing agent for textiles. 

Of these areas, there appears to have been a marked increase in the use of LCCPs in 

rubber, in particular between the years 1999 and 2004 (although a high level of use in 

this area was also evident in 1998); the use of LCCPs in sealants, textiles and leather 

fat liquors has markedly decreased over the same time period. The use of LCCPs in 

the other areas have either increased slightly (plasticiser in PVC) or decreased slightly 

(paints, metalworking lubricants) between 1999 and 2004. 

It is possible that the use of LCCPs in some areas could increase in the future as they 

replace other types of chlorinated paraffins (notably medium-chain chlorinated 

paraffins) for which controls on use are being considered (Entec, 2004). The extent of 

any replacement of medium-chain chlorinated paraffins with LCCPs will depend upon 

the final form of the risk reduction measures taken forward for medium-chain 

chlorinated paraffins, and also any changes to the classification and labelling of 

medium-chain chlorinated paraffin (a proposal for the classification and labelling of 

medium-chain chlorinated paraffins as R64 – may cause harm to breastfed babies – is 

currently being considered (ECB, 2005b)). 

LCCPs have been identified as potential alternatives for medium-chain chlorinated 

paraffins in the following applications: 

• Paints: 

o anti-corrosion primers/topcoats for metals based on PVC-related 

copolymer; 

o Outdoor wall paints, acrylics. 
36 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

• Rubber and polymers other than PVC: 

o conveyor belts and tubes for compressed air in the mining industry; 

o bellows for buses, metro and trains; 

o profiles for fire-proof doors. 

• Leather fat liquors. 

In many cases other (non-chlorinated paraffin) alternatives also exist. 

It should be stressed that at this stage the final form of any risk reduction measures 

needed for medium-chain chlorinated paraffins is still to be decided. 

Industry has also indicated that it is theoretically possible that LCCPs could be used to 

substitute other types of chlorinated paraffins in some applications. However, there are 

technical problems relating to the acceptability of the physical properties. For example, 

for a given chlorine content the viscosities and densities of the LCCPs are higher than 

those of short- and medium-chain length chlorinated paraffins. This difference can be 

overcome in some applications, such as paints, by adding solvent, but this difference 

cannot be easily overcome for most of the applications. In addition, there are economic 

issues relating to substitution as the paraffinic feedstock for LCCPs is more expensive 

than that for other types of chlorinated paraffins. 

For paints and coatings, there is a general move away from chlorinated paraffincontaining products to higher solids/lower VOC alternative coatings such as epoxy 

resins as a result of increased controls on VOC emissions. There is no move within the 

industry to use LCCPs to replace other types of chlorinated paraffins in paints and 

coatings (BCF, 2001). 

For metalworking and cutting fluids, there is a general trend away from the use of 

chlorinated paraffins in general in this area and it is unlikely that the amounts of LCCPs 

used will increase as a result of replacement of other types of chlorinated paraffin (BLF, 

2001). Recent information from industry has indicated that LCCPs are not used in 

emulsifiable metalworking fluids (Euro Chlor, 2008), however, the coverage of the 

survey is unclear (it is based on the customers of members of Euro Chlor but the 

percentage of customers responding is unclear). 

In summary, the available information indicates that LCCPs are not generally being 

seen as possible replacements for other types of chlorinated paraffins. It is possible 

that an increased use of LCCPs could occur in some areas in the future once the 

actual form of the risk reduction measures that will be applied to medium-chain 

chlorinated paraffins are known, but at this stage it is very difficult to estimate what 

potential increase (or otherwise) in the consumption of LCCPs could arise as a result of 

such measures. 

The emission estimation, PEC calculations and risk characterisation in this assessment 

are based on the use pattern of LCCPs in 2004, but assume a consumption of around 

10,000 tonnes/year. This approach allows for a potential future increase in the 

consumption of LCCPs. 

Very recently, confidential information has become available on the use pattern of 

LCCPs in the EU in 2006 (Euro Chlor, 2007). This information arrived too late to be 

taken into account in the emission estimates used in this risk assessment, however the 

trends in these new data are discussed below. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 37

The data show that the total consumption of LCCPs in 2006 has decreased slightly 

compared with 2004. There have been marked decreases in the consumption on 

LCCPs in rubber and PVC plasticisers, and a smaller decrease in the use in 

metalworking lubricants in 2006 compared with 2004. There has been an increase in 

their consumption in water proofing textiles, paints, sealants and adhesives, and 

leather fat liquors in 2006 compared with 2004. 

In terms of the different types of LCCPs, there has been a marked increase in the 

consumption of the C18–20 liquid chlorinated paraffins in 2006 compared with 2004. The 

increase in consumption is in metalworking lubricants, water proofing textiles, paints, 

sealants and adhesives and leather fat liquors. However, there was a marked reduction 

in the use of C18–20 liquid chlorinated paraffins in PVC plasticisers compared with 2004. 

For the C>20 liquid chlorinated paraffins, the consumption for all uses except for paints 

has decreased since the situation in 2004, with the largest decrease occurring in 

rubber. The amount of C>20 liquid chlorinated paraffins used in paints and coatings was 

similar in 2006 to that in 2004. 

For the C>20 solid chlorinated paraffins, there has been a marked decrease in the 

amounts used in both rubber and paints in 2006 compared with 2004. 

2.4 Legislative controls 

There do not currently appear to be any regulations relating specifically to the release 

of LCCPs in the environment. However, as chlorinated hydrocarbons, LCCPs will be 

covered indirectly by discharge consents etc. that are determined in terms of total 

organic carbon (TOC) or total adsorbable chlorine (AOX) content. For example, many 

lubricant blending facilities in the United Kingdom use oil-separation systems to 

achieve levels of oil of <5 mg/l in their discharges, and many leather formulators work 

to AOX levels of <0.5–1 ppm in their discharges. 

In Germany, certain halogen-containing wastes, for example metalworking fluids with 

>2 g halogen/kg and halogen-containing plasticisers, are classified as potentially 

hazardous waste and are incinerated (BUA, 1992). 

In addition to this, the current manufacturers of chlorinated paraffins recommend 

management processes (Euro Chlor, 2001b) for chlorinated paraffins. These are 

shown in Table 2.5. The recovery treatments are strongly recommended by the current 

manufacturers. 
38 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 2.5 Treatment methods currently recommended by Euro Chlor 

Type of waste Preparation for 

disposal/recovery 

Treatment methods 

Recovery e.g.: incineration with 

energy recovery (limiting chlorine 

content to 1 per cent); clean-up 

and re-use. 

Liquid wastes e.g.: oily 

waste from metalworking; 

plasticiser condensates; 

water based mixtures and 

emulsions 

Water separation e.g.: 

thermal splitting; 

ultrafiltration; chemical 

splitting. 

Disposal e.g.: incineration without 

energy recovery; absorb onto 

solids and then landfill. 

Recovery e.g.: incineration with 

energy recovery; re-process 

thermoplastics; grind/chip rubber. 

Solid wastes e.g.: plastics; 

rubber and resins; dried 

sludges from user 

processes. 

Disposal e.g.: incineration without 

energy recovery; landfill 

A number of uses of chlorinated paraffins in general are covered by the Integrated 

Pollution Prevention and Control (IPPC) Directive 1996/61/EC. Depending on the 

quantities involved (Entec, 2004), companies falling under this legislation include: 

• producers of LCCPs; 

• metalworking sites (only large companies in the ferrous and non-ferrous metals 

sectors); 

• some PVC compounding/conversion sites; 

• leather processors (larger sites). 

These sites are covered by the IPPC Directive based on the nature and size of the 

installation rather than on the specific use of chlorinated paraffins. The IPPC Directive 

does, however, place specific requirements on Member States to produce emission 

limit values for organohalogen compounds in general, which would include LCCPs. In 

addition, the “local authority pollution prevention and control regime” in the United 

Kingdom places requirements on the emissions to air from coating processes which 

include spread coating (relevant to the production of PVC wall coatings), as well as 

various other coating processes. These requirements are likely to encompass many 

companies involved in the formulation and application of paints. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 39

3. Environmental exposure 

3.1 Environmental releases 

In this assessment, releases to the environment are considered in various scenarios. 

The background to these different possibilities is explained more fully in the Technical 

Guidance Document (TGD). The local environment is considered to be the 

environment near to a site of release (e.g. a production, formulation or processing site). 

The regional environment is taken to represent a highly industrialised area (the size is 

200 km × 200 km, with 20 million inhabitants); it is assumed that 10 per cent of the total 

EU production and use takes place in this area. The continental environment is the size 

of the EU and is generally used to obtain "background" concentrations of the 

substance. 

In the following sections, releases to the environment have been estimated using both 

the default emission factors given in Appendix 1 of the TGD and industry-specific 

information where available. The industry-specific information is used in preference to 

derive the PECs later in this report. The PECs have been calculated using the EUSES 

program, which implements the methods given in the TGD. The EUSES printout is 

given in Appendix A. 

Some of the information obtained for this assessment, particularly regarding the total 

amounts of LCCPs used in the EU for various applications, is considered as 

confidential. As a result, the raw data do not appear in this report (they are summarised 

in a confidential Annex), but the raw industrial data have been used to derive some of 

the figures used. 

The emission estimates derived in the following sections are based on a total EU 

consumption of LCCPs of 10,000 tonnes/year using the 2004 use pattern data. The 

actual EU consumption in 2004 reported by Euro Chlor is well below this level but there 

are a number of factors that need to be taken into account here. For instance, the 

available information indicates that the actual EU consumption of LCCPs is increasing, 

and the consumption figures available do not take into account any imports of LCCPs, 

neither as the substances themselves nor as components of semi-finished articles. In 

addition, it is also possible that future controls on some uses of other chlorinated 

paraffins (for example those being considered on medium-chain chlorinated paraffins; 

see Section 2.3) may result in increased use of LCCPs as a replacement. The actual 

extent of any possible increase in use of LCCPs in the future as a result of these 

controls is very difficult to predict (particularly as the precise control measures that will 

be applied to medium-chain chlorinated paraffins are unknown at this stage). The use 

of an annual EU consumption value of 10,000 tonnes/year for LCCPs as a basis for 

this assessment allows for an approximately 25 per cent increase in their use in the 

future compared with the known consumption in 2004. 

3.1.1 Releases from production 

There is no production of LCCPs in the United Kingdom. Information on European 

production sites is given in the confidential annex. 
40 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

3.1.1.1 Default release estimate 

Default release estimates for production can be obtained using the emission factors 

contained in Appendix 1 of the TGD. These are carried out for a typical production site, 

assuming a production of around 5,000 tonnes/year as an example. 

The default emission factors (Table A1.1 of Appendix 1 of the TGD; Main Category 1c; 

vapour pressure <1 Pa) are 0 to air and 0.003 (0.3 per cent) to waste water for all types 

of LCCPs. The number of days of release can be estimated as 300 (Table B1.1 of 

Appendix 1 of the TGD). 

Therefore, using these figures, the default release estimates for a 5,000 tonnes/year 

production site are: 

 

 0 kg/day to air 

 100–200 kg/day to waste water (over 300 days). 

3.1.1.2 Industry-specific release information 

Mukherjee (1990) reported that chlorinated paraffin emissions from a production plant 

in Germany were around 0.1 g/kg of product, based on an air concentration of around 

30 mg/Nm3

, presumably in the exhaust gases. BUA (1992) gives an atmospheric 

emission of around 250 kg/year of chlorinated paraffin for Germany in the form of dust 

and vapour. It is not known which type of chlorinated paraffin these figures refer to. 

Emissions to water at a German plant manufacturing solid chlorinated paraffins have 

been reported by BUA (1992). The effluent from the plant (prior to waste water 

treatment) was thought to contain around 1 kg/year of chlorinated paraffin. 

More recent emission data have been provided for an LCCP production site in the EU. 

The data supplied are confidential but an emission factor to waste water of 1.3–19 

g/tonne of product can be derived from this information (the data are summarised in a 

confidential Annex). This factor will be used to calculate the emissions from a generic 

site producing 1,000 tonnes/year of C18–20 liquid chlorinated paraffins, 

5,000 tonnes/year of C>20 liquid chlorinated paraffins and 100 tonnes/year of C>20 solid 

chlorinated paraffins, over 300 days/year. 

C18–20 liquid Local release: 19 kg/year or 0.063 kg/day to waste water 

C>20 liquid Local release: 95 kg/year or 0.32 kg/day to waste water 

C>20 solid Local release: 1.9 kg/year or 0.0063 kg/day to waste water 

3.1.1.3 Transportation losses 

In theory, chemicals can be released to the environment during loading of transport 

containers at production sites and unloading of containers at the sites where the 

substance is used. These losses can take the form of spillages (to waste water) or 

volatilisation losses. LCCPs have very low vapour pressures at ambient temperatures 

and so any losses to the atmosphere should be negligible from loading or emptying 

containers. Losses to waste water could occur but these are considered as part of the 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 41

general losses from production sites and sites of use (e.g. formulation sites) and are 

already included in the release estimates reported and so are not considered 

separately here. 

3.1.2 Release from use in PVC 

LCCPs are used as (secondary) plasticisers in PVC. The main types currently used are 

the C18–20 products, although small amounts of C>20 liquid products may have also been 

used in the recent past. 

Chlorinated paraffins are usually added at 10–15 parts per hundred resin (phr), 

although some of the more highly chlorinated substances (e.g. >52% wt. Cl) are more 

compatible with PVC and can be used at around 25 phr, for example in a cable 

compound. Taking into account the other additives present in the PVC such as primary 

plasticiser, filler, stabiliser, lubricant etc., these loadings on a resin basis equate to a 

chlorinated paraffin content of around 6–10 per cent by weight, based on the PVC 

compound for the typical 10–15 phr loading and 15 per cent by weight based on the 25 

phr loading. The higher loadings are generally found in extrusion compounds with the 

lower loadings being used in PVC for coating processes. 

Based on the above information, an LCCP content of 10–15 per cent by weight of the 

PVC compound/product is a reasonable worst case value, with a lower limit of around 

six per cent by weight of the PVC. 

3.1.2.1 Default release estimate 

Appendix 1 of the TGD gives default release estimates for substances used in the 

polymers industry. The release factors for plasticisers (Use Category 47) during the 

polymer processing step for thermoplastics are 0.005 (0.5 per cent) to air (vapour 

pressure <1 Pa; estimated boiling point ≥400°C) and 0.001 (0.1 per cent) to waste 

water (Table A3.11 of Appendix 1 of the TGD). The same default emission factor would 

apply to all types of LCCPs. 

Based on the available data, the amount of PVC produced (in the regional model) 

containing LCCPs is estimated at 350–520 tonnes/year for the C18–20 liquid type, 

assuming that production of PVC is widespread throughout the EU. Using Table B3.9 

of Appendix 1 of the TGD, the amount of PVC containing LCCPs produced on a site 

can be estimated at between 78 tonnes/year over 31 days and 88 tonnes/year over 35 

days. 

Using the base figures given above, the following default release estimates can be 

calculated: 

C18–20 liquid Local release: 39–66 kg/year or 1.3–1.9 kg/day to air 

 8–13 kg/year or 0.25–0.37 kg/day to waste water 

 Regional release: 262 kg/year to air 

 52 kg/year to waste water 

 Total EU release: 2,620 kg/year to air 

 520 kg/year to waste water 
42 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

3.1.2.2 Industry-specific release information 

The Emission Scenario Document (ESD) on plastics additives (OECD, 2004b) 

considers the possible release of additives from their use in PVC. Around 220,000 

tonnes/year of flexible PVC is produced in the United Kingdom in closed, partially open 

and open systems, depending on the processing method used to produce the final 

product. Thus possible releases of LCCPs from many different processes have to be 

considered. According to the OECD (2004b), the worst case amounts of flexible PVC 

processed at a site are 744 tonnes/year for a site using open processing systems, 

3,990 tonnes/year for a site using partially open processing systems and 341 

tonnes/year for a site using closed processing systems. These are based on the known 

production volume of flexible PVC in the United Kingdom, along with information on the 

number and size distribution of production sites. 

In the following calculations it will be assumed that all the flexible PVC produced at a 

site contains LCCP at either 10 per cent by weight (for coating processes) or 15 per 

cent by weight (for extrusion and other processes). 

The amounts of LCCPs estimated to be used on a polymer processing site using the 

OECD (2004b) methodology are shown in Table 3.1. 

Table 3.1 Estimated amounts of LCCPs used at flexible PVC processing sites 

Type of 

processing 

Amount of PVC 

processed 

Estimated amount of LCCPs used per site 

10% LCCP in resins 

(coating processes) 

15% LCCP in resins 

(extrusion/other 

processes) 

Open system 744 tonnes/year 74.4 tonnes/year 112 tonnes/year 

Partially open 

system 

3,990 tonnes/year [399 tonnes/year]a 599 tonnes/year 

Closed system 341 tonnes/year [34.1 tonnes/year]a 51 tonnes/year 

Note: a Coating processes are usually carried out in open systems as defined in 

OECD (2004b). 

The estimates for the amount of LCCPs used at a worst case site given in Table 3.1

are much higher than those obtained using the Technical Guidance Default values. In 

particular, the amount estimated to be used at a site operating a partially open process 

is actually higher than the known total EU usage of LCCPs in PVC. This discrepancy 

probably arises because LCCPs are not the major chlorinated paraffin used in PVC 

(medium-chain chlorinated paraffins have a much higher usage) and so as a result, it is 

very unlikely that a large PVC production site will use only LCCPs in production of PVC 

(as is assumed in the calculations in Table 3.1) and most of the PVC produced at the 

site will contain medium-chain chlorinated paraffins. 

In terms of the local risk assessment, the most relevant information is the daily amount 

of LCCP used at a worst case site. Table 3.2 gives a comparison of the values 

obtained by using the OECD (2004b) methodology (processing occurs over 300 days) 

and the default methodology given in the TGD. As can be seen, there is general 

agreement between the two methods when the estimates are expressed as a daily 

usage rate. Therefore, in this current assessment the daily usage rates obtained from 

the OECD (2004b) method will be used, along with the number of days obtained from 

the default Technical Guidance Method. This approach then takes into account the fact 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 43

that a large PVC site will only use LCCPs in a proportion of the PVC made at the site 

(i.e. although PVC will be produced every day at the site, LCCPs will only be used on a 

few occasions during the year), which is in line with the known relative amounts of 

medium- and long-chain chlorinated paraffins used in this application. 

Table 3.2 Comparison of estimates for the daily worst case amounts of 

LCCPs used on a PVC processing site 

Type of 

processing 

Daily amount of C18–20 liquid chlorinated 

paraffin used on a site (tonnes/day) 

Estimated number of 

days (TGD method) 

 OECD (2004b) 

estimate 

TGD default estimate 

Open system 0.25 – coating 

processes 

0.37 – extrusion/other 

processes 

0.22–0.38 31–35 days 

mid point – 33 days 

Partially 

open system 

2.0 – extrusion/other 

processes 

0.22–0.38 31–35 days 

mid point – 33 days 

Closed 

system 

0.17 – extrusion/other 

processes 

0.22–0.38 31–35 days 

mid point – 33 days 

The following sections estimate LCCP releases during the different steps of PVC 

processing. 

Raw materials handling (formulation – step 1) 

The LCCPs typically used in PVC in the EU are liquids of low vapour pressure. Losses 

to the atmosphere are likely to be negligible when the substance is handled at ambient 

temperature. The liquid plasticisers are usually transported and handled in bulk, using 

enclosed storage systems and so a minimal loss by spillage can occur. The worst case 

release figure for loss through spillage is estimated at 0.01 per cent (OECD, 2004b). 

Using this release figure and the information discussed above, the release to the 

environment from sites using the various processing types can be estimated as follows: 

C18–20 liquid Open processing: coating 0.025 kg/day over 33 days 

(0.83 kg/year) 

 extrusion/other 0.037 kg/day over 33 days 

(1.2 kg/year) 

 Partially open 

 processing: extrusion/other 0.2 kg/day over 33 days 

 (6.6 kg/year) 

 Closed processing: extrusion/other 0.017 kg/day over 33 days 

 (0.56 kg/year) 

Based on the total EU usage of LCCPs in this application, the total EU emission from 

this source can be estimated as 52 kg/year for the C18–20 products. According to the 

TGD, the regional releases are 10 per cent of these figures, i.e. 5.2 kg/year, assuming 

the processing of PVC is widespread throughout the EU. 
44 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

As these release figures refer to spillage, the release can be assumed to enter the 

waste water stream as a worst case approach. 

Compounding (formulation – step 2) 

There are two general methods used for compounding PVC: dry blending and plastisol 

blending (OECD, 2004b; see Section 2.2.1 for further details). 

Dry blending is used to prepare blends for extrusion, injection moulding and sometimes 

calendering (Banbury blending is also occasionally used to prepare blends for 

calendering, but the emissions from this process are similar to those associated with 

dry blending (OECD, 2004b)). 

Dry blending accounts for the compounding of around 65–70 per cent of all plasticisers 

used in PVC. Dry blending involves mixing the PVC powder/granules with the 

plasticiser using a high speed rotating agitator which heats the material by friction (the 

maximum temperature reached is 100–120°C). The plasticiser is completely absorbed 

by the PVC in the process, and the only source of release to air is from the hot 

material. 

The loss to air of a plasticiser such as di-(2-ethylhexyl) phthalate (DEHP) from the 

process is estimated to be a maximum of 0.01 per cent. The vapour pressure of DEHP 

is around 2.2×10-5 Pa at 20°C and so DEHP can be considered to be of somewhat 

lower volatility than the C18–20 liquid chlorinated paraffins (approximate estimated 

vapour pressure 2.5×10-4 Pa at 25°C) but of similar volatility to the C>20 liquid 

chlorinated paraffins (approximate estimated vapour pressure 2.5×10-5 Pa at 25°C), 

taking into account the small difference in temperature between the DEHP data and the 

LCCP data. When considering these comparisons, it should be born in mind that there 

is considerable uncertainty over the actual vapour pressures of LCCPs (see Section 

1.4.4). 

Other information is available that allows a comparison to be made of the relative 

volatility of LCCPs to that of DEHP. These data refer to the weight loss on heating the 

plasticisers for four hours. The data for LCCPs are discussed in detail in Section 1.4.4 

and are summarised below in Table 3.3, along with the data obtained for DEHP under 

similar conditions (Euro Chlor, 1999). 

Table 3.3 Weight loss on heating plasticisers and LCCPs for four hours at 

180°C 

Substance Weight loss after heating for 4 hours at 

180°C 

DEHP 1.9% 

C18–20, 47–48% wt. Cl 0.8–1.6% 

C18–20, 50–52% wt. Cl 0.7–1.3% 

C>20, 42% wt. Cl 0.4–0.5% 

C>20, 48% wt. Cl 0.3–0.4% 

From these data it can be seen that at an elevated temperature the C18–20 liquid 

products appear to be around 1.2–2.7 (typically around 2.5) times less volatile than 

DEHP and the C>20 liquid products around 3.8–6.3 (typically around five) times less 

volatile than DEHP. It should also be born in mind that some of the weight loss seen 

with the chlorinated paraffins will be due to evolution of HCl from decomposition of the 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 45

chlorinated paraffin at the elevated temperature used (the weight loss from HCl 

formation was generally around 0.2 per cent under similar conditions; see Section 

1.4.4) and so these values probably represent the upper limits of the relative volatilities. 

Although these data are not directly comparable with the losses expected from the dry 

blending process, they do provide some experimental indication of the relative volatility 

of the LCCPs compared with DEHP. Given the uncertainties over the actual vapour 

pressure of LCCPs, these data are used here in preference to comparisons of relative 

volatility based on the vapour pressures of DEHP and LCCPs. In terms of the actual 

volatility from PVC, the relative volatility of the plasticisers will also depend to some 

extent on their compatibility (or solubility) in the PVC. As discussed in Section 2.2.1, 

the compatibility of the chlorinated paraffin with both PVC and the primary plasticiser 

varies with both the carbon chain length and degree of chlorination. 

Based on the available experimental weight loss data, it appears that both the C18–20

liquid products and the C>20 liquid products are less volatile from PVC than DEHP (by a 

factor of 2.5 and 5, respectively). Therefore the DEHP emission factor of 0.01 per cent 

to air will be reduced to 0.004 per cent for the C18–20 liquid products (the equivalent 

factor for the C>20 liquid products would be 0.002 per cent but there is no current use of 

this type of chlorinated paraffin in PVC). 

Approximately 30–35 per cent of all plasticiser use in PVC is in plastisol applications. 

Plastisol blending takes place in stirred vessels at ambient temperature. Cooling is 

used to remove any heat generated by friction. The releases to the air from this 

process are thought to be negligible due to the lower temperatures involved. Losses 

due to the handling of raw materials in this process are covered in the previous section 

(Raw materials handling). 

The estimated worst case emissions to air of LCCPs from the dry blending process are 

shown below. 

C18–20 liquid Open processing: extrusion/other 0.015 kg/day over 33 days 

 (0.49 kg/year) 

 Partially open 

 processing: extrusion/other 0.080 kg/day over 33 days 

 (2.6 kg/year) 

 Closed processing: extrusion/other 0.0068 kg/day over 33 days 

 (0.22 kg/year) 

The releases to air from plastisol blending for coating processes are negligible. 

Using the above emission factors, and assuming that 70 per cent of the LCCPs are 

used in dry blending processes (i.e. the same as for PVC plasticisers in general), then 

the total EU release from this source can be estimated as 14.6 kg/year for the C18–20

liquid products. The regional release will be taken to be 10 per cent of these figures 

(1.5 kg/year for the C18–20 liquid products). These releases are initially to the air. 

Conversion (processing) 

This section considers the releases from several processing methods. The release 

estimates assume that some fume reduction equipment is used. Such equipment is 

generally found at large sites (using >250 tonnes of plasticiser/year). The equipment is 

less common at smaller plants (using <250 tonnes of plasticiser/year) and the releases 

for some processes could be around 10 times higher at plants where fume reduction 
46 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

equipment is not present. The 250 tonne plasticiser limit is considered to be a 

reasonable criterion to distinguish between larger and smaller plants (OECD, 2004b). 

This figure refers to the total plasticiser used in the flexible PVC (as discussed earlier, 

chlorinated paraffins are generally used as secondary plasticisers along with other 

plasticisers such as DEHP, and chlorinated paraffins other than long-chain are used for 

the bulk of this application). 

According to the OECD (2004b), the typical total plasticiser level in flexible PVC is 30–

50 per cent. Thus 250 tonnes/year plasticiser is equivalent to a production of around 

500–830 tonnes/year of flexible PVC. As can be seen from the figures reported in 

Table 3.1, the sites with open and partially open system are generally large (and so 

use fume reduction equipment ), whereas sites with closed systems fall into the size of 

site where fume reduction equipment may not always be used. The following sections 

describe the possible losses to the environment from the various processes. The 

resulting release estimates are summarised in Table 3.4. 

Calendering (open system) 

A reasonable worst case emission of plasticiser (e.g. DEHP) from a calendering 

process is around 0.05 per cent to air. From the above discussion, it is suggested that 

this emission factor is reduced by a factor of around 2.5 for C18–20 liquid chlorinated 

paraffins (and by a factor of around 5 for C>20 liquid chlorinated paraffins) to take 

account of their lower volatilities compared to DEHP. This adjustment gives an 

emission factor of 0.02 per cent for the C18–20 chlorinated paraffins (the equivalent 

factor for the C>20 liquid chlorinated paraffins would be 0.01 per cent). This figure 

assumes that emission reduction equipment is used (OECD, 2004b). For sites with no 

emission reduction equipment the emission factor could be expected to be around a 

factor of 10 higher than this figure. 

Extrusion (partially open or closed system) 

The major types of flexible PVC products produced by extrusion are wire, cable and 

hoses, and blow-moulded film. For wire, cable and hose production there is no 

emission/exposure from the extruder itself. The main source of release is likely when 

the hot material leaves the die. As the surface area and exposure time (of the hot 

plastic to air) is lower than for calendering processes, an emission factor of 0.01 per 

cent to air is estimated for a typical plasticiser (e.g. DEHP) (OECD, 2004b). Taking into 

account the lower volatility of LCCPs, the equivalent emission factor is 0.004 per cent 

for C18-20 liquid products (and 0.002 per cent for C>20 liquid products). This emission 

factor assumes that emission reduction equipment is used. For applications where this 

equipment is not generally used, the emission factors may be around 10 times higher 

than these values (i.e. 0.04 per cent for C18–20 liquid products). 

Injection moulding (closed system) 

Injection moulding can be considered to be comparable to extrusion except that both 

the moulding and cooling phases of the process take place in closed systems. 

Therefore, emissions should be lower than for extrusion processes. However, as a 

worst case OECD (2004b) recommends an emission factor of 0.01 per cent to air for a 

general plasticiser such as DEHP. Again, for the less volatile LCCPs, this figure can be 

reduced by a factor of around 2.5 for a C18–20 liquid chlorinated paraffin, giving an 

emission factor of 0.004 per cent (the equivalent emission factor for a C>20 liquid 

chlorinated paraffin would be 0.002 per cent). For applications where this equipment is 

not generally used, the emission factors may be around 10 times higher than this value 

(i.e. 0.04 per cent for C18–20 liquid products). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 47

Plastisol spread coating (open system) 

Spread coating products include articles such as cushioned flooring, wall coverings, 

tarpaulins etc. These products are gelled in tunnel ovens heated with hot air at about 

180°C. The emission factor for a typical plasticiser such as DEHP from the process is 

around one per cent to air within the oven, based on both calculation and laboratory 

experiment (OECD, 2004b). This figure refers to the air leaving the equipment. Not all 

of this reaches the environment since condensation takes place in cooler pipes, ducts 

and stacks. Air treatment is thought to be relatively common within the industry (75 per 

cent of the activity in 1989 had air treatment and the figure was approaching 100 per 

cent in 1998 (OECD, 2004b)). 

Two types of air treatment are used: air filtration which typically removes 95 per cent of 

the plasticiser in the air; and incineration. Thus the overall emission factors for a typical 

plasticiser such as DEHP are estimated at between 0 and 0.05 per cent to air for the 

vast majority of sites with air emission treatment and 0.5 per cent to air for a site with 

no air emission treatment (OECD, 2004b). For the less volatile C18–20 chlorinated 

paraffins, these factors can be reduced by a factor of 2.5. This gives emission factors 

for C18-20 liquid products of 0-0.02 per cent to air for sites with air emission treatment 

and 0.2 per cent to air for sites with no air emission treatment (the equivalent factors for 

the C>20 liquid products would be 0-0.01 per cent to air and 0.1 per cent to air for sites 

with and without air emission treatment respectively). 

Other plastisol processes 

Other processing methods for plastisol PVC include car body coating and sealing, 

rotational coating, dipping and slush moulding. Of these, car underbody coating and 

sealing is the most important in terms of volume, but it is thought that chlorinated 

paraffins are not used in this application. In these processes, the coatings are dried in 

long air-heated tunnel ovens at temperatures of 130-160°C. The ovens in this industry 

have integrated air incinerators since the same process is used to simultaneously dry 

paint coats (OECD, 2004b). Therefore, the releases of LCCPs from this process, if they 

are used, should be near zero. 

The other possible plastisol processing steps are all small volume applications. The 

releases from dip coating and slush moulding are likely to be similar to those from 

spread coating and so will not be considered separately in the release estimation. 

Rotational moulding takes place in closed moulds and so the loss of long-chain 

chlorinated paraffin to the atmosphere from this process will be low. 

Summary of worst case release estimates from PVC conversion (processing) 

The estimated worst case releases of LCCPs to air from plastic processing obtained for 

various types of processes using the above information are shown in Table 3.4. As can 

be seen from the emission estimates, the actual releases from the various sites are 

very similar. Although the overall emission factors at large sites may be lower than at 

small sites owing to the use of emission controls on air releases, larger sites also 

process a larger quantity of plastics, so the overall emissions are roughly the same. 

The actual breakdown of the use of LCCPs between the various processes is 

unknown. However, the OECD (2004b) gives the following breakdown of the 

production of flexible PVC: 25 per cent in closed systems; 49 per cent in partially open 

systems and 26 per cent in open systems. 

If the same approximate breakdown applies to the use of LCCPs, then the total EU 

emissions from polymer processing can be estimated as 427 kg/year to air for C18-20

liquid products (assuming an emission factor of 0.2 per cent from open systems and 
48 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

0.04 per cent from partially open and closed systems). This figure assumes that no air 

emission control is applied. In Section 2.2.1 information is reported indicating that at 

least 50 per cent of the LCCPs are likely to be processed at sites with exhaust air 

treatment. The estimated emissions from these sites would be a factor of 10 lower, 

leading to total emissions from all sites of around 235 kg/year to air for C18-20 liquid 

products, assuming that 50 per cent of the sites have such exhaust air treatment. The 

actual overall proportion of the industry with such controls is currently unknown, but the 

use of such equipment is relatively commonplace, particularly at large sites, and is 

becoming increasingly common at other sites. Based on this, the total EU emission 

from this source will be taken as 235 kg/year for the C18–20 liquid chlorinated paraffins. 

The regional release will be taken as 10 per cent of the total EU release as 

recommended in the TGD.
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 49

Table 3.4 Estimated worst case emissions of C18–20 liquid chlorinated paraffins to air fro

Release factor to air 

Process Type of 

system Air emission 

control 

No air emission control 

Amount of chlorinated paraffin used used per site (kg/day) 

Number of days of use (days/year) A

c

Calendering open 0.02% 0.2% 370 33 0

(2

partially open 0.004% 0.04% 2,000 33 0

(2

Extrusion 

closed 0.004% 0.04% 170 33 - 

Injection moulding 

closed 0.004% 0.04% 170 33 - 

Plastisol spreadcoatinga

open 0.02% 0.2% 250 33 0

(

Notes: a Release from other plastisol processes such as dip coating and slush moulding is expected to be si

such as car underbody coating and sealing (if LCCPs are used), and rotational moulding are thought 

b In the PEC calculations it will be assumed that 50 per cent of the air emissions eventually reach wac Taken to represent a small site using closed processing where fume reduction equipment may not a
50 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

According to the OECD (2004b), the releases to air are as hot gases. For substances 

with low vapour pressures such as LCCPs, the possibility of condensation of the hot 

gases needs to be considered. This may lead to some of the releases initially entering 

other waste streams such as water due to cleaning etc. OECD (2004b) gives no 

guidance as to the fraction of the air release that could eventually end up in other 

effluent/waste streams. As a worst case approach, it could be assumed that 50 per 

cent of the release to air would eventually reach waste water. In the absence of other 

information, this assumption will be used later in the PEC calculations. 

3.1.3 Release from use as a plasticiser/flame retardant in rubber 

Information provided by industry indicates that both C>20 liquid and C>20 solid 

chlorinated paraffin products are used as plasticisers/flame retardants in rubber and 

textiles. 

LCCPs are used as flame retardant softeners (or process oils) in rubber. The estimated 

amount of rubber containing LCCPs produced in a region of the EU is estimated as 

4,175–8,350 tonnes/year (C>20 liquid chlorinated paraffin) and 207–414 tonnes/year 

(C>20 solid chlorinated paraffins), assuming that production of rubber is widespread 

throughout the EU. 

3.1.3.1 Default release estimation 

Appendix 1 of the TGD gives default release estimates for substances used in the 

polymers industry. No specific release factors are given for the rubber industry. 

However, since the processes involved for both rubber and plastic are generally similar 

(in that they both use a compounding step involving mixing of the flame retardant with 

plastic or rubber, followed by a shaping/curing operation involving heat), Table 3.11 of 

Appendix 1 of the TGD will be used for the default release estimation. From this table, 

the release factors for flame retardants (Use Category 22) during polymer processing 

for thermoplastics are 0.0005 (0.05 per cent) to air (boiling point ≥300°C; vapour 

pressure <1 Pa) and 0.0005 (0.05 per cent) to waste water for both the C>20 liquid and 

solid chlorinated paraffins. For thermosetting resins, the release factor to air is zero and 

the release factor to waste water is 0.0005 (0.05 per cent). 

The estimated amount of rubber containing LCCPs produced in a region of the EU is 

estimated as 4,175–8,350 tonnes/year (C>20 liquid chlorinated paraffin) and 207–

414 tonnes/year (C>20 solid chlorinated paraffins), assuming that production of rubber is 

widespread throughout the EU. Using Table B3.9 of Appendix 1 of the TGD, the 

amount of rubber containing LCCPs produced on a site would be 626–835 tonnes/year 

over 251–300 days/year for the C>20 liquid chlorinated paraffins and 51.8–103.5 

tonnes/year over 21–41 days/year for the C>20 solid chlorinated paraffins. The amount 

of LCCP used to produce this amount of rubber would be 41.8 (over 300 days) or 62.6 

tonnes/year (over 251 days) for the C>20 liquid chlorinated paraffin and 5.2 tonnes/year 

(over 21–41 days) for the C>20 solid chlorinated paraffin. 

Based on the above figures, the following default release estimates can be made for 

the LCCPs emitted: 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 51

C>20 liquid Local release: 20.9–31.3 kg/year or 0.070–0.12 kg day to air 

20.9–31.3 kg/year or 0.070–0.12 kg/day to waste 

water 

 Regional release: 209 kg/year to air 

 209 kg/year to waste water 

 Total EU release: 2,088 kg/year to air 

 2,088 kg/year to waste water 

C>20 solid Local release: 2.6 kg/year or 0.063–0.12 kg/day to air 

 2.6 kg/year or 0.063–0.12 kg/day to waste water 

Regional release: 10.4 kg/year to air 

 10.4 kg/year to waste water 

 Total EU release: 104 kg/year to air 

 104 kg/year to waste water 

3.1.3.2 Industry-specific release information 

A recent survey of rubber manufacturers in the United Kingdom indicated that releases 

of chlorinated paraffins from the process were thought to be very low, although no 

quantitative data were provided (BRMA, 2001). 

An estimate for the release to the environment from use of chlorinated paraffins in 

rubber has been reported in Government of Canada (1993). This gave a Swedish 

estimate for the total release from the process as <0.001 per cent of that used. No 

indication as to whether this was a release to waste water or air was given. 

Another source of potentially useful information is the ESD on plastics additives 

(OECD, 2004b). This details possible releases to the environment from the use of 

flame retardants in plastics. Although the processing (curing/vulcanisation) of natural 

and synthetic rubber take place at lower temperatures (e.g. 125–150°C) than for many 

polymers, the same sorts of processes as for plastics (e.g. injection moulding, 

extrusion, calendering etc.) can be used (Bouton, 1992; Kirk-Othmer, 1997). Therefore, 

as the compounding and subsequent processing of plastics are essentially similar to 

those of rubber, a similar (but possibly smaller) release would be expected from use of 

an additive in rubber than is found in plastics. 

Raw materials handling (formulation – step 1) 

Both C>20 liquid and solid chlorinated paraffins may be used in rubber. Volatile losses to 

the atmosphere during handling at ambient temperatures are likely to be negligible for 

both types. According to the OECD (2004b), liquid additives are usually transported 

and handled in bulk, using enclosed storage systems and so minimal loss by spillage 

can occur. The worst case release figure for loss through spillage is estimated at 0.01 

per cent. 

For solid materials of particle size >40 μm a worst case release figure of 0.2 per cent to 

solid waste/water is recommended as a result of dust generation etc. The long-chain 

solid chlorinated paraffins are generally reported to be "waxy" solids and so the 

potential for dust generation may be lower than indicated by this figure. Initially these 

emissions will be to the atmosphere, but eventually the particles will be removed or 

settle and so ultimately losses will be to solid waste or waste water. As a worst case it 

could be assumed that all the release occurs to waste water. 
52 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Compounding (formulation – step 2) 

Compounding is usually a dry process, where the base polymer and additives are 

mixed together. For plastics, the mixing process generates heat or is heated externally 

and so there is a potential for volatilisation from the process. This volatilisation loss is 

estimated at 0.002 per cent for organic flame retardants (OECD, 2004b). As this loss 

occurs as hot gas, there is a potential for subsequent condensation of the flame 

retardant and so it may also enter other waste streams as a result of cleaning etc. 

Similar to the case with PVC, it will be assumed that this loss is eventually split 50:50 

between air and water, giving a release factor of 0.001 per cent to air and 0.001 per 

cent to waste water for both the solid and liquid LCCPs. 

In addition to the loss by volatilisation, the solid LCCPs may be susceptible to dust 

generation during the compounding process. This loss is estimated at 0.01 per cent for 

powders of particle size >40 μm. Initially this loss will be to air, but ultimately it will be to 

solid waste or waste water as a result of settling/cleaning within the factory. As a worst 

case it could be assumed that all this loss eventually occurs to waste water. 

Conversion (processing) 

The OECD (2004b) gives the loss to the atmosphere of organic flame retardants from 

the conversion of plastics to be 0.01 per cent from open processes, 0.006 per cent 

from partially open processes and 0.002 per cent from closed processes. These 

releases will occur initially to air. Similar to the case with PVC, to take into account the 

possible condensation of the substance (and subsequent cleaning loss) it will be 

assumed that 50 per cent of the releases initially to air will enter into waste water and 

50 per cent will remain in the air. 

Overall emission factor 

Based on the worst case emission figures derived from the OECD (2004b), the overall 

loss of LCCP from the production of rubber can be estimated at up to 0.016 per cent to 

waste water and 0.006 per cent to air for C>20 liquid chlorinated paraffin products4

 and 

0.206 per cent to waste water and 0.006 per cent to air for C>20 solid chlorinated 

paraffins. The loss to waste water for the solid chlorinated paraffins is dominated by the 

solid losses (dust generation) at the raw materials handling stage. As indicated earlier, 

the solid chlorinated paraffins are generally described as "waxy" solids and so may be 

much less susceptible to dust generation than is indicated by these calculations. 

The other emission factors available are <0.001 per cent (compartment unknown) 

reported by the Government of Canada (1993) and the default emission factors from 

the TGD of 0.05 per cent to air and 0.05 per cent to waste water. The basis of these 

figures is unknown. The figure reported by the Government of Canada (1993) is much 

lower than estimated using the approach outlined by the OECD (2004b) and may 

indicate that, due to the generally lower processing temperatures involved, the losses 

of flame retardant from rubber manufacturing are lower than those associated with the 

manufacture of plastic. However, it is not clear if this emission factor also includes the 

possible contribution from dust generation or spillage of raw materials and so the 

figures derived from the OECD (2004b) will be used in the risk assessment as a worst 

 

4

 These emission factors are those recommended in OECD (2004b) for a flame 

retardant. As discussed in Section 3.1.2, similar factors for the C>20 liquid products 

could also be derived if based on the emissions as a plasticiser. In this case the factors 

would be 0.01 per cent to waste water from spillage; 0.001 per cent to air; 0.001 per 

cent to waste water from compounding; 0.001-0.005 per cent to air; and 0.001-0.005 

per cent to waste water from conversion. The overall emission factor would again be 

0.016 per cent to waste water and 0.006 per cent to air. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 53

case, recognising the potential problems in extrapolating data on processing of plastics 

to rubber processing. 

The previously estimated default amounts of LCCPs that are used on a rubber 

production site (62.6 tonnes/year over 251 days for the C>20 liquid chlorinated paraffin 

and 5.2 tonnes/year over 21 days for the C>20 solid chlorinated paraffin) are reasonably 

consistent with the available figures for the amounts of chlorinated paraffins that are 

used on sites in the United Kingdom (see Section 2.2.2), given that there appears to 

have been an increase in the use of LCCPs in this area in recent years. These values 

will be used as the basis for the realistic worst case release estimates. Using these 

data, the following release estimates can be obtained: 

C>20 liquid Local release: 3.8 kg/year or 0.015 kg/day to air 

 10.0 kg/year or 0.040 kg/day to waste water 

 Regional release: 25.1 kg/year to air 

 66.8 kg/year to waste water 

Total EU release: 251 kg/year to air 

 668 kg/year to waste water 

C>20 solid Local release: 0.31 kg/year or 0.015 kg/day to air 

 10.7 kg/year or 0.51 kg/day to waste water 

Regional release: 1.2 kg/year to air 

 42.6 kg/year to waste water 

 Total EU release: 12.4 kg/year to air 

 426 kg/year to waste water 

3.1.4 Release from use as a plasticiser/flame retardant in 

sealants/adhesives 

The main function of chlorinated paraffins in sealants/adhesives is as a plasticiser 

and/or flame retardant. The main types of LCCP used in sealants/adhesives are the 

C18–20 liquid and C>20 liquid products. The estimated amount of sealant/adhesive 

containing LCCPs produced in a region in the EU is around 175–262 tonnes/year for 

the C18–20 liquid chlorinated paraffins and 354–531 tonnes/year for the C>20 liquid 

chlorinated paraffins. 

3.1.4.1 Default release estimation 

No default release figures are given in the TGD for this use. 

3.1.4.2 Industry-specific information 

Information on the manufacture of sealants containing medium-chain chlorinated 

paraffins was reported in the risk assessment of that substance (ECB, 2005a) and 

forms the basis for the assessment here along with information obtained from industry 

on LCCPs. 

Sealants are produced by mixing the required additives with a viscous liquid polymer. 

Both low and high shear mixers may be used, depending on the surface area of the 

filler component used in the formulation (Palmer and Klosowki, 1997). As most 
54 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

sealants are moisture sensitive (particularly the one-part sealants), water is unlikely to 

be used in the process and so release to waste water is likely to be very low. 

Chlorinated paraffins are used in both one-part and two-part sealants, and similar 

methods are used to produce both types (ECB, 2005a). Typically, sealants are 

produced in a batch process of around 1,000 kg at a time. The process is simple 

mixing, sometimes under gentle heat (e.g. up to around 40°C) and is usually carried 

out under vacuum to avoid moisture entering the process. Once formulated, the sealant 

is pumped directly from the mixing vessel to fill cartridges (e.g. for one-part sealants) or 

tins (e.g. for two-part sealants). 

Typically, one to two tonnes of sealant containing chlorinated paraffin would be 

manufactured at a site per week (ECB, 2005a). Losses to waste water during the 

manufacture of sealants are reported to be low or zero as water is not used in the 

process (most sealants are moisture sensitive). Solid waste can be generated during 

the process and this may be up to five per cent of the amount of sealant produced as a 

result of machine cleaning or scrap material. Cleaning between batches is minimised 

by the use of dedicated equipment or by starting with the formulation of light coloured 

product and progressing through to darker coloured products. Generally, the solid 

waste material is removed from the equipment by hand. Solvent cleaning of the 

equipment can also occur. These solvents are collected and disposed of at the end of 

their useful life by registered waste contractors. 

Due to the physico-chemical properties of LCCPs, they are likely to be associated with 

the solid waste phases during the cleaning of equipment and so releases to waste 

water from the process are likely to be very low (the release to water due to leaching 

from the sealant is considered in Section 3.1.9). 

Some sealants (e.g. one-part) are supplied in the form of cartridges typically containing 

around 500 g of sealant. After use around 2–3 cm3

 of sealant are estimated to remain 

in the nole and tube when the cartridge has been emptied. This will quickly skin over 

and be protected inside the packaging. The final destination of these discarded 

cartridges will be as waste to landfill. 

Other sealants (e.g. two-part) are supplied in tins. Immediately before use, a curing 

agent is added to the tin and mixed with the sealant. The sealant is then filled into a 

cartridge on-site prior to application. Again, any unused material will quickly cure and 

set hard and will be disposed of in an appropriate manner. For industrial applications in 

the United Kingdom, the waste sealants are treated as special waste rather than 

general building waste. 

Based on the above information, the major loss of sealant containing LCCPs during 

their production and use (application) will be as solid waste. It is estimated that this 

solid waste could contain up to 13 tonnes/year of C18–20 liquid chlorinated paraffins and 

up to 27 tonnes/year of C>20 liquid chlorinated paraffins in the EU. 

3.1.5 Release from use as a plasticiser/flame retardant in paints 

LCCPs are used as plasticisers and/or flame retardants in paints. All three types of 

LCCPs considered in this report are used, and a paint may typically contain both liquid 

(either a C18–20 or C>20 liquid chlorinated paraffin) and solid C>20 chlorinated paraffins. 

Based on the data reported in Section 2.2.4, the total LCCP content of the paint is 

typically in the range 10–15 per cent, with the C18–20 or C>20 liquid chlorinated paraffin 

content in the range 3–7 per cent and the C>20 solid chlorinated paraffin content in the 

range 5–12 per cent. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 55

The total amount of paint estimated to be manufactured in a region in the EU 

containing all LCCPs can be estimated as around 2,320–3,480 tonnes/year. 

3.1.5.1 Default release estimation 

Appendix 1 of the TGD gives default emission factors for both the formulation and use 

of paints. 

Formulation 

The default emission factors for formulation of paints given in Table A2.1 of Appendix 1 

of the TGD are 0.001 (0.1 per cent) to air (vapour pressure <10 Pa; use of dedicated 

equipment) and 0.003 (0.3 per cent) to waste water. 

The amount of paint containing LCCPs formulated in a region is estimated to be 

between 2,320 and 3,480 tonnes/year, assuming that the paint formulation sites are 

numerous and widespread throughout the EU. From Table B2.3 of Appendix 1 of the 

TGD, the amount of paint formulated on one site can be estimated as 2,320 

tonnes/year over 300 days or 3,480 tonnes/year over 300 days. 

Based on the above information, the default release estimates for LCCP released 

during the formulation of paints can be estimated as: 

All LCCPs Local release: 348 kg/year or 1.2 kg/day to air 

comprising ~0.40 kg/day of either C18–20 liquid or C>20

liquid 

and ~0.80 kg/day C>20 solid chlorinated paraffin 

1,044 kg/year or 3.5 kg/day to waste water 

comprising ~1.2 kg/day of either C18–20 liquid or C>20 

liquid 

and ~2.3 kg/day C>20 solid chlorinated paraffin 

Regional and EU releases can be estimated as: 

C18–20 liquid Regional release: 180 kg/year to air 

 540 kg/year to waste water 

 Total EU release: 1,800 kg/year to air 

 5,400 kg/year to waste water 

C>20 liquid Regional release: 140 kg/year to air 

 420 kg/year to waste water 

 Total EU release: 1,400 kg/year to air 

 4,200 kg/year to waste water 

C>20 solid Regional release: 28.0 kg/year to air 

 84.0 kg/year to waste water 

 Total EU release: 280 kg/year to air 

 840 kg/year to waste water 

Processing (application of paints) 

The default emission factors from industrial use of paints are given in Table A3.15 of 

Appendix 1 of the TGD. The emission factors are 0 to air (Use Category 47; vapour 

pressure <10 Pa) and 0.001 (0.1 per cent) to waste water (solvent based paint; Use 
56 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Category 47; water solubility <10 mg/l). The amount of paint estimated to be used on 

an industrial site can be estimated at 348–522 tonnes/year over 300 days/year. This 

quantity of paint would contain a total of 52 tonnes of LCCP. 

Based on these data, the following release estimates for LCCPs from industrial paints 

can be obtained. 

All LCCPs Local release: 52 kg/year or 0.17 kg/day to waste water 

comprising ~0.06 kg/day of either C18–20 liquid or C>20

liquid 

and ~0.11 kg/day C>20 solid chlorinated paraffin 

C18–20 liquid Regional release: 180 kg/year to waste water 

 Total EU release: 1,800 kg/year to waste water 

C>20 liquid Regional release: 140 kg/year to waste water 

 Total EU release: 1,400 kg/year to waste water 

C>20 solid Regional release: 28.0 kg/year to waste water 

 Total EU release: 280 kg/year to waste water 

Default emission factors for private (domestic/DIY) use of construction and 

maintenance paints are given in Table A4.5 of Appendix 1 of the TGD. Here the 

emission factor for air is 0 (Use Category 47; vapour pressure <10 Pa) and the 

emission factor for release to waste water is 0.001 (0.1 per cent) (Use Category 47; 

water solubility <10 mg/l; solvent based paint). 

The extent of domestic usage of paint containing LCCPs is unknown but is likely to be 

very limited. The TGD indicates that for these types of paints the fraction used in 

domestic applications is of the order of 0.04–0.2 per cent of the total use. This value 

gives the amount of paint for domestic use in a region of 0.93 tonnes/year (assuming 

15 per cent total LCCP content) or 7.0 tonnes/year (assuming a 10 per cent total LCCP 

content). The fraction of this paint used in the local scenario is 0.002 (0.2 per cent) and 

so the amount of paint used in the local scenario can be estimated as 1.9 kg/year (15 

per cent total LCCP content) or 14 kg/year (10 per cent total LCCP content) over 300 

days/year. Using the emission factor of 0.1 per cent, the worst case estimate for local 

release of total LCCPs to waste water from domestic use lies between 2.9×10-4 and 

1.4×10-3 kg/year (9.7×10-7 to 4.7×10-6 kg/day). These values can be considered as 

negligible. 

3.1.5.2 Industry-specific information 

Formulation 

Information on the releases to the environment from formulation and use of chlorinated 

paraffins in paints has been obtained from industry (ECB, 2005a; BCF, 1999; BCF, 

2001). 

Chlorinated paraffins are generally only used in solvent-based paints, mainly for 

industrial applications. Releases to the environment from formulation and use are likely 

to be minimal (Government of Canada, 1993; ECB, 2005a) because the chlorinated 

paraffin is likely to be associated with the solid phase (e.g. dried paint) of any waste 

generated; it is very unlikely to enter into the aqueous effluent streams. The ESD for 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 57

paints, lacquers and varnishes industry in Chapter 7 of the TGD is also produced on 

this basis. 

In addition to the above ESD, a further recent ESD on coatings is also available 

(Environment Agency, 2003). For formulation, this ESD indicates that emissions to air 

and water should be minimal for solvent-borne paints and coatings. Any solvent-borne 

paint/coating left in the manufacturing equipment at the end of the formulation of a 

batch is washed out with organic solvents and either recycled back to the process or 

disposed of (by incineration or as hazardous waste) and hence little or no release to 

the environment occurs from this process. Packaging waste will be disposed of in a 

similar fashion. The emission factors given in the ESD for formulation of solvent-borne 

coatings are summarised in Table 3.5. 

Table 3.5 LCCP emission factors for formulation of solvent-borne coatings 

(from Environment Agency ESD, 2003) 

Emission type Emission factor 

Standard size batch 

(~1,000 litres) 

Large size batch 

(~10,000 litres) 

Waste generation 

 equipment leftovers 0.5% (recycled) 0.25% (recycled) 

0.5% (to disposal) 0.25% (to disposal) 

 packaging waste 0.5% ((to disposal) 0.5% (to disposal) 

 dust emissions 0.492% (to disposal) 0.493% (to disposal) 

Emissions to air 

 Low volatility liquids 0% 0% 

 Solids 0.005% 0.005% 

Emissions to water 

 Liquids 0% 0% 

 Solids 0.003% 0.002% 

The main source of emission to water identified in the ESD is from wash-off of dust 

from workshop areas. This source of emission would only be relevant for C>20 solid 

chlorinated paraffins but as these are waxy solids rather than dusty solids the amounts 

estimated to be emitted from this route are difficult to quantify. 

On this basis, the local and regional emissions to waste water and air during the 

formulation of solvent-borne paints and coatings containing LCCPs can be assumed to 

be very low. 

Other information on the possible releases to the environment during formulation of 

paints containing chlorinated paraffins has been obtained for the United Kingdom 

(BCF, 1999; BCF, 2001). This work confirmed that the releases to the atmosphere and 

waste water are expected to be very low during paint formulation. The amount of (solid) 

waste generated during the process was estimated as 0–2 per cent of the total amount 

of paint; the waste is disposed of to landfill or by incineration. 

BCF (1999) indicated that paints and coatings containing chlorinated paraffins typically 

make up only a small fraction (typically <1–2 per cent, maximum five per cent) of the 

total amount of paint formulated on a site. The information obtained also indicated that 

the amount of chlorinated paraffin used at a site was generally small (the average 

usage per site was 2.8 tonnes/year) and that an estimated 30 sites in total in the United 

Kingdom manufactured paints containing chlorinated paraffins. Euro Chlor (1999) also 
58 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

indicated that the number of sites manufacturing paints containing chlorinated paraffins 

around 10–50 in a country/region. 

Assuming that there are only 10 sites formulating paints in a region, then the amount of 

paint containing LCCPs formulated on a site would be around 232–348 tonnes/year. 

Comparing these amounts with the default quantities estimated earlier suggests that 

only around 10 per cent of the total paint formulated at a site will contain LCCPs, which 

is consistent with the data available from sites in the UK (a maximum of five per cent 

was found in a survey of several sites in the UK (see above)). 

Using the emission factors given by the Environment Agency (2003) and outlined in 

Table 3.5 (0 per cent to air and waste water for liquids, 0.005 per cent to air and 0.003 

per cent to waste water for solids), the following local, regional and total EU releases 

can be estimated for paint formulation. 

All LCCPs Local release: 1.2 kg/year or 0.0039 kg/day to air 

comprising ~0 kg/day of either C18–20 liquid or C>20

liquid 

and ~0.0039 kg/day C>20 solid chlorinated 

paraffin) 

0.70 kg/year or 0.0023 kg/day to waste 

water 

comprising ~0 kg/day of either C18–20 liquid or C>20

liquid 

and ~0.0023 kg/day C>20 solid chlorinated 

paraffin 

C18–20 liquid Regional release: 0 kg/year to air 

0 kg/year to waste water 

 Total EU release: 0 kg/year to air 

0 kg/year to waste water 

C>20 liquid Regional release: 0 kg/year to air 

0 kg/year to waste water 

 Total EU release: 0 kg/year to air 

0 kg/year to waste water 

C>20 solid Regional release: 1.4 kg/year to air 

0.84 kg/year to waste water 

 Total EU release: 14 kg/year to air 

8.4 kg/year to waste water 

Processing (application of paints) 

During application of the paint, immediate losses of chlorinated paraffin to air should be 

minimal due to the low vapour pressure of the substance at ambient temperatures 

(losses over extended time periods are considered later). Losses to water are also 

expected to be low (owing to the low water solubility of the substance) from industrial 

application of paints. This is also indicated in the ESD for coatings (Environment 

Agency, 2003), and the default calculations given above. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 59

In the absence of information on the releases to the environment from the use of paints 

containing LCCPs, the default release estimates calculated earlier will be used in the 

PEC determinations. 

The release from subsequent volatilisation and leaching from paint over long 

timescales is considered later in Section 3.1.9. It should be noted that the ESD on 

coatings (Environment Agency, 2003) indicates that a considerable amount of 

paint/coatings containing LCCPs may be disposed of during the application process 

(estimates range from 2.5 per cent to 60.8 per cent depending on the coating type and 

the mode of application), and this is taken into account in the estimate of lifetime losses 

from painted articles. 

3.1.6 Release from use as an extreme pressure additive in metal 

cutting/working fluids 

The C>20 liquid chlorinated paraffins are the main types of LCCPs used in metal cutting 

fluids in the EU, although it appears that a very small amount of C18–20 liquid chlorinated 

paraffins are also used in this application. 

Chlorinated paraffins in general are used in both oil-based and water-based (emulsion) 

metal cutting/working fluids, although LCCPs appear to be used primarily in fluids for 

the more difficult deep drawing operations. In most oil-based cutting fluids, the 

chlorinated paraffin content is around 5–10 per cent, but can be up to 70 per cent in 

some heavy drawing applications. 

In water-based metal cutting/working fluids, the chlorinated paraffin may be present 

typically at around five per cent in the formulation. In use, this formulation is diluted 

(emulsified) in water to give the final metal cutting/working fluid. The typical dilution is 

around 1:20 with water. Thus if the chlorinated paraffin is present at five per cent in the 

formulation, the concentration in the fluid in use is around 0.25 per cent. Recent 

information from industry has indicated that LCCPs are not used in emulsifiable 

metalworking fluids (Euro Chlor, 2008), however the coverage of the survey is unclear 

(it is based on the customers of members of Euro Chlor but the percentage of 

customers responding is not reported). 

The estimated amount of formulated fluid containing LCCPs produced in a region in the 

EU is around 515–1,030 tonnes/year, assuming formulation of such products is 

widespread throughout the EU. It will be assumed that LCCPs are used in both the oilbased and water-based lubricants and fluids. 

3.1.6.1 Default release information 

Formulation of metal cutting/working fluids 

The default release factors for the formulation of metal cutting/working fluids can be 

obtained from Table A2.2 of the TGD. For LCCPs these are 0.00005 (5×10-3 per cent) 

to air and 0.002 (0.2 per cent) to waste water (Industry Category 8; Use Category 35; 

vapour pressure <1 Pa). 

Assuming that 515–1,030 tonnes/year of metal cutting/working fluid are formulated in a 

region, the amount formulated on a site can be estimated to be 515–1,030 tonnes/year 

over 300 days (Table B2.3 of the TGD). The resulting default release estimates of C>20

liquid chlorinated paraffins are: 
60 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

C>20 liquid Local release: 2.6 kg/year or 0.0086 kg/day to air 

 103 kg/year or 0.34 kg/day to waste water 

 Regional release: 2.6 kg/year to air 

 130 kg/year to waste water 

 Total EU release: 25.8 kg/year to air 

 1,030 kg/year to waste water 

The equivalent calculations for C18–20 liquid chlorinated paraffins are confidential but 

would lead to a maximum local release of a few grammes per day to air and waste 

water, and so are unlikely to be significant in terms of this risk assessment. The 

regional and total EU releases are confidential. 

Use in metal cutting/working fluids 

Appendix 1 of the TGD gives default emission factors to waste water for metal cutting 

fluid additives of 0.185 (18.5 per cent) from oil-based fluids and 0.316 (31.6 per cent) 

from water-based (emulsifiable) fluids (Table A3.7; Industry Category 8; Use Category 

35). The default emission factors to air are 0.0002 (0.02 per cent) from both types of 

fluid. 

The actual split of LCCP use between oil-based and emulsion fluids is unknown. 

Industry-specific information reported later indicates that this split is likely to be around 

67:33 oil-based:water-based for chlorinated paraffins in general; this split will be 

assumed here. Although recent information from industry has indicated that LCCPs are 

not used in emulsifiable metalworking fluids (Euro Chlor, 2008), the coverage of the 

survey is unclear (it is based on the customers of members of Euro Chlor but the 

percentage of customers responding is not reported). 

Based on this 2:1 oil-based:water-based ratio, the amount of oil-based fluid containing 

LCCPs used in a region in the EU can be estimated at around 345–690 tonnes/year 

assuming there are a large number of potential sites of use in the EU. From Table B3.5 

of Appendix 1 of the TGD, the amount of fluid used on one site can be estimated as 

345–690 tonnes/year for steel works and 276–552 tonnes/year for other applications, 

both over 300 days/year. These quantities of fluid would contain around 34.5 and 27.6 

tonnes of LCCP for the two applications, respectively. 

For water-based fluids, the amount of formulation (before dilution) containing LCCPs 

used in a region in the EU can be estimated as 340 tonnes/year. When this formulation 

is diluted 1:20 for use, the total amount of emulsion fluid used is around 6,800 

tonnes/year. From Table B3.5 of Appendix 1 of the TGD, the amount of emulsion fluid 

used on one site can be estimated at 5,100 tonnes/year for steelworks and 2,040 

tonnes/year for other uses, both over 300 days. These quantities of fluid would contain 

around 12.8 and 5.1 tonnes of LCCP for the two applications, respectively. 

Based on these figures, the following default release estimates can be obtained for 

C>20 liquid chlorinated paraffins: 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 61

C>20 liquid Oil-based fluids

 Local release (steelworks): 6.9 kg/year or 0.023 kg/day to air 

6,383 kg/year or 21.3 kg/day to waste 

water 

 Local release (other sites): 5.5 kg/year or 0.018 kg/day to air 

5,160 kg/year or 17.0 kg/day to waste 

water 

 Regional release: 6.9 kg/year to air 

 6,383 kg/year to waste water 

 Total EU release: 69 kg/year to air 

 63,834 kg/year to waste water 

 Water-based (emulsion fluids) 

 Local release (steel works): 2.6 kg/year or 0.0087 kg/day to air 

4,045 kg/year or 13.5 kg/day to waste 

water 

 Local release (other sites): 1.0 kg/year or 0.0034 kg/day to air 

 1,610 kg/year or 5.4 kg/day to waste water 

 Regional release: 3.4 kg/year to air 

 5,370 kg/year to waste water 

 Total EU release: 34.0 kg/year to air 

 53,700 kg/year to waste water 

The equivalent calculations for C18–20 liquid chlorinated paraffins are confidential, but 

result in a local emission of 0.11 kg/day or less to waste water and 6.7×10-5 kg/day or 

less to air. The regional and total EU emission estimates are confidential. 

3.1.6.2 Industry-specific release information 

Formulation 

Information on the releases to the environment from this application is given in the ESD 

on lubricants and additives (OECD, 2004a). Formulation or blending of metal 

cutting/working fluids is normally carried out in a batch process. First, the base oils to 

be used are metered into the mixing vessel and the oils are blended together. This step 

is usually carried out at ambient temperature, but higher temperatures of up to 60°C 

can be used. Next, the additives are added to the base oil either by meter from a bulk 

storage tank or directly (either in neat form or diluted in base oil). Many additives are 

difficult to handle due to their high viscosity. Such additives may be pre-heated prior to 

blending. The blending vessels are normally mixed using paddle mixers or jet mixers, 

but other methods are sometimes used, such as air sparging, pulse-air mixing, high 

shear mixing and passing the fluid through a convoluted chamber to induce turbulence. 
62 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

The general approach given in the ESD for estimating emissions from lubricant 

blending plants is outlined here. The ESD itself should be consulted for full details of 

the methods involved. 

For emissions to air, the ESD assumes that the maximum concentration of lubricant in 

air within the blending plant is 1 mg/m3

. The ventilation rate of a representative plant is 

then used to estimate the amount of lubricant released in air. This assumes that there 

is no clean-up of the air before emission. Using the default parameters suggested in 

the emission scenario document, this results in an emission of 58 g/day to air of 

lubricant. 

According to the ESD, a representative plant is one which blends 30,000 tonnes of 

lubricant per year. The ESD provides a formula to calculate the ventilation rate of other 

sizes of plant, and this has been used here to adjust the emissions to the actual 

amounts of lubricant containing C18–20 liquid or C>20 liquid chlorinated paraffins that are 

estimated to be produced at a site. 

In order to estimate annual emissions from the plants the number of days of operation 

is needed. The ESD provides two methods to estimate this. One consistently results in 

a larger number of days than the other. For this assessment, both methods have been 

used and an intermediate value has been selected. 

The emission estimated above relates to the base fluid, which will make up the majority 

of the lubricant in the vapour phase. For additives, the ESD calculates the mole 

fractions of additive and base fluid in the liquid phase and then estimates the mole 

fractions in the vapour phase using Raoult’s law. The amount of additive in the vapour 

phase is then used to estimate the relevant emission. 

Using this method the following emission estimates are obtained: 

C18–20 liquid Local release 4×10-4 kg/day to air 

 Regional release Confidential (but very small) 

 Total EU release Confidential (but very small) 

C>20 liquid Local release 4×10-5 kg/day to air 

 Regional release 3×10-4 kg/year to air 

 Total EU release 3×10-3 kg/year to air 

For the emissions to water, the method in the ESD is based on the partitioning of 

additives between the oil phase and the aqueous phase in a separation system within 

the plant prior to the discharge of the waste water. It assumes that a maximum of 0.25 

per cent of the lubricant is included in the water and oil which reaches the separator, 

and that the maximum content of oil in discharged water is 5 mg/l (the limit of visibility). 

The additive can be released in the oil phase and the water phase, with the relative 

importance depending on the partitioning properties of the specific chemical of interest. 

The number of days of operation estimated above is used to calculate the amount of 

lubricant blended each day. 

The combined emission factors for the oil phase and water phase estimated using the 

method given in the emission scenario document are as follows: 

C18–20 liquid emission factor to water = 5×10-5 kg/tonne lubricant 

C>20 liquid emission factor to water = 5×10-5 kg/tonne lubricant 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 63

In the United Kingdom there are thought to be six large lubricant blending plants for all 

types of lubricants (OECD, 2004a). Assuming that each plant produces cutting fluids 

containing LCCPs (there is evidence to suggest that most formulators do, or have used 

chlorinated paraffins in the recent past (RPA, 1996)), the quantity of fluid containing 

C>20 liquid chlorinated paraffin formulated at any one site can be estimated as a sixth of 

that estimated to be used in a country/region. The regional amount of fluid produced is 

estimated at 515–1,030 tonnes/year. Thus the amount of fluid containing LCCPs 

formulated at a large blending plant can be estimated at around 86–172 tonnes/year. 

Using the methods outlined in OECD (2004a), this amount of lubricant will be 

formulated over 1–50 days. A midpoint value of 25 days will be used here. The 

amounts estimated to be emitted using this approach are summarised below: 

C>20 liquid Local release: 4.3×10-3 – 8.6×10-3 kg/year or 1.7×10-4–3.4×10-4

kg/day to waste water 

 Regional release: 0.026–0.052 kg/year to waste water 

 Total EU release: 0.26–0.52 kg/year to waste water 

For the C18–20 chlorinated paraffins, the amounts used are very small and in this case it 

has been assumed that the total amount used is blended on a single site in the EU. 

The estimated emissions to water using this assumption are summarised below: 

C18–20 liquid Local release: 5×10-4 kg day to waste water 

 Regional release: Confidential (but small) 

 Total EU release: Confidential (but small) 

Use in metal cutting/working fluids 

The major uses of LCCPs are as additives in oil-based metal cutting/working fluids 

(neat oils). However, they may also be used in water-based emulsions and so both 

types need to be considered5

. It is recognised that many metalworking facilities have 

adopted fluid management techniques to reduce costs through less frequent fluid 

purchases and less frequent disposal; proper fluid management reduces machine 

downtime by optimising the intervals between fluid changes. However, since it cannot 

currently be said that all facilities use the latest fluid management systems, this 

assessment represents a “realistic worst case” throughout Europe. 

Oil-based fluids (neat oils) 

Information has been obtained on the use of, and release from, metalworking fluids in 

the United Kingdom (OECD, 2004a). Losses of fluid, and hence any additive contained 

within it, are dependent on the type of equipment available for separating the fluid from 

the swarf. In the United Kingdom it is thought that around 40 per cent of the 

metalworking activity is carried out in large machine shops with sophisticated swarf 

treatment, 30 per cent in medium-sized machine shops with basic swarf treatment and 

the remaining 30 per cent in small machine shops with no swarf treatment. Little 

information is available on the size distributions in other EU countries, although the 

distribution in Spain is thought to be similar to that in the United Kingdom, and in Italy 

 

5

 Recent information from industry has indicated that LCCPs are not used in 

emulsifiable metalworking fluids (Euro Chlor, 2008), however the coverage of the 

survey is unclear (it is based on the customers of members of Euro Chlor but the 

percentage of customers responding is not reported). 
64 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

the proportion of large machine shops is slightly higher (60 per cent in large machine 

shops, 30 per cent in medium-sized machine shops and 10 per cent in small machine 

shops) (RPA, 1996). 

The estimated annual losses of cutting fluid, based on the replacement rates in the 

United Kingdom, are thought to be close to 50 per cent for a large machine shop, 75 

per cent for a medium-sized machine shop and 100 per cent from a small machine 

shop (OECD, 2004a). Not all of this loss, however, is released to the environment. A 

breakdown of the total losses for a large and small machine shop using oil-based 

cutting fluids is shown in Table 3.6 (OECD, 2004a). 

Table 3.6 Total losses of oil-based cutting fluids in large and small 

metalworking shops 

Type of loss Annual percentage fluid loss 

 Large facility 

(with swarf 

reprocessing) 

Small facility 

(no swarf 

reprocessing) 

Misting/evaporation 2% to air 2% to air 

Overalls 1% to water 2% to water 

Leaks 1% to watera 3% to watera

Dragout/workpiece 1% to water 1% to water 

2% to chemical waste 2% to chemical waste 

Internal reprocessing 1% to watera

 not applicable 

External reprocessing 10% (reused/discarded 

as waste oil) 

not applicable 

Dragout-swarf 30% (of which 90% 

burnt, 10% landfill) 

90% (of which 90% 

burnt, 10% landfill) 

Total losses 48% 100% 

Notes: a The losses may be further minimised by collecting the cutting fluid for re-use. 

The major losses of oil-based metal cutting/working fluids are associated with the 

swarf. It is thought that the vast majority (90 per cent) of swarf produced (and the 

adhering cutting fluid) is melted for re-use. Thus the cutting fluid and any additive will 

be destroyed in this process. In some situations, the swarf may undergo solvent 

cleaning prior to melting, and so some LCCP could end up in waste solvent in such 

sites. The remaining 10 per cent of swarf is thought to be disposed of to landfill (OECD, 

2004a). 

As can be seen from Table 3.6, the losses to waste water from a large and small 

machine shop can be estimated at four per cent and six per cent, respectively. 

However, some other losses have the potential for entering waste water. For instance, 

misting/evaporation losses are initially to air. However, these have the potential to 

settle within the facility and reach waste water as a result of cleaning equipment etc. 

The losses from external reprocessing of spent cutting fluid are due to line flushing etc. 

In a well controlled facility, flushings will be collected and re-used or discarded as 

waste oil. However, in a less well controlled facility, it is possible that this waste could 

be discharged to waste water. 

Another source of loss is dragout of the cutting fluid on the workpiece. This is generally 

removed by either alkaline washing or solvent washing and it is thought that in both 

cases the remaining cutting fluid is distributed between emissions to water and 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 65

chemical waste. In a worst case it could be assumed that all this dragout loss ends up 

in waste water. 

From the above information, a worst case loss from a metalworking facility would be 

around 18 per cent. Since these worst case loss figures are more likely to apply to a 

small facility than a large facility, where suitable reprocessing is usually carried out, an 

assessment will be made of both a large facility (release to waste water of four per 

cent) and a small facility (release to waste water of 18 per cent). The situation at a 

medium sized facility is likely to be between these two extremes. 

It is thought that a typical large-scale metal cutting/working plant in the United Kingdom 

would contain around 50,000 litres of cutting oil. This volume will be used as the basis 

for the local emission scenario for a large site. Assuming that the LCCP makes up 

around five per cent of the cutting fluid, then 50,000 litres of cutting fluid would contain 

around 2,500 kg of LCCP. The possible emissions of LCCP to waste water can be 

estimated at 100 kg/year, using the four per cent release figure. These emissions are 

equivalent to 0.33 kg/day, assuming use on 300 days/year. 

Information reported in RPA (1996) indicates that a small company may use <20 per 

cent of the metal cutting/working fluid than a large company. Therefore, an assessment 

will also be carried out for a small metal cutting/working plant containing 10,000 litres of 

cutting fluid. Assuming an LCCP content of five per cent, then 10,000 litres of cutting 

fluid would contain around 500 kg of LCCP. The possible emissions of LCCP to waste 

water from such a plant can be estimated at 90 kg/year, using the 18 per cent release 

figure. These emissions are equivalent to 0.3 kg/day over 300 days. 

These estimates are obtained assuming a five per cent LCCP content in the cutting 

fluid. If a 10 per cent content is used then the emission estimates would be double 

these figures. 

The local release estimates for use of C>20 liquid chlorinated paraffins in oil-based 

cutting fluids are summarised below: 

Local release (large site): 0.33 kg/day to waste water over 300 days 

(assuming five per cent chlorinated paraffin content) 

0.66 kg/day to waste water over 300 days 

(assuming 10 per cent chlorinated paraffin content) 

Local release (small site): 0.30 kg/day to waste water over 300 days 

(assuming five per cent chlorinated paraffin content) 

0.60 kg/day to waste water over 300 

(assuming 10 per cent chlorinated paraffin content) 

The daily emissions of C18–20 liquid chlorinated paraffins from sites of use would be of a 

similar order to those estimated above, however, as the quantities involved are small 

(and hence the total amount of cutting fluid containing C18–20 liquid chlorinated paraffins 

is small), such emissions from a small site are thought to be most relevant. 

Emulsifiable cutting fluids 

Similar to the situation with the neat oil cutting fluids, the losses of emulsifiable cutting 

fluids to the environment depend on the type of equipment available for separating the 

fluid from the swarf. However, there are some differences between the two types of 

fluids that have to be taken into account. 
66 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Firstly, losses by evaporation and by mist generation with emulsifiable fluids are higher 

than those associated with neat oils. However, since the emulsifiable cutting fluid is 

mainly water, which is more volatile than the additives present, the vapours and mists 

generated tend to have higher water contents than the bulk material. Thus the losses of 

additives may not be in proportion to the total losses of fluid. Also, the adhesion of 

emulsifiable cutting fluids to the swarf is less than that with neat cutting fluids (due to 

lower viscosity), although recovery of emulsifiable cutting fluids from swarf is not 

generally practised (OECD, 2004a). 

A breakdown of the potential losses to the environment of emulsifiable 

metalworking/cutting fluids is shown in Table 3.7 (OECD, 2004a). 

Table 3.7 Potential losses to the environment of emulsifiable 

metalworking/cutting fluids 

Type of loss Percentage of loss 

Misting/evaporation 5% to air 

Overalls 2% to water 

Leaks 3% to waste oil/water 

Dragout/workpiece 1% to water 

2% to chemical waste 

Dragout-swarf 87% 

 (of which 90% burnt, 10% landfill) 

Total losses 100% 

In use, it is important to maintain the correct oil/water ratio and an average 

replenishment rate of around 10 per cent per week can be considered typical to 

compensate for loss of fluid by dragout and evaporative losses etc. Since there is 

preferential evaporative loss of water, the replenishment package used is often a 

diluted version of the original fluid, typically containing around 50 per cent of the normal 

working concentration of the oil component. In addition, emulsifiable cutting fluids are 

subject to degradation (largely bacterial) during use and the whole system has to be 

replenished at a much higher frequency than with neat oils, typically at intervals of 

between one and six months. A typical worst case volume of cutting fluid present in the 

holding tanks at a site using emulsifiable cutting fluids is around 10,000 litres of fluid 

(OECD, 2004a). 

The emulsifiable metal cutting/working fluids are made by adding the oil component 

(containing the chlorinated paraffin at typically five per cent of the oil) to water at a 

dilution of around 1:20 oil:water. Thus, 10,000 litres of the emulsified fluid will contain 

500 litres of oil and approximately 25 kg of chlorinated paraffin. These concentrations 

will be approximately maintained in the cutting fluid by weekly additions of half-strength 

emulsion (to take into account the preferential evaporation of the water phase), at a 

rate of around 10 per cent of the total cutting fluid volume present (i.e. 1,000 

litres/week). The losses to water are likely to have a similar composition to the cutting 

fluid as used. From the loss figures reported in Table 3.7, the losses to water are 

estimated to be around six per cent (due to overalls, leaks and dragout from the 

workpiece). Thus the weekly loss of cutting fluid to waste water during use can be 

estimated as 60 litres/week. This volume of cutting fluid would contain around 0.15 

kg/week or 0.025 kg/day of LCCP, assuming six working days/week (300 days/year) 

(OECD, 2004a). 

In addition to the weekly loss of fluid during use, the whole system (10,000 litres of fluid 

containing 25 kg of LCCP) will be replaced every one to six months (OECD, 2004a). An 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 67

annual replenishment rate (or sometimes even longer) is thought to be typical for most 

facilities in the United States (CPIA, 2001). Before disposal, water-based (emulsion) 

cutting fluids can be treated before disposal by separating the oil and water phases by 

methods such as ultrafiltration. The oil phase can be collected for disposal (e.g. 

incineration) and the water phase then discharged to waste water. 

Given the physical properties of LCCPs, it is likely that most of the chlorinated paraffin 

will be associated with the oil phase and so will not be released to the environment. 

However, it is thought that around 50 per cent of waste emulsion is discharged to the 

sewage treatment plant without any pre-treatment. Thus as a worst case, in addition to 

the 0.025 kg/day release of the LCCP from losses during use (as discussed above), an 

intermittent (2–6 times/year) discharge to waste water of 25 kg of LCCP at each 

discharge needs to be considered.6

Information is also available on the likely residual oil content of the water phase after 

treatment by ultrafiltration prior to disposal to waste. The typical residual oil content of 

such water is around <10–40 mg/l (BUA, 1992). If it is assumed that the chlorinated 

paraffin composition of this residual oil is the same as the content in the oil used to 

produce the cutting fluid (i.e. five per cent of the oil), then the chlorinated paraffin 

content of the waste water can be estimated as 0.5–2 mg/l. 

The local release estimates for C>20 liquid chlorinated paraffins from the use and 

disposal of emulsifiable cutting fluids are summarised below: 

Local release: Use of cutting fluid 0.025 kg/day to waste water over 300 

days 

Disposal of cutting fluid 25 kg/day to waste water on 2–6 

days/year 

The emissions of C18–20 chlorinated paraffins from use in emulsifiable cutting fluids 

would be expected to be similar to those estimated above. However, it should be noted 

that the tonnage involved is very small, and it is not clear if the C18–20 chlorinated 

paraffins are used in emulsifiable cutting fluids. 

Total EU and regional release estimate for metal cutting/working fluids 

The differences in the loss and disposal patterns of oil-based and emulsion cutting 

fluids need to be taken into account in the estimation of the regional and continental 

release of LCCPs from use of metal cutting/working fluids. 

The split between the use of LCCPs in oil-based and emulsion fluids is not known. The 

OECD (2004a) indicates that the amount of base oil used to produce oil-based and 

emulsion fluids in the United Kingdom is in the ratio 15,750:7,700 tonnes/year. Since 

the LCCP is present at similar concentrations in both the oil-based and emulsifiable 

cutting fluids (before dilution to the working strength), the same ratio could be used to 

determine the relative amounts of chlorinated paraffin used in each type. Thus, it can 

be assumed that, of the 515–1,030 tonnes/year of fluid containing C>20 liquid 

 

6

 According to an analysis by Entec (2004), intermittent disposal of such emulsified 

metal cutting/working fluids to drain is not necessarily prohibited under existing 

legislation in the United Kingdom, provided the site operator obtained relevant 

permission from the sewerage undertaker. However, most companies are expected to 

separate the oil phase from the emulsified fluid prior to disposal to drain (with the oil 

being disposed of by processes such as incineration). Therefore this scenario is not 

relevant to the vast majority of sites using emulsifiable metal cutting/working fluids 

containing LCCPs. 
68 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

chlorinated paraffins estimated to be used in a region in the EU, approximately 346–

692 tonnes/year can be expected to be used in oil–based fluids and 169–338 

tonnes/year can be expected to be used in emulsion-based fluids prior to dilution to 

working strength. 

The total worst case regional release from emulsion-based fluids can be estimated 

assuming that 50 per cent of the fluid is eventually released to waste water without any 

pre-treatment (OECD, 2004a). Thus the total regional release of C>20 liquid chlorinated 

paraffins from emulsion-based fluids is estimated at 8,455 kg/year. 

For the oil-based fluids, the release to the environment depends on the size of the 

facility. As discussed above, around 60 per cent of oil-based fluids can be assumed to 

be used in large (and medium) facilities with swarf reprocessing, and the realistic worst 

case release to waste water from such facilities is estimated at four per cent. This gives 

a total regional release of LCCPs from large sites using oil-based fluids of 830 kg/year. 

For the remaining 40 per cent of oil, this will be assumed to be used in small and 

medium facilities, where little or no swarf reprocessing is carried out. For both these 

facilities, a worst case release figure of 18 per cent to waste water will be assumed. 

This gives a total regional release of LCCPs from small and medium sized facilities 

using oil-based fluids of 2,491 kg/year. Thus the overall regional release of LCCPs to 

waste water from use in oil-based cutting fluids is 3,321 kg/year. 

The total regional emissions from use of C18–20 liquid chlorinated paraffins have been 

estimated using a similar approach but the details of the calculation are confidential. 

3.1.7 Release from use in leather fat liquors 

Both C18–20 liquid and C>20 liquid chlorinated paraffins are used in the EU in the 

formulation of leather fat liquors. 

The amount of leather fat liquor containing LCCPs formulated in a region in the EU is 

estimated at approximately 240 tonnes. The EU is an exporter of leather fat liquors 

containing chlorinated paraffins (around 50 per cent of the leather fat liquors containing 

medium-chain chlorinated paraffins are exported from the EU (ECB, 2005a)), but the 

extent of this export for fat liquors containing LCCPs is unknown and so is not taken 

into account in this assessment. 

3.1.7.1 Default release estimation 

Appendix 1 of the TGD provides default release estimates for the formulation and 

processing (use) of substances used in the leather processing industry (Industry 

Category 7). 

Formulation 

For the formulation stage, Table A2.1 of the Appendix is appropriate. The default 

emission factors for this process are 0.001 (0.1 per cent) to air (vapour pressure <10 

Pa; produced in dedicated equipment) and 0.003 (0.3 per cent) to waste water. The 

amount of leather fat liquor formulated on one site can be estimated from Table B2.3. 

Assuming a regional production of 240 tonnes of leather fat liquors, all of this 240 

tonnes of fat liquor is estimated to be used on one site over 300 days. The following 

figures can therefore be estimated for release of total LCCPs from the formulation step: 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 69

Local release: 24 kg/year or 0.08 kg/day to air 

split 0.055 kg/day C18–20 liquid chlorinated paraffin 

and 0.025 kg/day C>20 liquid chlorinated paraffin 

72 kg/year or 0.24 kg/day to waste water 

split 0.15 kg/day C18–20 liquid chlorinated paraffin 

and 0.075 kg/day C>20 liquid chlorinated paraffin 

Regional release: 24 kg/year to air 

split 16.5 kg/year C18–20 liquid chlorinated paraffin 

and 7.5 kg/year C>20 liquid chlorinated paraffin 

72 kg/year to waste water 

split 49.3 kg/year C18–20 liquid chlorinated paraffin 

and 22.6 kg/year C>20 liquid chlorinated paraffin 

Total EU release: 240 kg/year to air 

split 165 kg/year C18–20 liquid chlorinated paraffin 

and 7 5 kg/year C>20 liquid chlorinated paraffin 

720 kg/year to waste water 

split 493 kg/year C18–20 liquid 

and 226 kg/year C>20 liquid chlorinated paraffin 

These estimates assume that a site formulates leather fat liquors using both C18–20 and 

C>20 liquid chlorinated paraffins. 

Processing (use of leather fat liquors) 

The assessment assumes that around 240 tonnes of leather fat liquors containing 

LCCPs are used in a region in the EU each year. According to Table B3.4 of Appendix 

1 of the TGD, the amount used at a site is 100 tonnes/year of leather fat liquor 

containing C18–20 liquid chlorinated paraffin over 100 days or 46 tonnes of leather fat 

liquor containing C>20 liquid chlorinated paraffin over 46 days. 

Table A3.6 of Appendix 1 of the TGD gives default emission factors for the use of 

substances during the processing step. For LCCPs the emission factors are 0.001 (0.1 

per cent) to air (solubility <100 mg/l; vapour pressure <100 Pa) and 0.05 (5 per cent) to 

waste water (Main Category 2 (inclusion into matrix; solubility <100 mg/l)). 

The following figures can therefore be estimated for release of LCCPs from the leather 

fat liquoring (i.e use of leather fat liquors) step: 
70 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

C18–20 liquid Local release: 10 kg/year or 0.10 kg/day to air 

 500 kg/year or 5 kg/day to waste water 

 Regional release: 16.7 kg/year to air 

 830 kg/year to waste water 

 Total EU release: 166 kg/year to air 

 8,300 kg/year to waste water 

C>20 liquid Local release: 4.6 kg/year or 0.1 kg/day to air 

 230 kg/year or 5.0 kg/day to waste water 

 Regional release: 7.6 kg/year to air 

 380 kg/year to waste water 

 Total EU release: 76 kg/year to air 

 3,800 kg/year to waste water 

3.1.7.2 Industry-specific release estimation 

Formulation of fat liquors 

Information on the formulation of leather fat liquors has been provided previously by a 

major formulator (Euro Chlor, 1998). This site complied with a discharge consent of 

<0.5 ppm of adsorbable organic halogen (AOX) (chlorinated paraffins are the only 

source of halogen in this discharge). Industry sources indicated that a similar situation 

with regards to discharge is likely to exist for all European formulators (Euro Chlor, 

1998). In France, the discharge limit is 1 ppm for total AOX, but halogen sources other 

than LCCPs may contribute to this limit. 

A small amount of chlorinated paraffin may also be sold directly to tanneries which then 

make their own fat liquors. The emissions from this process are likely to be small 

compared to the emissions associated with the fat liquoring process itself (default 

release factor for formulation is 0.3 per cent compared with the release factor for fat 

liquoring of two per cent (see later)); these emissions are not considered any further. 

Processing (fat liquoring) 

An ESD is available for the leather industry (Chapter 7 of the TGD). This recommends 

a value of 15 tonnes/day as a reasonable worst case for the mass of leather processed 

at a site, based on production data for Germany. Figures for typical water use are also 

available. These figures depend on whether the site carries out all stages of leather 

production (from processing of raw skins to production of the final leather), where a 

water consumption of 35 l/kg raw hide is typical, or is specialised in the refining of “wet 

blue” (leather produced after the tanning step), where a water consumption of 18 l/kg 

leather is typical. Processing of one tonne of raw hides produces a maximum of 250 kg 

of “wet blue”. Since the fat liquoring step follows the tanning stage, both types of site 

have the potential to use fat liquors containing LCCPs. 

Information on the amount of fat liquor used in treating leather has been provided 

previously (Euro Chlor, 1998). The typical application rate is around 70–120 g of fat 

liquor/kg of leather treated. Since the fat liquor typically contains around 10 per cent by 

weight of the chlorinated paraffin, the amount of the chlorinated paraffin used in this 

process is around 7–12 g/kg leather treated. The amount of chlorinated paraffin 

present in the treatment solution at the end of the process is thought to be around two 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 71

per cent of that used (Euro Chlor, 1998). This residual amount will be discharged to 

waste water. 

Using this information, the following site release estimates can be made, using the 

methods outlined in Chapter 7 of the TGD: 

Complete processing: 

 Mass of raw leather processed/day = 15 tonnes 

 Mass of “wet blue” leather produced = 3.75 tonnes/day 

 Mass of LCCPs used = 12 kg/tonne “wet blue” = 45 kg/day 

 Percentage released to waste water = 2 per cent 

 Mass of LCCPs released to waste water = 0.9 kg/day 

Processing of “wet blue”: 

 Mass of “wet blue” processed/day = 15 tonnes 

 Mass of LCCPs used = 12 kg/tonne “wet blue” = 180 kg/day 

 Percentage released to waste water = 2 per cent 

 Mass of LCCPs released to waste water = 3.6 kg/day 

These release estimates are appropriate for both types of LCCP used in the process. 

The default estimated number of days of use at a local site are 100 days/year for the 

C18–20 chlorinated paraffin and 46 days/year for the C>20 chlorinated paraffin. Since the 

calculations are based on the total amount of leather processed at a site, if both types 

of LCCP are used at the same site, then the figures would refer to the combined 

amount of the chlorinated paraffins used. 

The calculation for processing of "wet blue" scenario assumes that 15 tonnes/day are 

processed at a site as recommended in the ESD in the TGD. However, a draft update 

to this ESD indicates that the typical mass of "wet blue" processed at a site may be 

around 3.2 tonnes/day (UBA, 1998). This would reduce the calculated emissions by a 

factor of around four, and would lead to similar calculated PECs as obtained for the 

complete processing scenario. Therefore, the PECs obtained for complete processing 

only will be taken forward to the risk characterisation. 

The overall release estimate to waste water from the process in the EU is 3,320 

kg/year of C18–20 liquid chlorinated paraffins and 1,520 kg/year of C>20 liquid chlorinated 

paraffins. The estimated regional release will be 10 per cent of these figures. 

3.1.8 Release from use in textiles 

Information provided by industry indicates that both C>20 liquid and C>20 solid 

chlorinated paraffin products may have been used in the past as plasticisers/flame 

retardants for textiles, where they were applied as a backcoating. However this use no 

longer occurs in the EU. 
72 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

However a small amount of C18–20 liquid chlorinated paraffins is used for waterproofing 

textiles in the EU. Few details of the process used are available and so the default 

methods in the TGD have been used to estimate the following emissions from this use. 

Details of the calculations are considered confidential. 

C18–20 liquid Local release 8.3 kg/day to air. 

 4.3 kg/day to waste water 

 Regional release Confidential 

 Total EU release Confidential 

3.1.9 Release from articles over their service life 

Although LCCPs are of low vapour pressure at ambient temperatures, the vapour 

pressure is not so low as to preclude the possibility of volatilisation from plastics, 

paints, rubber, textiles and sealants during their service life. This is particularly true of 

the C18–20 liquid chlorinated paraffins with lower chlorine contents (see Appendix B for 

estimates of how vapour pressure varies with chlorine content). 

3.1.9.1 Volatilisation 

The ESD on plastics additives (OECD, 2004b) summarises the work that has been 

carried out on plasticiser leaching and volatilisation from PVC products. 

For volatilisation from PVC the following equation was derived for thin film applications: 

 rate of volatilisation (% per year) = 1.1×106 × vapour pressure (mmHg). 

In Section 1.4.4, it was shown that the vapour pressure of LCCPs depends markedly 

on the carbon chain length and degree of chlorination. Using the representative vapour 

pressures for the various LCCP products, rates of volatilisation can be estimated using 

the above equation (see Table 3.8). 

Table 3.8 LCCP rates of volatilisation 

LCCP Vapour pressure Estimated volatilisation 

rate 

C18–20 liquid 1.9×10-6 mmHg (2.5×10-4 Pa) 2 per cent/year 

C>20 liquid 1.9×10-7 mmHg (2.5×10-5 Pa) 0.2 per cent/year 

C>20 solid 1.1×10-16 mmHg (1.5×10-14 Pa) 1×10-10 per cent/year 

These estimates apply to losses from thin film applications. These estimated rates are 

highly uncertain because they are dependent on the vapour pressure. As discussed in 

Section 1.4.4, there are some uncertainties over the actual vapour pressures of these 

substances. 

For general articles an emission factor of 0.05 per cent of the annual consumption of 

plasticiser is recommended for losses over the lifetime of articles (OECD, 2004b). This 

figure is appropriate for a plasticiser such as DEHP, and is based on the estimated 

amount volatilised (approximately 140 tonnes/year) from the major applications, related 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 73

to the annual consumption of the substance. Thus, although the amount of the 

substance present in articles will be higher than the annual consumption (the lifetime of 

many products more than one year), this is accounted for in the way the emission 

factor has been estimated. The figure of 140 tonnes/year for the amount of DEHP 

volatilised was estimated from the results of theoretical and semi-experimental studies 

on the volatilisation rate from PVC, along with the estimated surface area of PVC 

articles and products present in the EU, taking into account the lifetime of the product. 

As discussed earlier, the C18–20 liquid and C>20 liquid products appear to be around 2.5 

and five times less volatile than DEHP from products; a general emission factor of 0.02 

per cent and 0.01 per cent, respectively, is appropriate for the loss of these LCCPs 

over the lifetime of the products, (related to the annual consumption of LCCPs 

incorporated in the products). The volatile loss of C>20 solid chlorinated paraffins over 

the articles’ lifetime is expected to be very low. 

Information provided by industry indicates that a polyurethane coating is typically 

applied to cushioned PVC flooring produced by spread coating to improve the wear 

properties and staining resistance. It is estimated that around 50–60 per cent of the 

cushion vinyl flooring may have such coatings. These coatings may reduce the 

potential for volatilisation loss from the flooring. This is considered further in Appendix 

F. 

Other products, such as paints, rubber, textiles, sealants, etc., can also be expected to 

lose LCCP by volatilisation. A similar rate of volatilisation to that in PVC will be 

assumed. 

The estimated loss rate of two per cent per year for C18–20 liquid chlorinated paraffins 

and 0.2 per cent per year for C>20 liquid chlorinated paraffins from thin films may be 

appropriate for paints (although as paints form a surface skin of low permeability, this 

should reduce the emissions compared to those from a thin film of plastic). However, 

this value will overestimate the releases from sealants, rubber and textiles, so a loss 

rate of 0.01–0.02 per cent over the lifetime would appear more appropriate here. 

The release figure for thin films should be applied to the total amount LCCP present in 

painted articles in the EU, rather than the yearly consumption figure in this area. The 

releases from paints using this figure have been estimated based on a 5–7 year 

lifetime for painted surfaces. It is likely that the actual releases from painted surfaces 

will be lower than this figure due to formation of a surface skin of low permeability. 

Table 3.9 summarises the possible volatilisation losses from articles containing 

LCCPs. 
74 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.9 Estimated volatilisation losses of LCCPs from polymeric materials 

over their lifetimes 

Use Release to air 

C18–20 liquid C>20 liquid C>20 solid 

PVC (over lifetime) 105 kg/year NA NA 

Rubber NA 418 kg/year negligible 

Textile Confidential NA NA 

Paints (over 5–7 year 

lifetime) 

180,400–252,560 

kg/year 

13,940–19,516 

kg/year 

negligible 

Sealants and 

adhesives (over 

lifetime) 

52 53 kg/year NA 

Total EU ~180,600–~252,700 

kg/year 

14,411–19,987 

kg/year 

negligible 

Regional total ~18,060–~25,270 

kg/year 

1,411–1,999 kg/year negligible 

Note: NA = not applicable (i.e. no major use in the application). 

An alternative approach to estimating the volatilisation losses of LCCPs from PVC use 

is considered in Appendix F. This method gives a release to air over the products’ 

lifetime of around 126–139 kg/year for C18–20 liquid chlorinated paraffins (and 3.0–3.3 

kg/year for C>20 liquid chlorinated paraffins, based on their use in the past in this 

application). These estimates are in good agreement with the figures derived in Table 3.9. 

The approach taken in Appendix F requires a large number of assumptions 

and so there is considerable uncertainty in the figures derived. Therefore the figures 

from Table 3.9 will be used in the environmental modelling to estimate the regional 

concentrations. 

Volatilisation could also occur from other products containing LCCPs, such as leather 

articles. However, there is insufficient information available about the emission rates 

from these types of products to make a reasonable attempt to estimate the overall 

releases. 

3.1.9.2 Leaching 

Information has been reported on the leaching of plasticiser from PVC flooring during 

washing (OECD, 2004b). Again, this information has generally been generated for a 

phthalate plasticiser such as DEHP. Since leaching losses are likely to depend to some 

extent on the water solubility of LCCPs, the difference in solubility between DEHP 

(recommended value taken from Draft DEHP ESR Assessment: 3 μg/l) and LCCPs 

(≤5 μg/l) needs to be considered. Thus, based on these water solubilities, the potential 

for leaching of LCCPs appears to be similar to that determined for DEHP. 

The worst case losses to water were estimated at 0.05 per cent for washing of interior 

products and 0.7 per cent for exterior products such as roofing (OECD, 2004b). The 

factor of 0.05 per cent for washing interior products is the estimated loss over the 

products’ lifetime, and applies to the annual consumption of plasticiser rather than the 

total amount present in articles (this is accounted for in the way the emission factor was 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 75

derived). Information provided by industry indicates that a polyurethane coating is 

typically applied to around 50–60 per cent of cushioned PVC flooring. These coatings 

may reduce the potential for leaching loss from washing of the flooring. 

The factor of 0.7 per cent for outdoor use was determined for loss of total phthalate 

plasticiser from roofing material over four years. Thus the average annual loss rate in 

the study is 0.15 per cent/year. This factor should be applied to the actual amount of 

LCCP present in products, taking into account the products’ lifetime. It should also be 

noted that the derived emission factor will also include contributions from loss of 

particulates, degradation etc. from the material due to weathering or erosion and so is 

likely to overestimate the actual leaching loss of the LCCP. 

Since a major use of chlorinated paraffins is likely to be in indoor applications such as 

flooring (see Appendix F) the 0.05 per cent release factor over the products’ lifetime is 

appropriate. As indicated above, some cushioned PVC products may have coatings 

that reduce the potential for leaching loss from the product, but the extent of this 

reduction is unknown and so adds further uncertainty to the estimates presented, and 

is considered further in Appendix F. 

For paints and, to a lesser extent, sealants, the external release factor may be more 

appropriate, as they are sometimes used in applications where significant exposure to 

water may occur (e.g. marine paints, masonry paints). A 5–7 year lifetime will be 

assumed for paints and a 10–30 year lifetime will be assumed for sealants. 

For textile applications, there will be the potential for loss to water during washing or 

exposure to rain etc. There are no data available on the possible emissions from this 

process. In the absence of any further information the 0.05 per cent loss factor for 

washing of interior products will be used in the assessment for textile products over 

their lifetime. 

For the other applications, e.g. leather, the potential for exposure to water appears to 

be limited. The worst case release to the environment from leaching of LCCPs from 

products is shown in Table 3.10. 

An alternative approach to estimating the leaching losses from PVC use is considered 

in Appendix F. This gives a release to water of around 429–530 kg/year to waste water, 

298 kg/year to surface water (plus a loss of around 298 kg/year to soil, and 51 kg/year 

to waste water from leaching from landfills) for C18–20 liquid chlorinated paraffins (the 

equivalent figures for the past use of C>20 liquid chlorinated paraffins are around 20–

25 kg/year to waste water, 14 kg/year to surface water, 14 kg/year to soil and 2 kg/year 

to waste water from leaching from landfills). These estimates are in reasonable 

agreement with the figures derived in Table 3.10. 

The approach taken in Appendix F requires a large number of assumptions and so 

there is a large degree of uncertainty in the figures derived. Therefore the figures from 

Table 3.10 will be used in the environmental modelling to estimate the regional 

concentrations. The estimate for the historic use of C>20 liquids in PVC is very small 

compared with the estimates for leaching from other uses of the substance and so has 

not been considered significant in this risk assessment. 
76 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.10 Estimated leaching losses of LCCPs from polymeric materials over 

their lifetime 

Use Release to water 

C18–20 liquid 

(kg/year) 

C>20 liquid 

(kg/year) 

C>20 solid 

(kg/year) 

PVC over lifetime 262a NA NA 

Rubber over 

lifetime 

NA 2,088b 104b 

Textiles over 

lifetime 

Confidential NA NA 

Paints over 5–7 

years lifetime 

13,530–18,942b 10,455–14,637b 2,100–2,940b 

Sealants and 

adhesives over 

10–30 years 

lifetime 

3,930–11,790b 7,965–23,895b NA 

Total EU ~18,000–~31,000 

 • 105 to waste water 

 • 8,810–15,500 to 

 surface water 

 • 8,810–15,500 to 

 soil 

20,508–40,620 

 • 10,254–20,310 to 

 surface water 

 • 10,254–20,310 to 

 soil 

2,204–3,044 

 • 1,102–1,522 to 

 surface water 

 • 1,102–1,522 to soil 

Regional total 1,800–3,100 

 • 10 to waste water, • 

881–1,550 to 

 surface water 

 • 881–1,550 to soil 

2,051–4,062 

 • 1,025–2,031 to 

 surface water 

 • 1,025–2,031 to soil 

220–304 

 • 110–152 to 

 surface water 

 • 110–152 to soil 

Notes: NA = not applicable (i.e. no use in the application). a

 The emission is assumed to be split 40 per cent to waste water treatment 

plants, 30 per cent direct to surface water and 30 per cent direct to 

industrial/urban soil. 

b The emission is assumed to be split 50 per cent direct to surface water and 50 

per cent direct to industrial/urban soil. 

The losses from leaching are likely to be released either to waste water, surface water 

directly or to industrial/urban soil. In the assessment a 50:50 split between surface 

water and industrial/urban soil will be used for the emissions from paints and sealants. 

For PVC emissions to waste water treatment plants are also likely and it will be 

assumed here that the emissions are split approximately 40 per cent to waste water, 30 

per cent direct to surface water and 30 per cent to industrial/urban soil, in line with the 

analysis in Appendix F. 

The figures estimated for the leaching loss are likely to overestimate the actual loss as 

not all the PVC, paint, sealants or textiles containing LCCP will come into contact with 

water. There are also uncertainties in determining representative lifetimes of products 

such as sealants, which have a large bearing on the resulting release estimates. In 

addition, some of the emission factors used also include losses of particulates etc. due 

to weathering effects and erosion, as well as leaching loss. The environmental 

behaviour of LCCPs in these particulates is unknown. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 77

3.1.9.3 Waste in the environment and ultimate disposal 

“Waste remaining in the environment” 

As well as volatilisation and leaching losses of LCCPs from products/articles, LCCPs 

may also enter into the environment as a result of “waste” from the products 

themselves during their useful lifetime and disposal. Such waste could include 

erosion/particulate losses of polymeric products, paints and sealants as a result of 

exposure to wind and rain or may occur as a result of their mode of use (e.g. wear on 

conveyor belts, flooring etc.). Similarly, when products/articles are dismantled or 

disposed of at the end of their useful life, there is again a potential for this type of 

particulate release. In either case the end result is that polymeric particles containing 

LCCPs could enter into the environment. 

No agreed method is currently included in the TGD for addressing these potential 

sources of release. These emissions were considered in the EU risk assessment for 

medium-chain chlorinated paraffins (ECB, 2005a). Appendix F uses a similar approach 

to that taken in ECB (2005a) to derive the following overall release figures for LCCPs 

as particulates. 

Release to air = 81–83 kg/year of C18–20 liquid 

 + 238 kg/year of C>20 liquid 

 + 19 kg/year of C>20 solid 

 Release to surface water = 19,857–20,719 kg/year of C18–20 liquid 

 + 59,643–59,913 kg/year of C>20 liquid 

 + 4,779 kg/year of C>20 solid 

 Release to waste water = 865–1,570 kg/year of C18–20 liquid 

 + 41–74 kg/year of C>20 liquid 

 Release to urban/industrial soil = 59,813–62,410 kg/year of C18–20 liquid 

 + 179,647–180,457 kg/year of C>20 liquid 

 + 14,393 kg/year of C>20 solid 

As these releases of LCCP are essentially bound within a polymer matrix, the actual 

bioavailability and environmental behaviour of the LCCP are unknown. There are no 

agreed methods available in the current TGD for dealing with these types of releases in 

the risk assessment. In this assessment they have been taken to represent a 

bioavailable source of LCCPs in the environment and have been included in the 

regional and continental models. 

Ultimate disposal 

Since LCCPs have not generally reacted or changed during their lifecycle, ultimately all 

the chlorinated paraffin used in products will be disposed of at the end of the products’ 

useful lives. Disposal by landfill or incineration is likely to be the ultimate destination of 

much of the chlorinated paraffin. For some applications, e.g. metalworking fluids, some 

of the chlorinated paraffin could be destroyed in processes such as recycling of metal 

swarf. For other processes, the LCCP present is likely to end up in the sludge 

produced in the process, which will again most likely be disposed of by incineration or 

landfill. 

As a first approximation, it can be assumed that the annual consumption of LCCP is 

used to replace the articles disposed of each year, thus the amount of LCCPs disposed 

of to landfill and incineration each year is of the order of up to 5,000–10,000 tonnes. 
78 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Of the possible disposal methods, incineration is likely to completely destroy the LCCP. 

In landfills, chlorinated paraffins are expected to be relatively stable for a number of 

years and so could be subject to leaching or volatilisation from the landfill. It is currently 

not possible to quantify these releases. However, LCCPs are expected to adsorb 

strongly onto soil and so leaching and volatilisation from landfill would not be expected 

to be significant processes compared with other sources of release (see Section 3.1.9 

and Appendix F). 

3.1.10 Summary of release estimates 

The releases of LCCPs to the environment are summarised in Table 3.11. In most 

cases the releases are based on some information specific to the industry, 

supplemented with default release estimates from the TGD where appropriate. 

The relative contributions of the various sources to the total regional emissions are 

shown in the following charts (Figure 3.1 to Figure 3.3).
 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 79

Figure 3.1 Contribution to total air emissions 

Production

PVC - raw materials handling 

PVC - compounding

PVC - processing

Rubber

Paints - formulation

Paints - application

Metal working fluids - fomulation

Metal working fluids - use in oilbased

Metal working fluids - use in

emulsions

Leather fat liquors - formulation

Leather fat liquors - processing 

Textiles

C18-20 C>20 liquid C>20 solid

Figure 3: Contribution to total air emissions
80 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Production

PVC - raw materials handling 

PVC - compounding

PVC - processing

Rubber

Paints - formulation

Paints - application

Metal working fluids - fomulation

Metal working fluids - use in oil-based

Metal working fluids - use in emulsions

Leather fat liquors - formulation

C18-20 C>20 liquid C>20 solid

Figure 4: Contribution to total emissions direct to surface water

Figure 3.2 Contribution to total emissions direct to surface 
 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 81

Figure 3.3 Contribution to total emissions via waste water trea

Production

PVC - raw materials handling 

PVC - compounding

PVC - processing

Rubber

Paints - formulation

Paints - application

Metal working fluids - fomulation

Metal working fluids - use in oil-based

Metal working fluids - use in emulsions

Leather fat liquors - formulation

Leather fat liquors - processing 

C18-20 C>20 liquid C>20 solid

Figure 5: Contribution to total emissions via waste water treatment pl
82 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.11 Summary of environmental release estimates for LCC

Estimated local 

release (kg/day) 

No of 

daysl

Estimated regional release 

(kg/year) 

Use Comment Type of 

LCCP 

air waste 

water 

air waste 

waterg 

soilo 

C18–20

liquid 

 0.063 300 

C>20

liquid 

 0.32 300 

Production Generic 

calculation 

C>20 solid 0.0063 300 

n n n 

Use in PVCe – 

plastisol coatingh 

Compounding site (formulation) 

C18–20

liquid 

0.025a 33 

 Conversion 

site (processing) 

C18–20

liquid 

0.025a 0.025a 33 

 Combined 

compounding and conversion site 

C18–20

liquid 

0.025a 0.050a 33 

Use in PVCe – 

extrusion/other 

Compounding site (formulation) 

C18–20

liquid 

0.0075a

0.040b

0.0034c 

0.0445a

0.24b 

0.0204c

33 

 Conversion 

site (processing) 

C18–20

liquid 

0.037a 

0.040b 0.034c 

0.037a 0.040b 0.034c 

33 

Table 3.11 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 83

Table 3.11 continued 

Estimated local release (kg/day) 

No of daysl

Estimated regional release (kg/year) 

Use Comment Type of 

LCCP 

air waste 

water 

air waste 

waterg 

soilo 

Use in PVCe – 

extrusion/other 

Combined compounding and conversion site 

C18–20

liquid 

0.0445a 

0.080b 0.0374c 

0.0815a

0.28b 

0.0544c

33 

Raw materials handling (formulation) 

C18–20

liquid 

 5.2 

Compounding (formulation) 

C18–20

liquid 

 0.7 0.7 

Use in PVC – regional and continental releases 

Conversionf

(processing) 

C18–20

liquid 

 12 12 

Rubber Formulation/ C>20 liquid 0.015 0.040 251 25 67 

processing site C>20 solid 0.015 0.51 21 1.2 43 

C18–20 

liquid 

Sealants/ negligible adhesives 

Formulation/ use 

C>20 liquid negligible 

C18–20

liquid 

negligible 

C>20 liquid negligible 

Paints and varnishes 

Formulation 

C>20 solid 0.0039 0.0023 300 1.4 0.84 
84 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Estimated local release (kg/day) 

No of daysl

Estimated regional release (kg/year) 

Use Comment Type of 

LCCP 

air waste 

water 

air waste 

waterg 

soilo 

 {0.06} 300 {180}  {0.06} 300 {140} 

Industrial application of paints (Processing) 

C18–20 liquid 

C>20 liquid 

C>20 solid {0.11} 300 {28} 

C18–20 

liquid 

4×10-4 5×10-4 Metal <10 n n 

cutting/working fluids 

Formulation 

C>20 liquid 4×10-5 3.4×10-4 25 3×10-4 0.052 

Use in oil based fluids (processing; large site) 

C>20 liquid 0.33i or 

0.66j

300 830 

C18–20

liquid 

 0.30i or 

0.60j

 Use in oil 300 n 

based fluids (processing; small site) 

C>20 liquid 0.30i or

0.60j

300 2,491 

C18–20

liquid 

 0.025 

(plus an intermittent discharge of 25 kg/event) 

 Use in 300 n 

emulsifiable fluids (processing) 

C>20 liquid 0.025 

(plus an intermittent discharge of 25 kg/event) 

300 8,455 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 85

Table 3.11: continued

Estimated local release (kg/day) 

No of daysl

Estimated regional release (kg/year) 

Use Comment Type of 

LCCP 

air waste 

water 

air waste 

waterg 

soilo 

Leather fat liquors 

Formulation C18–20

liquid 

{0.055}i {0.15}i 300 {17} {49} 

 C>20

liquid 

{0.025}i {0.075}i 300 {7.5} {23} 

 Use – 

complete processing of raw hides 

C18–20 

liquid 

 0.9 100 332 

 C>20

liquid 

 0.9 46 152 

 Use – 

processing of “wet blue” 

C18–20

liquid 

 3.6 100 

 C>20

liquid 

 3.6 46 

Textiles Processing C18–20

liquid 

{8.3} {4.3} 300 n n 

C18–20liquid 

 18,060– 

25,270 

10 + 881–1,550m 

881–1,550 

C>20

liquid 

 1,411– 

1,999 

1,025–2,031m 

1,025–2,031m 

Articles – volatile and leaching loss 

Service life 

C>20 solid negligible 110-152m 110-152 
86 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.11: continued 

Estimated local release (kg/day) 

no of daysl

Estimated regional release (kg/year) 

Use Comment Type of 

LCCP 

air waste 

water 

 air waste waterg soilo 

C18–20

liquid 

 8 1,986–2,072m

+ 87–157 

5,981–

6,241 

C>20

liquid 

 24 5,964– 

5,991m + 4–7 

17,965

–

18,046 

“Waste” remaining in the environment 

Service life 

and disposal 

C>20 solid 2 478m 1,439 

C18–20

liquid 

 18,098

–

25,308 

541–597 via 

wwtp 

3,002–3,771 

direct to 

surface water 

6,862–

7,791 

Total emissions 

C>20

liquid 

 1,468–

2,056 

9,730–9,732 

via wwtp 

9,421–10,455 

direct to 

surface water 

18,990

–

20,077 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 87

C>20 solid 4.6 57 via wwtp 

602–644 

direct to 

surface water 

1,549–

1,591 

Notes: a Open systems (as defined in OECD, 2004b). 

b Partially open systems (as defined in OECD, 2004b). 

c Closed systems (as defined in OECD, 2004b). 

d Continental release = total EU release-regional release. 

e Releases estimated from OECD, 2004b assuming that 50 per cent of the initial release to air will 

water. 

f Regional and continental releases from conversion assume 50 per cent of sites have air emission c

the industry with such controls is unknown, but is likely to be higher than this figure. 

g A 80 per cent connection rate to waste water treatment plants will be assumed. h Releases from car underbody coating and sealing, and rotational moulding are thought to be negligibi Industry-specific release information is also available and has been used to estimate the PEClocal in pj Figure assumes a 5 per cent chlorinated paraffin content in the cutting fluid. k Figure assumes a 10 per cent chlorinated paraffin content in the cutting fluid. l Number of days/year over which the local emission occurs. m Emissions occur directly to surface water. 

n Confidential information – the regional and continental releases from this source are small compa

sources. 

o Direct emissions to urban/industrial soil. 

 { } Denotes estimates are based on the TGD default values only. 
88 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

3.2 Environmental fate and distribution 

3.2.1 Atmospheric degradation 

LCCPs will react with hydroxyl radicals in the atmosphere. Second order rate constants 

(kOH) for this reaction can be estimated from chemical structure using the Syracuse 

Research Corporation AOP (version 1.86; the program is based on the Atkinson method 

recommended in the TGD), and example calculations have been given in Table 3.12. 

The estimated atmospheric half-lives are based on an atmospheric hydroxyl radical 

concentration of 5×105

 molecule/cm3. 

Table 3.12 Estimated atmospheric half-lives for LCCPs 

Formula Chlorine 

content 

(% wt. Cl) 

kOH

(cm3

/molecule s) 

Atmospheric half-life 

C18H33Cl5 41.6 1.27×10-11 30.3 hours 

C18H30Cl8 53.6 9.83×10-12 39.2 hours 

C20H36Cl6 43.6 1.47×10-11 26.2 hours 

C20H33Cl9 53.9 1.05×10-11 36.7 hours 

C25H45Cl7 41.9 1.88×10-11 20.5 hours 

C25H42Cl10 50.9 1.53×10-11 25.2 hours 

C25H29Cl23 71.3 3.43×10-12 112 hours 

C30H53Cl9 43.6 2.14×10-11 18.0 hours 

C30H49Cl13 53.0 1.79×10-11 21.5 hours 

C30H35Cl27 70.8 5.51×10-12 69.9 hours 

The predicted data indicate that for a given chlorine content, the half-life in air would be 

expected to decrease with increasing carbon chain length. Conversely, for a given 

carbon chain length, the predicted half-life increases with increasing chlorine content. 

3.2.2 Aquatic degradation 

3.2.2.1 Abiotic degradation 

In aqueous systems, LCCPs are not expected to degrade significantly by abiotic 

processes such as hydrolysis or direct photolysis. 

3.2.2.2 Biodegradation 

The biodegradation of a C20–30, 42% wt. Cl product has been determined in a prolonged 

Biochemical Oxygen Demand (BOD) test (Madeley and Birtley, 1980). The test was 

carried out using an emulsion of the chlorinated paraffin. First, a concentrated emulsion 

was prepared in distilled water. This was left to stand for 24 hours and a sub-sample of 

the emulsion was taken and the concentration of chlorinated paraffin in the emulsion 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 89

analysed by infrared spectrophotometry after solvent extraction. The emulsion was then 

added to BOD dilution water at concentrations of 2, 10, and 20 mg/l and the microbial 

seed was added. Two microbial populations were used in the study: firstly a culture from 

soil collected close to a chlorinated paraffins production plant that was acclimatised over 

an eight week period to a concentration of 20–50 mg/l of the chlorinated paraffin; and 

secondly, a non-acclimatized culture obtained from the effluent of a laboratory activated 

sludge unit treating domestic sewage. Replicate BOD bottles were used for each test 

concentration and the concentration of dissolved oxygen remaining at various times was 

measured. The results are shown in Table 3.13 (it is not clear to which test 

concentration the results refer). The results indicate some potential for degradation with 

acclimated microorganisms. 

Table 3.13 BOD values for LCCPs (Madeley and Birtley, 1980) 

Substance Microorganism BOD (g O2/g substance) 

source 

Day 10 Day 15 Day 20 Day 25 

Approx. % 

biodegradationa

at day 25 

C20–30, 42% non-acclimated 0.16 0.18 0.31 0.14 7.5 per cent 

wt. Cl. acclimated 0.01 0.14 0.37 0.43 23 per cent 

Note: a

 The approximate percentage biodegradation has been estimated from the 

BOD/ThOD ratio. The ThOD (theoretical oxygen demand) has been estimated 

(ThOD (g O2/g substance) = 16[2×c+0.5×(h-cl)]/mw; where c=number of carbon 

atoms, h=number of hydrogen atoms, cl=number of chlorine atoms and MW = 

molecular weight) for an example formula of the commercial substance as 

follows: 42% wt. Cl (C25H45Cl7), ThOD=1.86 g O2/g substance. Slightly different 

degradation percentages would be obtained if other example formulae were 

used. 

To investigate the potential for degradation further, Madeley and Birtley (1980) carried 

out a series of experiments using a 14C-labelled pentacosane (radiolabelled on the 

central carbon) mixed with the same C20–30, 42% wt. Cl product in Hach respirometers 

with non-acclimated microorganisms. After eight weeks incubation, around 11 per cent 

of the 14C was collected as 14CO2, indicating that where degradation had occurred it was 

extensive enough to release the central carbon atom of the C25 chain. 

In addition to the above studies, Madeley and Birtley (1980) also reported preliminary 

studies investigating the degradation of the C20–30, 42% wt. Cl product under anaerobic 

conditions. The anaerobic bacteria were obtained from anaerobic sludge digesters. Gas 

production (methane and CO2) in the presence of increasing quantities of an emulsion 

of the chlorinated paraffin was determined over 30 days and compared with controls. 

No significant increase or decrease in bacterial activity was seen at concentrations of 

the chlorinated paraffin of up to 10 per cent by weight of dry sludge solids. It was 

concluded that the substance was not toxic to the bacterial population present but also 

was not actively degraded under these conditions. 

Howard et al. (1975) report the results of unpublished biodegradation studies on LCCPs 

carried out by Hildebrecht (1972). The degradation (determined by oxygen 

consumption) was studied over 20 hours using a Warburg respirometer or over five days 

using a BOD method. The sewage seed used was acclimated to up to 100 mg/l of 

chlorinated paraffins before use in the test. The details of the substances tested and the 

results obtained are shown in Table 3.14. The validity of these results is questionable as 

the test solutions contained a surfactant (and in some cases other carbon sources) that 
90 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

may have been biodegradable under the conditions of the test. Unidentified nutrients 

were also added to the test which may also have contributed to the BOD seen if they 

were biodegradable. In addition, the extent of degradation was determined by the 

authors by comparing the oxygen consumption in the test with the theoretical oxygen 

demand (ThOD) based on oxidation to CO2 of the total organic carbon present in the 

solution from all sources. Howard et al. (1975) also indicates that the estimation of 

ThOD by this method is only approximate as it does not account for any oxygen 

consumed in the formation of water from available hydrogen. Therefore, the results refer 

to the biodegradability of the formulation tested rather than the actual chlorinated 

paraffin component of the formulation and so it is not possible to draw definite 

conclusions as to the degradability of the chlorinated paraffins in these tests. 

Table 3.14 Biodegradation results of Hildebrecht (1972) 

Chlorinate Warburg respirometry BOD dilution method 

d paraffin 

Formulation 

tested 

Oxygen 

consumption 

(mg/l) 

Degradationa BOD 

(mg/l) 

Degradationa 

C>20, 40–

42% wt. Cl 

500 mg/l of a 

mixture containing 

75% chlorinated 

paraffin, 5% 

surfactant and 20% 

water. 

83 17.2% 120 25% 

C>20, 70% 

wt. Cl 

500 mg/l of a 

mixture containing 

37.5% chlorinated 

paraffin, 37.5% 

perchloroethylene, 

5% surfactant and 

20% water. 

298 17.2% 30 2% 

500 mg/l of the 

surfactant. 

377 46.5% 530 65% 

Note: a Degradation was estimated by the authors as the percentage of the theoretical 

oxygen demand based on the total carbon content of the test solution. 

Substances other than the chlorinated paraffin contribute to this total carbon 

content. 

Hoechst AG (1976 and 1977) reported five-day biochemical oxygen demand (BOD5) 

values for various LCCPs. Few details of how the tests were carried out are given. The 

results are reported in Table 3.15 and show little or no biodegradation when compared 

with the measured chemical oxygen demand (COD) values. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 91

Table 3.15 BOD5 and COD values for various LCCPs (Hoechst AG, 1976 and 

1977) 

Chemical COD 

(mg O2/g) 

BOD5

(mg O2/g) 

Percentage 

biodegradation 

C18–20, 35% wt. Cl 1,720 12 0.7% 

C18–20, 44% wt. Cl 820 <10 <1.2% 

C18–20, 49% wt. Cl 440a <10 <2.3% 

C18–20, 52% wt. Cl 1,620 <10 <0.6% 

Note: a The COD value was not reproducible. 

The removal of LCCPs has been studied using non-adapted activated sludge. Few 

experimental details of the test conditions used are reported. However, removal was 

determined by chemical oxygen demand determination, presumably of effluent or water 

in the system. The substances tested were a C18–20, 35% wt. Cl product, a C18–20, 44% 

wt. Cl product, a C18–20, 49% wt. Cl product and a C18–20, 52% wt. Cl product. In all 

cases, removal was reported to be >90 per cent over five and 10 days, but it was also 

indicated that the majority of the removal was by adsorption onto the sludge rather than 

biodegradation (Hoechst AG, 1976 and 1977). 

The degradation of several LCCPs has been studied by Omori et al. (1987) using a 

variety of bacterial cultures. The LCCPs studied had average chemical formulae of 

C24.5H44.5Cl6.5 (40.5% wt. Cl), C24.5H41Cl10 (50% wt. Cl) and C24.5H30Cl21 (70% wt. Cl) and 

degradation was studied by monitoring the release of chloride ion. First, degradation of 

the 40.5% and 70% wt. Cl chlorinated paraffin was studied using resting cell cultures of 

Pseudomonas aeroginosa, Achromobacter delmarvae, A. cycloclastes, Micrococcus sp. 

and Corynebacterium hydrocarboclastus grown on glycerol. These bacteria had 

previously been shown to degrade 1-chlorohexadecane as well as some other monoand dichlorinated alkanes. 

Little or no degradation (chloride release) was observed when the 70% wt. chlorinated 

paraffin was incubated with the bacteria for 24 hours at 30°C. However, chloride was 

found to be released from the 40.5% wt. Cl chlorinated paraffin, with the highest 

amounts being seen with A. delmarvae and A. cyclocastes (36 and 25 mg/l respectively) 

and lower amounts from Micrococcus sp. (17 mg/l), C. hydrocarboclastus (12 μg/l) and 

P. aeroginosa (4–5 mg/l). The initial chlorinated paraffin concentration in these 

incubations was 10 mM, which for the 40.5% wt. Cl substance corresponds to 5.7 g/l (or 

2.3 g/l of chlorine), and so 36 mg/l of chloride released represents around 1.6 per cent 

of the total available. 

For the co-metabolic degradation studies, bacterial strains (designated HK-3, HK-6, HK8 and HK-10) were isolated from soil using an enrichment culture containing nhexadecane as the sole carbon source. The co-metabolic biodegradation experiments 

were carried out using the single bacterial strains (HK-3, HK-6 or HK-8) incubated at 

30°C for 48 hours in mineral medium containing 0.05 per cent (i.e. 500 mg/l) nhexadecane and 0.1 per cent (i.e. 1,000 mg/l) of either the 40.5%, 50% or 70% wt. Cl 

chlorinated paraffin. In addition, biodegradation of both the 40.5% wt. Cl and 70% wt. Cl 

products (concentration equivalent to 180 mg Cl in 1.2 litres) was studied under similar 

conditions (36 hour incubations) using a mixed bacterial inoculum (containing all four 

strains) previously exposed to 5,000 mg/l of n-hexadecane. A final study was carried out 

by inoculating the co-metabolic culture broth from bacterial strain HK-3 (after 

autoclaving) with another bacterium (strain H15-4) that had been shown to release 

chlorine from 2-chlorinated fatty acid (a possible metabolite of the chlorinated paraffins). 

The results of these test are shown in Table 3.16. 
92 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

The authors concluded that the degradation seen was consistent with that previously 

observed for other chlorinated alkanes in that a variety of enzymes are required to 

degrade chlorinated paraffins and that the most likely mode of degradation involves 

firstly dechlorination of the terminal methyl groups, with subsequent oxidation to form 

chlorinated fatty acids, which are then broken down to 2- or 3-chlorinated fatty acids via 

β-oxidation. 

Table 3.16 Results of dechlorination experiments (Omori et al., 1987) 

Chlorinated Chloride release over 48 hours incubation (mg/l) 

paraffin 

(average 

formula) 

Bacterial 

strain HK-3 

Bacterial 

strain H15-4 

Bacterial 

strain HK-6 

Bacterial 

strain HK-8 

Mixed bacterial 

culture (HK-3, 

HK-6, HK-8 and 

HK-10) 

C24.5H44.5Cl6.5

(40.5% wt. 

Cl) 

40 (9.9%)a, b 13%a 9 (2.2%)a 14 (3.5%)a 50 (33%)a 

C24.5H41Cl10 

(50% wt. Cl) 

15 (3.0%)a 9%a 9 (1.8%)a 13 (2.6%)a 

C24.5H30Cl21

(70% wt. Cl) 

18 (2.6%)a 12%a 10 (1.4%)a 12 (1.7%)a 22 (15%)a 

Notes: a Chloride release expressed as a percentage of the total present in the 

chlorinated paraffin. 

b

 The pH of the culture medium fell as dechlorination proceeded and may have 

inhibited growth of the microorganism and hence further dechlorination. 

Allpress and Gowland (1999) identified a bacterium (Rhodococcus sp.) that was able to 

grow using various chlorinated paraffins as sole source of carbon and energy. The 

bacterium was isolated from stream water from an industrial area of the United Kingdom 

using a minimal salts medium containing one per cent by volume of a C14–17, 45% wt. Cl 

chlorinated paraffin product. The ability of this bacterium to utilise LCCPs was 

investigated by inoculating minimal salts medium containing one of two LCCPs (a C18–20, 

48% wt. Cl product and a C>20, 42% wt. Cl product) at a concentration of one per cent by 

volume and determining the chloride release compared with controls over 71 days of 

incubation at 20°C. The test media also contained anti-bumping granules to aid 

dispersion of the test substance within the media. 

Both of the LCCPs tested were used by the bacterium and 11 per cent (C18–20, 48% wt. 

Cl product) and 14 per cent (C>20, 42% wt. Cl product) of the chlorine present in the 

chlorinated paraffins was released as chloride after 71 days. Several other chlorinated 

paraffins were tested using this system and it was concluded that the Rhodococcus sp. 

identified in the study was able to utilise chlorinated paraffins as sole source of carbon 

and energy, but little or no utilisation occurred with chlorinated paraffins with high 

degrees of chlorination (at or above around 59–60% wt. Cl). 

Zitko and Arsenault (1974 and 1977) reported the results of a study to determine the 

biodegradation of two LCCPs in spiked estuarine sediments under both aerobic and 

anaerobic conditions. The substances tested were a C>20, 42% wt. Cl product and a 

C>20, 70% wt. Cl product. The tests were carried out in flasks containing 25 g of 

sediment, 300 ml of sea water and 10 ml of a suspension of decomposing organic 

matter in sea water. Three flasks were used in the experiment, one for each of the two 

products tested, and a third acting as control. The flasks were incubated at 19–22°C 

with aeration for 28 days (the volume of water was kept constant by adding distilled 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 93

water during the test). In addition to these, another identical set of three flasks were kept 

stoppered over the exposure period. Samples of sediments were collected at various 

times during the experiment and analysed for the presence of the chlorinated paraffins. 

The results are shown in Table 3.17. 

Table 3.17 Biodegradation in sediments (Zitko and Arsenault, 1974 and 1977) 

Time Concentration of chlorinated paraffin (mg/kg dry weight) 

Aerated flasks Stoppered flasks 

 C>20, 42% wt. Cl C>20, 70% wt. Cl C>20, 42% wt. Cl C>20, 70% wt. Cl 

0 days 596 357 596 357 

10 days 257 76 80 41 

21 days 147 128 194 33 

28 days 377 72 98 50 

The analytical method used in the degradation experiments was based on 

microcoulometry. This method detects the presence of chlorine and so will detect all 

chlorinated compounds present, but may also suffer from interference from sulphur and 

nitrogen compounds. Interferences were found to occur in the control and the sediment 

spiked with the C>20, 42% wt. Cl product, but these were found to be reasonably volatile 

and could be effectively removed by drying the sediment at 46°C at reduced pressure 

(27 psi) overnight. The effect of this treatment on the recoveries of the chlorinated 

paraffins is not given, but the concentrations reported are corrected for overall recovery 

and background measurements in the control. 

After 30 days, all the remaining sediments were dried and analysed for chlorinated 

paraffins and breakdown products using thin layer chromatography and infra-red 

spectrophotometry. Only trace amounts of the chlorinated paraffins could be detected, 

and there was evidence for more polar metabolites (as shown by thin layer 

chromatography) being present. 

The results from this experiment show that primary degradation of LCCPs occurred to 

some extent in these tests. The extent of primary degradation appears to have been 

greater in the stoppered flasks than in the aerated flasks. The paper interprets this as 

representing a higher rate of degradation in anaerobic conditions than aerobic 

conditions. However, this interpretation should be treated with caution as it assumes 

that the stoppered flasks were anaerobic, but no information is given in the paper to 

show that this was the case (i.e. for instance the flasks had effectively 200 ml of 

headspace, and the actual oxygen content of the stoppered flasks is not given). 

3.2.2.3 Degradation products 

Little information is available on the possible degradation products of LCCPs. Of 

possible concern for the environment would be if the LCCPs were broken down to give 

the more bioavailable short- and medium-chain chlorinated paraffins in the environment. 

This possibility is unlikely to be significant for the reasons outlined below. 

The two main forms of biodegradation possible are aerobic and anaerobic degradation. 

Under aerobic conditions, the most likely mechanism for degradation would be ßoxidation, which would lead to chain shortening by two carbon units each time, but more 
94 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

importantly would also lead to oxidation of the terminal carbon, usually forming an acid 

group. Also, such processes tend to progress step-wise down the carbon chain and 

there is no reason why, if degradation did occur, it would stop at a carbon chain length 

of C10-13. 

The co-metabolic degradation experiments carried out by Omori et al. (1987), 

mentioned in the preceeding section, indicated that ß-oxidation to form initially 

chlorinated fatty acids which are then broken down to 2- or 3-chlorinated fatty acids was 

the most likely degradation mechanism for chlorinated paraffins. It is unlikely that shortor medium-chain chlorinated paraffins themselves would be formed under such 

conditions from LCCPs. 

Under anaerobic conditions, most chlorinated compounds appear to degrade by 

reductive dechlorination, which removes chlorine from the molecule but would not be 

expected to alter the carbon chain length. This sort of reaction has been most 

extensively studied for halogenated aromatics, but substances such as 

tetrachloroethylene and trichloroethylene appear to degrade in a similar way. Again, 

even if chain shortening did occur as well, there is no reason why the reaction would 

stop at C10–13 and so it is unlikely that short- or medium- chain chlorinated paraffins 

would be formed as a result of these types of reactions. 

3.2.3 Degradation in soil 

No data are available on the degradation of LCCPs in soil systems. 

3.2.4 Evaluation of environmental degradation data 

No standard-ready or inherent biodegradation test results are available for LCCPs. From 

the available data, LCCPs can be considered as not biodegradable in such systems and 

so a biodegradation rate constant of 0 day-1 will be used for all types of LCCPs in the 

risk assessment. 

There is evidence that some microorganisms may be capable of degrading LCCPs in 

the environment in acclimated or co-metabolic systems. The potential for biodegradation 

appears to increase with decreasing chlorine content. There is also some evidence that 

biodegradation may occur under anaerobic conditions, although it is not clear whether 

anaerobic conditions were actually maintained in the test. It is not possible to derive rate 

constants for biodegradation in soil, surface water and sediment systems from the 

available data. As a worst case approach, no biodegradation will be assumed in these 

media in the PEC calculations. The actual biodegradation rate used in the assessment 

has little effect on the local PECs, but has a major effect on the predicted regional and 

continental concentrations. This issue is considered further in Appendix E. 

Hydrolysis and aquatic photolysis is not expected to be a significant degradation 

process for LCCPs in the environment. 

LCCPs are predicted to react with hydroxyl radicals in the atmosphere. For this 

assessment, the atmospheric half-lives given in Table 3.18 will be taken as being 

representative of the various subgroups considered. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 95

Table 3.18 Atmospheric half-lives of LCCPs 

Subgroup Best estimates 

C18–20 liquids 

(typically 40–52% wt Cl) 

30 hours 

C>20 liquids 

(typically 40–54% wt. Cl) 

25 hours 

C>20 solids 

(typically 70% wt. Cl) 

110 hours 

For the marine environment, experiments have been carried out to investigate the 

biodegradation of two LCCPs in a sea water/estuarine sediment system. These provide 

some indication of degradation but it is not possible to derive any biodegradation rates 

applicable to the marine environment from these data. 

3.2.5 Environmental partitioning 

The potential environmental distribution of LCCPs has been studied using a generic 

level III fugacity model. The model used was a four compartment model (EQC version 

1.01, May 1997) that has been circulated for use within the OECD HPV program. The 

model was run four times with a nominal release rate of 1,000 kg/hour, initially entering 

the air, soil or water compartments in different proportions. A summary of the results is 

given in Table 3.19. Further details of the input values used and the model output are 

given in Appendix C. 

The results of the fugacity modelling indicate that LCCPs are likely to be associated with 

the soil and sediment compartments. When the substances are released to air, the 

model predicts that they will end up mainly in soil, probably as a result of atmospheric 

deposition processes. When the substances are released to water, the model predicts 

that the vast majority of the substance will be associated with sediment, but some would 

also be expected to occur in the water phase. When the substance is released to soil, it 

is predicted to remain mainly in the soil compartment, but a small amount may also 

enter the sediment compartment, possibly as a result of wash-off from the soil to water. 

Very little of the substance released to water is predicted to enter the soil phase, 

indicating that transport processes such as volatilisation to the atmosphere and 

subsequent deposition are not likely to occur for these substances. However, the key 

input parameter into this prediction is the Henry’s Law constant. The model estimates 

this value from the vapour pressure and water solubility of the substance. As discussed 

in Section 1.4.8.3 there are large uncertainties in the reliability of the Henry’s Law 

constants estimated for LCCPs from the available vapour pressure and water solubility 

data. The "best" estimates for the Henry’s Law constants are 16 Pa m3

/mole for C18–20

liquid chlorinated paraffins, 15 Pa m3

/mole for C>20 liquid chlorinated paraffins and 1×10-

6

 Pa m3/mole for the C>20 solid chlorinated paraffins. These values indicate that transport 

from water to the atmosphere is not likely to be significant for the C>20 solid chlorinated 

paraffins, but may be more significant than predicted here for the C18–20 liquid and C>20

liquid chlorinated paraffins. 

From the fugacity modelling results it is clear that most of the LCCP in the environment 

would be expected to be associated with the soil and sediment phases. 
96 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.19 Results of level III fugacity modelling for LCCPs 

Release compartment 

Percentage distribution 

(%) 

Air Water Soil 

C18–20

liquid 

C>20

liquid 

C>20

solid 

C18–20

liquid 

C>20

liquid 

C>20

solid 

C18–20

liquid 

C>20

liquid 

C>20

solid 

100% to air 1.14 

×10-3

4.45 ×10-4

3.68 ×10-4

3.40 ×10-3



3.35 ×10-3

3.34 ×10-3

99.6 99.6 99.6 

100% to water 7.12 

×10-6

2.78 ×10-7

8.08 ×10-24

0.853 0.857 0.858 0.625 0.062 2.19 

×10-1

100% to soil 7.05 

×10-8

2.35 ×10-9

6.37 ×10-24

3.01 ×10-3

3.01 ×10-3

3.01 ×10-3

99.6 99.6 99.6 

50% to air and 50% to water 

1.12 ×10-3

4.41 ×10-4

3.66 ×10-4

0.018 0.012 8.45 

×10-3

97.9 98.6 99.0 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 97

3.2.6 Adsorption 

3.2.6.1 Experimental data 

No experimental adsorption coefficients appear to be available for LCCPs. 

3.2.6.2 Predicted data 

Organic carbon-water partition coefficients (Koc) can be estimated from log Kow using 

the methodology outlined in the TGD. The equation given for predominantly hydrophobic 

chemicals is: 

 log Koc = 0.81×log Kow + 0.10 

Definitive determinations of Koc values using short-chain chlorinated paraffins have 

indicated that the above equation is applicable to chlorinated paraffins (Thompson et al., 

1998). Using this equation, the following values for Koc can be estimated: 

 C18–20 liquid chlorinated paraffin log Kow = 9.7 Koc = 9.06×107

 l/kg 

 C>20 liquid chlorinated paraffin log Kow = 10.3 Koc = 2.77×108

 l/kg 

 C>20 solid chlorinated paraffin log Kow = 17 Koc = 7.4×1013 l/kg 

The validity of the equation for very high log Kow values is not known. 

Koc values for several LCCPs have also been estimated using the Syracuse Research 

Corporation PCKOC (version 1.63) program. This estimates Koc values from chemical 

structure using a molecular connectivity index approach. The values obtained for 

several example structures are shown in Table 3.20. These estimates are reasonably 

consistent to those obtained above from log Kow. 

Table 3.20 Estimated Koc values for LCCPs from structure 

Formula % wt. Cl Koc (l/kg) 

C18H33Cl5 41.6 2.93×106 

C18H30Cl8 53.6 1.27×107 

C20H36Cl6 43.6 1.61×107 

C20H33Cl9 53.9 7.00×107 

C25H45Cl7 41.9 5.58×108 

C25H42Cl10 50.9 2.42×109 

C25H29Cl23 71.3 1×1010 a 

C30H53Cl9 43.6 1×1010 a 

C30H49Cl13 53.0 1×1010 a 

C30H35Cl27 70.8 1×1010 a 

Note: a Upper limit of estimation method. 

The high Koc value estimated for LCCPs indicates that the substance is expected to be 

relatively immobile in soil and would not be expected to leach from soil into 
98 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

groundwater. Vertical movement of LCCPs adsorbed onto soil particulates via 

macropores may provide a transport mechanism in soil. 

3.2.6.3 Summary of adsorption data 

No experimental data are available for LCCPs. The following estimated values will be 

considered in the risk assessment: 

 C18–20 liquid chlorinated paraffin Koc = 9.06×107

 l/kg 

 C>20 liquid chlorinated paraffin Koc = 2.77×108

 l/kg 

 C>20 solid chlorinated paraffin Koc = >1×1010 l/kg 

The very high values for Koc indicate that LCCPs will adsorb strongly onto sediments 

and soil and will not leach significantly from soil. 

Appendix E considers the effects of varying the log Kow value (and hence predicted 

Koc) on the overall outcome of the risk assessment. 

No data are available specific to the marine environment. The estimated Koc values are 

considered to be representative. 

3.2.7 Volatilisation 

LCCPs have low, but measurable, vapour pressures at ambient temperatures. 

Therefore they are predicted to volatilise only slowly from articles in use (although 

volatilisation could be more extensive at elevated temperatures). Once in the 

environment, LCCPs could also volatilise slowly from water or soil etc., but in these 

compartments volatilisation is likely to be mediated to a large extent by strong 

adsorption of the LCCPs to sediment and soil. The potential for volatilisation is expected 

to reduce with both increasing carbon chain length and increasing chlorine content (i.e. 

in line with the expected trends in the decrease in vapour pressure and increase in 

adsorption to soil and sediment). 

3.2.8 Precipitation 

LCCPs have a very low water solubility and so are unlikely to be significantly removed 

from the atmosphere in precipitation in the dissolved phase. However, LCCPs are 

expected to adsorb strongly onto atmospheric particulates which could then be washed 

out of the atmosphere by precipitation (or deposited by dry deposition processes). Thus 

transfer from the atmosphere to soil and surface water could occur via atmospheric 

particulates. 

3.2.9 Bioaccumulation and metabolism 

3.2.9.1 Bioconcentration from water 

Bengtsson et al. (1979) studied the uptake of an LCCP by bleak (Alburnus alburnus). 

The chlorinated paraffin tested was a C18–26, 49% wt. Cl substance. The tests were 

performed at 10°C using a semi-static procedure in which the test solutions containing 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 99

125 μg/l of the test substance were renewed every two to three days over the 14-day 

exposure period. A seven-day depuration period followed the 14-day exposure period. 

The water used in the experiment was Baltic Sea water with a salinity of 7‰, and 

acetone was present in all aquaria, including controls, at a concentration of 0.1 ml/l. The 

fish used in the experiment had an average weight of 4.5 g and were not fed during the 

exposure period. Six groups of 15 fish were used for both the exposure and control 

solutions. 

No mortalities or effects on behaviour were seen in fish exposed to the LCCP during the 

test. Very little uptake of the chlorinated paraffin occurred during the exposure period, 

with whole body levels of the LCCP of around 1–2 mg/kg fresh body weight (read from 

graph) being determined at 14 days. From this value a BCF of around 8–16 l/kg can be 

estimated. A reduction in the body concentration occurred during the seven-day 

depuration period. The analytical method used (neutron activation analysis) is not 

specific for the chlorinated paraffin and so may also include any chlorinated metabolites 

present in the fish, which may result in an overestimate of the actual chlorinated paraffin 

concentration in the fish if substantial metabolism was occurring. 

In this experiment the concentration tested was above the water solubility of the 

substance in pure water, leading to the possibility that not all the test substance was 

present in true solution in the experiment. Also, the exposure period in the study is 

relatively short and so it is not certain that equilibrium would have been reached. 

The accumulation of two LCCPs has been studied in rainbow trout (Oncorhynchus 

mykiss) over 60 days in GLP studies (Madeley and Maddock, 1983a and b). The 

investigations were carried out as part of a long-term toxicity test, and the 

bioconcentration factors were determined only at the end of the study. The substances 

tested were commercial products (either a C22–26, 43% wt. Cl product or a C>20, 70% wt. 

Cl product) mixed with a n-pentacosane-13-14C that had been chlorinated to a similar 

degree. A flow-through system was used for each test and the concentrations of 

chlorinated paraffin were measured by both radioactivity measurements and parent 

compound analysis (using a thin layer chromatography (TLC) method). The tests were 

carried out at a temperature of 12±1°C. Fish were fed with a proprietary trout food 

throughout the test at a rate of two per cent of body weight/day. Further details of the 

test system used can be found in Section 4.1.1. 

For the C22–26, 43% wt. Cl substance (Madeley and Maddock, 1983a), two nominal 

exposure concentrations of 1.0 mg/l and 3.2 mg/l were used. In order to provide stable 

test solutions/suspensions, acetone at a concentration of 500 ppm (0.5 ml/l) was also 

present in the tests. The actual mean measured concentrations found during the test 

were 0.97 and 4.0 mg/l at the two exposure concentrations respectively, based on 

regular 14C-measurements. On five occasions during the tests parent compound 

analyses were also carried out. These gave mean measured concentrations of 0.76 mg/l 

and 2.2 mg/l for the two exposure concentrations respectively, and were in general 

agreement with the 14C-measurements. No treatment-related mortalities occurred during 

the test. The BCFs determined were 17.9–37.6 l/kg, based on 14C measurements in 

whole fish and 3.6–9.0 l/kg based on parent compound analysis in whole fish, with the 

higher BCF values being found at the higher exposure concentrations. 

For the C>20, 70% wt. Cl substance (Madeley and Maddock, 1983b) three nominal 

exposure concentrations of 1.0 mg/l, 2.1 mg/l and 4.2 mg/l were used. In order to 

provide stable test solutions/suspensions, acetone at a concentration of 500 ppm (0.5 

ml/l) for the two lower concentrations or 1,000 ppm (1 ml/l) for the highest concentration 

was also present in the test. Monitoring of the actual test concentrations by 14Cmeasurements indicated that the mean measured concentrations were 0.84 mg/l, 1.9 
100 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

mg/l and 3.8 mg/l at the three test concentrations respectively. Parent compound 

analysis of the exposure concentrations on five occasions during the test gave similar 

results (mean measured levels were 0.6 mg/l, 1.0 mg/l and 2.1 mg/l at the three 

concentrations respectively). No treatment-related mortalities occurred during the test, 

although some behavioural effects were seen in both the control and exposed 

populations during the test. The BCFs determined were 5.7–53.8 based on 14Cmeasurements in whole fish, and 1.0–42.8 mg/l based on parent compound analysis of 

the levels in whole fish. 

In this experiment, the highest BCF values were obtained in the experiments with the 

lowest exposure concentration. The BCF determined in the 1.9 mg/l exposure groups 

(5.7 based on 14C-measurments and 1.0 based on parent compound measurements) 

was lower than that found at the other two concentrations (32.5–53.8 based on 14Cmeasurements and 31.6–42.8 based on parent compound analysis). The results of the 

Madeley and Maddock (1983a and 1983b) studies are summarised in Table 3.21. 

Madeley and Thompson (1983a and 1983b) determined bioconcentration factors in 

mussels (Mytilus edulis) at the end of a 60-day toxicity study using the same two LCCPs 

as used in the Oncorhynchus mykiss studies above (GLP study). The test substances 

were dissolved in acetone before dilution with sea water (salinity 34.0–35.5‰, pH 8.0–

8.3, dissolved oxygen 6.1–8.25 mg/l, temperature 15°C). The test used a flow-through 

system in order to maintain the concentration in the exposure vessels but, as the study 

was actually designed to determine the toxicity to mussels, relatively high nominal 

concentrations of the test substances were used and the BCFs were only determined at 

the termination of the study. The organisms were fed with algae (Platymonas suecica) at 

a rate of 1.0–1.1×109

 cells/day. The alga were continuously added to the in-flowing 

dilution water. 

The mussels were exposed to the chlorinated paraffin via the water phase. However, 

adsorption to the algae with subsequent ingestion or direct ingestion of undissolved test 

substance could also have occurred. For the C22–26, 43% wt. Cl substance (Madeley and 

Thompson, 1983a), two nominal test concentrations of 0.32 and 3.2 mg/l were used. 

Acetone, at a concentration of 500 ppm (0.5 ml/l), was also present in the test solutions 

in order to produce stable solutions/dispersions. The highest test solution was reported 

to be cloudy in appearance, and some fine white deposits were observed occasionally 

on the surface. The mean measured exposure concentrations were determined to be 

0.12 and 2.18 mg/l based on frequent 14C-measurements throughout the test period. 

The mean exposure concentrations determined by parent compound (TLC) analysis on 

four occasions were 0.09 mg/l and 2.85 mg/l respectively, which are in reasonable 

agreement with the 14C-measurements. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 101

Table 3.21 Results of the 60-day rainbow trout bioconcentration studies (Madeley and Madd

Substance tested 

Measured exposure 

concentrations 

(mg/l) 

Measured concentration in whole fish after 60 

days exposure 

(mg/kg wet wt.) 

Measured 

(concentration i

14C-measurements 14C-measurements Parent compound 

measurements 

14C-measuremen

0 (control) - 1.2 - 0 (solvent control) - 1.1 - 

0.97 17.4 3.5 17.9 

C22–26, 43% 

wt. Cl 

4.0 150.2 36 37.6 0 (control) - 1.2 - 0 (solvent control) - 0.8-1.1 - 0.84 45.2 36 53.8 1.9 10.9 2.0 5.7 

C>20, 70% 

wt. Cl 

3.8 123.6 120 32.5 
102 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

No treatment-related mortality occurred during the test, however reduced filter feeding 

behaviour of the mussels compared with control organisms was consistently observed 

at the higher exposure concentration from day 7 onwards. The BCFs ((mg/kg wet 

mussel)/(mg/l test solution)) determined were 261–1,158 l/kg, based on 14C 

measurements in the mussels and 87.2–1,000 l/kg based on parent compound 

analysis in the mussels (Madeley and Thompson, 1983a); the BCF was found to be 

lower at the higher exposure concentration. The similarity between the values obtained 

by the two analytical methods indicates that the majority of the 14C present in the 

organism must have been as parent compound rather than metabolites. 

For the C>20, 70% wt. Cl substance (Madeley and Thompson, 1983b), two nominal 

concentrations of 0.56 and 1.8 mg/l were used. Acetone, at a concentration of 500 ppm 

(0.5 ml/l) was again present in the test solutions in order to produce stable 

solutions/dispersions. Some deposition of the test substance was observed at the 

higher concentration tested, indicating that the maximum solubility in the test system 

had been exceeded. The mean measured exposure concentrations were 0.46 mg/l and 

1.33 mg/l respectively, based on frequent 14C-measurements. The mean exposure 

concentrations determined by parent compound (TLC) analysis on four occasions were 

0.51 mg/l and 0.9 mg/l respectively, which are in reasonable agreement with the 14Cmeasurements. 

No treatment-related mortality or effect on filter feeding activity was observed during 

the test. The BCFs determined were 223–341 l/kg based on 14C measurements in the 

mussels and 105–167 l/kg based on parent compound analysis in the mussels. Again, 

the BCF was found to be lower at the higher exposure concentration. There was also 

reasonable agreement between the values obtained by the two analytical methods, 

indicating that the majority of the 14C found in the mussels must have been as parent 

compound rather than metabolites. 

The results of the Madeley and Thompson (1983a and 1983b) studies are summarised 

in Table 3.22. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 103

Table 3.22 Summary of the 60-day mussel bioconcentration studies (Madeley and Thompso

Substance tested 

Measured exposure concentrations (mg/l) 

Measured concentration in mussels after 60 days exposure (mg/kg wet wt.) 

Measured bioco(concentration water) (l/kg) 

14C-measurements 14C-measurements Parent compound 

measurements 

14C-measureme

0 (control) - 0.63 - 0 (solvent control) - 1.3 - 

0.12 138.9 120 1,158 

C>20, 43% 

wt. Cl 

2.18 569.7 190 261 0 (control) - 1.1 - 0 (solvent control) - 1.2 - 

0.46 157 77 341 

C22–26, 70% 

wt. Cl 

1.33 297.1 140 223 
104 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Discussion of bioconcentration data 

None of the available bioconcentration studies can be considered fully valid. All of the 

studies have used exposure concentrations in excess of the water solubility of the 

substance and indeed some of the tests appear to have been carried out using 

suspensions. In addition, there is no indication in the available studies that a steady 

state had been reached during the uptake phase. This means that these experiments 

may underestimate the true BCF of the substance. 

According to the TGD, the bioconcentration factor (BCF) for fish can be estimated from 

the following equation. 

 log BCF = -0.20×(log Kow)2

 + 2.74×log Kow - 4.72 

The equation applies to substances with log Kow >6 and molecular weights <700 

g/mole. The log Kow values for LCCPs range from around 7.5 to >12 (see Section 

1.4.6). The BCF values estimated using this equation over this range of log Kow values 

are shown in Figure 3.4. 

38,019

25,119

13,183

5,495

1,820 479 100 17 2.2 0.22

0

5,000

10,000

15,000

20,000

25,000

30,000

35,000

40,000

Estimated BCF (l/kg

7.5 8 8.5 9 9.5 10 10.5 11 11.5 12

Log Kow

Figure 6: Estimated BCF values

Figure 3.4 Estimated BCF values 

These data indicate that the BCF value is predicted to decrease with increasing log 

Kow, reaching a value of <100 when the log Kow value becomes >10.5. Thus, it is 

clear that at least some LCCPs are not expected to bioconcentrate to a significant 

extent. As discussed in Section 1.4.6, the log Kow values of LCCP are likely to 

increase with increasing carbon chain length and increasing degree of chlorination. 

This trend in the predicted BCF for LCCPs continues the trend found with the available 

fish BCF data for short-chain and medium-chain chlorinated paraffins. Here, reliable 

BCFs of 7,816 and 1,087 l/kg were determined for short-chain (log Kow ~6) and 

medium-chain (log Kow ~7) chlorinated paraffins respectively. Thus, based on 

comparison with the available data for other chlorinated paraffins, the fish BCF for 

LCCPs would be expected to further reduce with increasing carbon chain length. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 105

One explanation for the apparent fall-off of BCF with log Kow is that the molecule 

becomes too large to pass through cell membranes and so cannot be effectively taken 

up. This phenomenon is considered to occur when the diameter of the molecule 

reaches a certain size, and as a rough approximation this generally occurs at molecular 

weights of 700–800 g/mole and above. 

Since all chlorinated paraffins conform to the general formula CnH2n+2-yCly, it is relatively 

straight forward to determine the chlorine content for each value of n where this 

800 g/mole molecular weight limit may be reached. These values are shown in Table 

3.23. 

Based on these theoretical considerations, it is unlikely that the highly chlorinated (i.e. 

70% wt. Cl) LCCPs will undergo significant bioconcentration in fish. 

The BCF values selected for use in the assessment are summarised in Section 3.2.9. 

Table 3.23 Approximate chlorine contents resulting in a molecular weight of 

800 g/mole 

Number of carbon atoms 

(n) 

Calculated number of 

chlorine 

atoms/molecule 

Chlorine content of 

chlorinated paraffin 

18 15.0 66.0% wt. Cl 

19 14.6 64.7% wt. Cl 

20 14.2 63.0% wt. Cl 

21 13.8 61.3% wt. Cl 

22 13.4 59.6% wt. Cl 

23 13.0 57.9% wt. Cl 

24 12.7 56.2% wt. Cl 

25 12.3 54.5% wt. Cl 

26 11.9 52.8% wt. Cl 

27 11.5 51.1% wt. Cl 

28 11.1 49.4% wt. Cl 

29 10.7 47.7% wt. Cl 

30 10.4 46.0% wt. Cl 

3.2.9.2 Accumulation from sediment and soil 

The risk assessment methodology in the TGD considers uptake from soil into 

earthworms and into plants (root crops). 

Earthworms 

For earthworms, no measured BCF or uptake data are available for LCCPs and so a 

predicted value is used in the assessment. A number of approaches have been 

considered for predicting the BCF for earthworms. Firstly, the methodology outlined in 

the TGD has been used to estimate the BCF for earthworms from log Kow. The 

resulting BCF values are shown below. These BCF values relate the uptake in 

earthworms to the soil pore water concentrations of the substance. 
106 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

 BCFearthworm 

C18–20 liquid 6.0×107 l/kg 

C>20 liquid 2.4×108

 l/kg 

C>20 solid 1.2×1015 l/kg 

It should be noted that the method used for earthworms within the current TGD and 

EUSES is only valid for substances with log Kow of up to around 8. All three types of 

LCCPs considered in this assessment have log Kow values significantly above this 

value and so the above estimates are of questionable value to the assessment. In 

addition, as was noted earlier, the bioaccumulation potential of LCCPs appears to be 

lower than would be expected based on the high log Kow value alone. 

The reliability of the above TGD method has recently been studied in detail (Brooke 

and Crookes, 2007). In this study, the predictions obtained using the TGD method were 

compared with available experimental data from laboratory or field studies for a range 

of chemicals for both exposure via water only and exposure in whole soils. 

For the water only exposure, test data were available for 11 substances (pesticides and 

chlorobenzenes) covering a log Kow range from -0.47 to 5.50. For this test set, 

generally good agreement was found between the predicted earthworm BCF and the 

experimentally determined BCF. However, it should be noted that the test set did not 

include substances with log Kow values >6. 

A much larger test set of experimental data was available for whole soil exposure (both 

from field studies and laboratory studies). The test set contained 488 data points for 

around 107 substances covering an approximate log Kow range of 1 to 9.5. In this 

case, a comparison was made between the predicted accumulation and that actually 

measured by converting both datasets to a bioaccumulation factor (BAFearthworm) based 

on the concentrations in earthworms (mg/kg wet weight)/concentration in soil (mg/kg 

wet weight). This analysis showed the current TGD method consistently overpredicted 

the BAFearthworm (and hence the concentration in earthworms) for substances with a log 

Kow above about 4 to 5. Further, the overprediction appeared to increase linearly with 

increasing log Kow above this range. Based on these findings, Brooke and Crookes 

(2007) determined the following correction to the BAFearthworm by linear regression that is 

applicable to all substances with log Kow values in the range 1 to 9.5 provided that the 

Koc value is estimated using the QSAR for predominantly hydrophobic substances7. 

 log BAFearthworm_corrected = log BAFearthworm_predicted – (0.39×log Kow) + 1.72. 

In order to use this correction it is necessary to convert the earthworm BCF to a 

BAFearthworm value. This conversion is achieved using the default worm and soil 

properties laid out in the TGD. Brooke and Crookes (2007) showed that the BAFearthworm

can be related to the BCFearthworm and the organic carbon-water partition coefficient 

(Koc) using the following equation: 

 

7

 The methodology used by Brooke and Crookes (2007) required an estimate of the 

Koc value from log Kow. The analysis was carried out using both the TGD default 

QSAR for Koc (log Koc = 0.52×log Kow + 1.02), and the QSAR for predominantly 

hydrophobic chemicals (log Koc = 0.81×log Kow + 0.10). Similar results were obtained 

in both cases, but the final equation for the correction is slightly different when the TGD 

default QSAR is used rather than the QSAR for predominantly hydrophobic chemicals. 

For LCCPs, the QSAR for predominantly hydrophobic chemicals has been used to 

estimate the Koc values used in the assessment (see Section 3.2.6). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 107

1133.1

1133.0

)Koc03.0(2.0

BCF7.1

BAF

earthworm

earthworm

⎥

⎦

⎤ ⎢

⎣

⎡

+⎟

⎟

⎠

⎞

⎜

⎜

⎝

⎛

×+

×

=

Using these equations values for the BAFearthworm_predicted and BAFearthworm_corrected can be 

estimated for LCCPs (Table 3.24). 

Table 3.24 Estimated LCCP earthworm BAF 

Property C18–20 liquid C>20 liquid C>20 solid 

Log Kow 9.7 10.3 17 

Koc (Section 3.2.6) 9.06×107

 l/kg 2.77×108 l/kg 7.4×1013 l/kg 

(>1×1010 l/kg) 

BCFearthworm (TGD 

prediction – see 

above) 

6.0×107

 l/kg 2.4×108 l/kg 1.2×1015 l/kg 

BAFearthworm_predicted 33.9 kg/kg 44.1 kg/kg 825.5 kg/kg 

BAFearthworm_corrected 0.29 kg/kg 0.22 kg/kg 0.010 kg/kg 

For comparison, a measured BAFearthworm is available for the related medium-chain 

chlorinated paraffins (ECB, 2005a). The BAF measured was around 5.6 (on a wet 

worm (mg/kg)/wet soil (mg/kg) basis; this value is extrapolated to the default properties 

of soil used in the TGD). The value of the BAFearthworm_predicted that would be estimated 

using the TGD methodology for medium-chain chlorinated paraffins (log Kow of 7) 

would be around 11 and using the above correction this would lead to a 

BAFearthworm_corrected of around 1. In this case, both the predicted and corrected BAFs are 

of a similar order to the measured BAF. 

A third possibility for the estimation of the BCF for earthworms is to use an older 

method that was included in a previous version of the TGD. This method was used for 

medium-chain chlorinated paraffins (ECB, 2005a) and was found to give reasonable 

agreement with the measured data for that substance. The relevant equation, which 

relates the BAFearthworm (on a wet worm (mg/kg)/wet soil (mg/kg) basis), the octanolwater partition coefficient (Kow) and the soil-water partition coefficient (Ksoil-water) is 

given below (see ECB (2000a) for further details). 

watersoil

3

earthworm K

10700,1 BAF 16.0Kow25.0

−

− ×

×××=

The method was recommended for log Kow values in the range 1.0–6.5. For 

substances with a log Kow above this range, the method recommended that a Kow of 

3.16×106

 (i.e. a log Kow of 6.5) was used. For medium-chain chlorinated paraffins, the 

BAFearthworm predicted using this method was 12.2 which compares reasonably with the 

experimental value of 5.6. The BAF values estimated for LCCPs using this method 

(assuming a Kow of 3.16×106

 for all three substances) are summarised in Table 3.25

below. 
108 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.25 Estimates for BAFearthworm using alternative TGD method 

LCCP subgroup Ksoil-water (m3

/m3)

8

 BAFearthworm 

C18–20 liquid 2.72×106 0.080 

C>20 liquid 8.31×106 0.026 

C>20 solid >3.0×108

 <7.2×10-4

The estimates for the earthworm BAF for LCCPs obtained using the older TGD method 

are much lower (by a factor of around 400–1×106

) than those obtained using the 

current TGD methodology, but only about a factor of four to eight lower than those 

obtained by applying the correction to the current TGD method discussed above. 

A final method suggested by industry for estimating the earthworm BAF for LCCPs is to 

scale the measured BAF of 5.6 kg/kg determined for medium-chain chlorinated 

paraffins to LCCPs using the predicted BCF for fish as a scaler. Using a predicted fish 

BCF of 45,700 l/kg9

 for medium-chain chlorinated paraffins, 1,096 l/kg for C18–20 liquid 

chlorinated paraffins, 192 l/kg for C>20 liquid chlorinated paraffins and <1 l/kg for C>20

solid chlorinated paraffins, the following scaled earthworm BAF values can be 

estimated.

 BAFearthworm_scaled 

C18–20 liquid 0.13 kg/kg 

C>20 liquid 0.024 kg/kg 

C>20 solid <1.2×10-4 kg/kg 

This approach gives a similar value to the corrected TGD approach and the “old” TGD 

approach for the C18–20 liquid chlorinated paraffins, but a lower value than both methods 

for the C>20 liquid and C>20 solid chlorinated paraffins. However, the reliability of this 

“scaling” method can be questioned as it relies on the earthworm BAF being directly 

proportional to the predicted fish BCF. For example, the fish BCF estimates made 

using the TGD method rise with increasing log Kow, up until log Kow is around 7, and 

then decrease with increasing log Kow above this value. It is not known if the 

earthworm BAF actually follows the same trend. 

The values below (obtained using the correction to the current TGD methodology) will 

be used to estimate the uptake and accumulation in earthworms. These have been 

chosen because: 

• the methodology used for estimating the uptake into earthworms in the current 

TGD was designed to improve upon the methodology in the older versions of 

the TGD; 

• an extensive validation exercise has been carried out on the current TGD 

methodology and this identified a correction that could be applied to substances 

with very high log Kow values; 

 

8

 Values estimated from the organic carbon-water partition coefficient using the 

methods in the TGD. 

9

 Estimated using the TGD methodology for a substance with a log Kow of 7. The 

actual fish BCF for medium-chain chlorinated paraffins has been measured as 1,087 

l/kg (ECB, 2005a). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 109

• that there are uncertainties with the older methodology for substances with log 

Kow values above 6.5; 

• the uncertainty in using a fish BCF to “scale” the available data for mediumchain chlorinated paraffins to LCCPs. 

The values for BAFearthworm_corrected are: 

 BAFearthworm_corrected 

C18–20 liquid 0.29 kg/kg 

C>20 liquid 0.22 kg/kg 

C>20 solid 0.010 kg/kg 

Plant roots 

No experimental information is currently available on the uptake of LCCPs into plant 

roots and so predicted data are considered in the assessment. 

The partition coefficient between plant roots and water (Kplant-water) and the root-soil 

accumulation factors (BAFroot, which can be defined as the concentration in root (mg/kg 

wet weight)/concentration in soil (mg/kg wet weight)) that are predicted by the TGD 

methodology are summarised below for the LCCPs. 

 Kplant-water (m3

/m3) BAFroot (kg/kg) 

 C18–20 liquid 1.6×107

 14.6

 C>20 liquid 6.1×107 17.9

 C>20 solid 1.4×1014 <1.1×106 

When these values are used in the calculation of the total daily uptake in humans via 

the food chain the resulting estimated daily dose is dominated by the predicted 

concentration in root crops (root crops account for >99 per cent of the total daily dose; 

calculations not shown). However, the concentrations in root crops predicted by the 

model are in most cases unrealistically high and so the use of these default 

accumulation factors may lead to significant overestimation of the total daily intake. For 

example, in the regional calculations for the C>20 solid chlorinated paraffins the 

concentration predicted in root crops using the TGD default method is 1.9×104

 mg/kg, 

meaning that the root crop is essentially two per cent LCCP by weight – a value that is 

clearly unrealistic. 

A recent validation exercise of the methodology used in the TGD to estimate the 

uptake of chemicals into food has been carried out by Brooke et al. (2007). The study 

compared the predicted root uptake with that seen in studies using whole soil or 

nutrient solutions using a dataset consisting of around 122 datapoints for around 47 

chemicals covering a log Kow range between -0.5 and 9.1. 

The chemicals used in the study included various pesticides along with polycyclic 

aromatic hydrocarbons and chlorinated and brominated hydrocarbons, including a data 

point for medium-chain chlorinated paraffins. The analysis found that the current TGD 

methodology predicts the uptake into roots well for substances with a log Kow value up 

to around three. For substances with a log Kow value between three and four, there 

was a tendency for the TGD method to overpredict the actual uptake, but this 

overprediction was generally less than a factor of 10. For substances with log Kow 

values above four, the overprediction of the uptake became progressively worse with 

increasing log Kow. 
110 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

In particular, it was evident that the TGD method predicts the value for BAFroot

increases with increasing log Kow in this region, whereas the available experimental 

data shows a decreasing trend in the BAFroot with increasing log Kow. By normalising 

the available experimental data to a standard soil organic carbon content of two per 

cent, Brooke et al. (2007) derived the following equation relating the BAFroot to log Kow: 

 log BAFroot = -0.38×log Kow + 0.67 

However, it should be noted that there was considerable scatter in the data, and the 

correlation coefficient for the above regression equation was low (R2

 = 0.41). The 

estimated BAFroot, and the equivalent Kplant-water obtained using this equation for LCCPs 

are summarised below (Table 3.26). As can be seen, these values are considerably 

smaller than predicted above using the TGD methodology. 

Table 3.26 BAFroot and Kplant-water estimates for LCCP subgroups obtained using 

equation from Brooke et al. (2007) 

LCCP subgroup log Kow BAFroot (kg/kg) Kplant-water (m3

/m3) 

C18–20 liquid 9.7 9.6×10-4 1.1×103 

C>20 liquid 10.3 5.7×10-4 2.0×103 

C>20 solid 17 1.6×10-6 200 

Also relevant to the discussion here are the experimental data available on uptake from 

soil into root crops for the medium-chain chlorinated paraffins. These data are 

discussed in ECB (2007a). Here experiments carried out with carrot roots showed that 

the actual BAFroot for medium-chain chlorinated paraffins was 0.045 kg/kg and the 

equivalent Kplant-water of 330 m3

/m3, was around 136 times lower than would be predicted 

using EUSES. The log Kow value for medium-chain chlorinated paraffins is around 7 

and using this log Kow value in the above equation derived would lead to an estimated 

BAFroot of 0.010 which is of a similar order to that determined experimentally. 

Although it is not possible to extrapolate the measured BAFroot value for medium-chain 

chlorinated paraffins directly to LCCPs (the BAFroot depends on both the plant-water 

partition coefficient and the soil-water partition coefficient) it is reasonable to expect the 

actual bioaccumulation factor for LCCPs to be lower than that determined for mediumchain chlorinated paraffins. Therefore, it can be concluded that the contribution from 

root crops to the total daily intake for LCCPs is likely to be much lower than the default 

calculations predicted using the TGD methodology. 

Based on the above discussion, the values for the plant-water partition coefficient to be 

used in the risk assessment are given in Table 3.27. These values are derived from the 

analysis of the TGD methodology carried out by Brooke et al. (2007). Although there 

was considerable uncertainty in the regression equation used, it should be noted that 

these values for the Kplant-water are similar to (in the case of the C>20 solid chlorinated 

paraffins) or higher than (for the liquid LCCPs) the equivalent value for medium-chain 

chlorinated paraffins (Kplant-water = 330 m3

/m3) derived from laboratory studies and so 

there appears to be some conservatism built in to the use of these Kplant-water values. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 111

Table 3.27 Values for the plant-water partition (Kplant-water) to be used in the 

assessment 

LCCP subgroup log Kow BAFroot (kg/kg) Kplant-water (m3

/m3) 

C18–20 liquid 9.7 9.6×10-4 1.1×103 

C>20 liquid 10.3 5.7×10-4 2.0×103 

C>20 solid 17 1.6×10-6 200 

3.2.9.3 Dietary/oral accumulation 

The accumulation of a C18, 49% wt. chlorinated paraffin has been studied in juvenile 

rainbow trout (Oncorhynchus mykiss) (Fisk et al., 2000). The substance tested was a 

single carbon chain length product synthesised by the free-radical chlorination of a 14Clabelled C18-alkane with SO2Cl2. The product had an average formula of C18H30.3Cl6.7, 

but the position of the radio-label in the carbon chain was not stated. The food used 

during the test was a commercial fish food (41 per cent protein, 14 per cent lipid and 

three per cent fibre). The chlorinated paraffin was added to the food as a suspension in 

hexane followed by evaporation of the solvent. 

Two chlorinated paraffin concentrations were tested: 1.6 mg/kg wet wt. food and 15 

mg/kg wet wt. food. During the test, groups of 36 juvenile fish in flow-through tanks 

(initial weight 1–5 g, final weight 23–69 g) were fed the contaminated food (daily 

feeding rate was 1.5 per cent of mean weight of fish) over a 40-day period, followed by 

a 160-day depuration period using clean food. At various times during the experiment 

fish were sampled for 14C levels in the carcass (whole fish minus liver and 

gastrointestinal tract). All measured concentrations were corrected for growth dilution. 

At day 40 of the uptake phase and day 40 of the depuration phase the amount of nontoluene-extractable 14C-label present in carcass was also determined. This 

measurement was assumed to reflect the extent of biotransformation of the substance 

in fish. No effect on body and liver growth rates or liver somatic indices were seen 

between exposed and control populations during the test. 

The results indicated that the chlorinated paraffin uptake had not reached steady state 

by day 40 of the uptake phase and so the bioconcentration factor for uptake from food 

was determined kinetically. The assimilation efficiencies (based on lipid corrected 

concentrations in fish and food) were determined to be 13–22 per cent, and the 

depuration rate constant was estimated to be 0.0076–0.0088 d-1 (depuration half-life 

~79–91 days). There was little evidence for biotransformation of the chlorinated 

paraffin by the fish. Based on the measured kinetic parameters, the bioaccumulation 

factor (concentration in fish (lipid normalised)/concentration in food (lipid normalised) 

was around 0.81–0.93. 

The uptake and accumulation of a C20–30, 42% wt. Cl product has been studied using 

both rainbow trout (Oncorhynchus mykiss) and mussel (Mytilus edulis) (Madeley and 

Birtley, 1980). The chlorinated paraffin used was a 14C-pentacosane (radiolabel on the 

central carbon atom of the C25 chain) which had been chlorinated to 42 per cent by 

weight. This was then mixed with a commercial C20–30, 42% wt. product before use. The 

food used in the test was suspended yeast cells for mussel and a commercial trout diet 

for trout. The food was dosed with the chlorinated paraffin mixture prior to feeding of 

the organisms. 

In the trout studies, three groups of 40 fish were fed diets containing chlorinated 

paraffins at doses of either 0 mg/kg dry food (control group), 47 mg/kg dry food or 385 
112 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

mg/kg dry food for 35 days. After the 35 day exposure period, all three groups were fed 

the control diet for a further 49 days (depuration period). The temperature during the 

experiment was maintained at 12±3°C. No treatment related adverse effects were seen 

in any of the fish during the experiment. 

The resulting tissue concentrations (as determined by 14C-measurements) are shown 

in Table 3.28. The uptake of radioactivity was found to be highest in the liver and gut, 

with the concentrations found approaching those in the administered food. The levels in 

all tissues were found to increase with time during the exposure phase, but were all 

approaching a plateau level by day 35 of the exposure. During the depuration phase, 

the 14C-activity in both gut and liver was found to rapidly diminish. Based on the ratio of 

the concentration in fish at day 35 and the concentration in food, the bioaccumulation 

factor can be estimated to be 0.22–0.26 on a dry weight basis in this study. 

Table 3.28 Tissue concentrations of 14C in fish fed a diet of 14C-labelled 42% 

wt. Cl LCCP (Madeley and Birtley, 1980) 

Tissue concentration (based on 14C-measurements) 

(mg/kg dry weight) 

Dose Exposure phase 

Liver Gut Flesh Remains Total body 

burden 

End of 35-day uptake 

period 

47 29.5 36.4 2.5 6.8 10.3 

mg/kg 

dry food End of 49-day 

depuration period 

2.8 4.8 1.4 3.1 3.3 

End of 35-day uptake 

period 

385 263 353 23.1 66.3 100.6 

mg/kg 

dry food End of 49-day 

depuration period 

21.8 

(6.5)a 

47.3 

(5.4)a 

17.2 

(3.7)a

29.8 

(5.7)a 

31.6 

Note: a Concentration of chlorinated paraffin determined directly by TLC analysis. 

In addition to the 14C-analyses, some fish in the 385 mg/kg dry food dose group were 

also analysed for the parent chlorinated paraffin directly by a thin layer chromatography 

(TLC) method at the end of the depuration phase. These results are also shown in 

Table 3.28 for comparison with the 14C-measurements. The levels measured by this 

direct method were generally much lower than those obtained by the 14C-method, 

indicating that chlorinated paraffin had been metabolised in the fish to some extent. 

In the mussel study the dry yeast was dosed with the chlorinated paraffin at a 

concentration of 524 mg/kg dry weight and the exposure period was 47 days, followed 

by a depuration period of 56 days. The tissue concentrations measured at various 

times during the experiment are shown in Table 3.29. During the test, seven control 

animals and 10 exposed mussels died. The total number of mussels used in the study 

is not given in the paper but was at least 84 and so this difference in death rate is 

probably not significant. 

In addition to the 14C-analyses, some mussels were also analysed for the parent 

chlorinated paraffin directly by a thin layer chromatography (TLC) method at the end of 

both the exposure phase and the depuration phase. These results are also shown in 

Table 3.29 for comparison with the 14C-measurements. The levels measured by this 

direct method were generally in agreement with those obtained by the 14C method, 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 113

indicating that little or no metabolism of the chlorinated paraffin had occurred in the 

experiment. 

Table 3.29 Uptake of 14C-labelled long-chain (42% wt. Cl) chlorinated paraffin 

by mussels (Madeley and Birtley, 1980) 

Tissue concentration (based on 14C-measurements) 

(mg/kg dry weight) 

Time 

Digestive 

gland 

Foot Gonad Gill Remaining 

tissues 

Total body 

burden 

Uptake phase 

Day 5 - - - - - 1.8 

Day 9 - - - - - 2.4 

Day 12 - - - - - 4.2 

Day 19 - - - - - 5.1 

Day 26 155.2 2.6 2.8 3.5 1.8 4.3 

Day 33 36.6 1.3 1.9 5.3 2.9 5.9 

Day 42 100.7 2.2 3.5 4.4 4.6 6.6 

Day 47 80.5 5.4 1.9 7.0 6.8 11.2 

(3–16)a 

Depuration phase 

Day 7 35.1 1.8 1.4 3.3 1.7 5.5 

Day 21 37.0 3.3 2.0 3.1 1.7 2.9 

Day 28 42.2 3.1 1.0 1.9 1.5 2.0 

Day 39 15.8 2.9 2.0 3.6 1.7 2.2 

Day 49 11.3 1.7 1.5 2.5 1.3 3.1 

Day 56 7.0 0.9 0.9 1.5 0.6 1.2 

(<1–7)a 

Note: a Concentration of chlorinated paraffin determined directly by TLC analysis. 

Zitko (1974) studied the uptake of two LCCPs in the diet of juvenile Atlantic salmon 

(Salmo salar) over 181 days. The weekly amount of contaminated food added was 8 g 

per tank, with each tank containing 20 fish (fish weight was approximately 5–7 g/fish). 

In addition, shorter experiments were carried out to investigate the uptake of 

chlorinated paraffins by fish from suspended solids (silica). The chlorinated paraffins 

studied were a C>20, 42% wt. Cl product and a C>20, 70% wt. Cl product. A positive 

control (polychlorinated biphenyl (Aroclor 1254)) was also used in the study. The 

concentrations in the fish were expressed on a whole fish body weight as chlorine. 

Mortalities occurred in the exposed fish and also in the control group during the feeding 

studies. These findings are discussed further in Section 4.1.1. The results are shown in 

Table 3.30. 
114 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.30 Uptake of LCCPs by juvenile Atlantic salmon (Zitko, 1974) 

Substance Exposure 

concentration 

Exposure 

time 

Lipid content 

of fish 

Concentration in fish 

(wet weight basis) 

Studies using suspended solids 

Control 48 hours 0.99% 0.34 mg Cl/kg 

C>20, 42% 48 hours 1.10% 0.44 mg Cl/kg 

wt. Cl 

1 g/kg solid 

144 hours 1.33% 0.75 mg Cl/kg 

C>20, 70% 48 hours 1.56% 0.22 mg Cl/kg 

wt. Cl 

1 g/kg solid 

144 hours 2.10% 0.46 mg Cl/kg 

24 hours 1.52% 19.9 mg Aroclor 1254/kg 

48 hours 1.86% 28.3 mg Aroclor 1254/kg 

Positive 

control 

(Aroclor 

1254) 

1 g/kg solid 

144 hours 1.78% 134 mg Aroclor 1254/kg 

Feeding studies 

33 days 1.03% 0.30 mg Cl/kg 

109 days 0.65% <0.05 mg Cl/kg 

Control 

181 days 0.47% <0.05 mg Cl/kg 

33 days 1.30% 0.11 mg Cl/kg 

109 days 0.69% <0.05 mg Cl/kg 

10 mg/kg food 

181 days 0.49% <0.05 mg Cl/kg 

33 days 1.22% 0.51 mg Cl/kg 

109 days 0.49% <0.05 mg Cl/kg 

C>20, 42% 

wt. Cl 

100 mg/kg food 

181 days 0.34% <0.05 mg Cl/kg 

33 days 1.13% 0.29 mg Cl/kg 

109 days 0.40% <0.05 mg Cl/kg 

10 mg/kg food 

181 days 0.29% <0.05 mg Cl/kg 

33 days 1.30% 0.49 mg Cl/kg 

109 days 0.56% <0.05 mg Cl/kg 

C>20, 70% 

wt. Cl 

100 mg/kg food 

181 days 0.92% <0.05 mg Cl/kg 

33 days 5.09% 3.86 mg Aroclor 1254/kg 

109 days 3.10% 3.80 mg Aroclor 1254/kg 

10 mg/kg food 

181 days 2.07% 3.80 mg Aroclor 1254/kg 

33 days 5.30% 13.9 mg Aroclor 1254/kg 

109 days 2.73% 24.0 mg Aroclor 1254/kg 

Positive 

control 

(Aroclor 

1254) 100 mg/kg food 

181 days 2.69% 30.0 mg Aroclor 1254/kg 

The results indicate that very little uptake of the chlorinated paraffins occurred from 

suspended solids or from food over the time period of the experiments. 

A further feeding study with fish has been carried out by Bengtsson and Baumann 

Ofstad (1982). In this experiment, bleak (Alburnus alburnus) were exposed to a C18–26, 

49% wt. Cl product via food for 91 days, followed by a 316-day depuration period. The 

fish used in the study had a body weight of around 4 g at the start of the experiment 

and the experiments were carried out in glass tanks with a continuous flow of brackish 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 115

water (~7‰). The temperature of the water varied between 3.5–16°C following the 

natural fluctuations in the bay from which the water was extracted. 

During the exposure phase, the chlorinated paraffin was added to the fish food (flakes) 

at a concentration of 3,400 mg/kg food and this was added to the exposure tank 

(containing 30 fish) in 0.25 g portions twice daily on weekdays and once daily at 

weekends. The fish in three tanks were fed non-contaminated food at the same rate, 

and acted as the control groups for the experiment. Throughout the test, the dissolved 

oxygen was measured to be >90 per cent of saturation. Fish were sampled on days 14, 

28, 56 and 91 of the exposure phase and on days 7, 35, 133 and 316 of the depuration 

phase. These fish were starved for two days (to avoid contributions of chlorinated 

paraffin from undigested food) prior to whole body analysis for levels of total chlorine 

using neutron activation analysis. 

No significant increase in mortality was seen in the exposed fish during the experiment. 

Only a small amount of the LCCP appeared to be accumulated by the fish. The 

estimated concentration of chlorine (assumed to be chlorinated paraffin) in fish reached 

24 mg/kg at the end of the 91-day exposure period (the bioaccumulation factor is 

therefore 24/3,400 = 0.007). The authors estimated that the uptake efficiency was 

around two per cent. The total chlorine levels in the fish were found to be reduced by 

around 50 per cent during the first four to five weeks of the depuration period, then the 

level appeared to remain constant for the remainder of the depuration period (40 

weeks). 

Yang et al. (1987) investigated the oral uptake of a radio labelled C18, 50–53% wt. Cl 

chlorinated paraffin in Sprague-Dawley rats. The chlorinated paraffin used in the study 

was synthesised by chlorination of 1-14C-octadecane. A single oral dose of 0.5 g/kg 

body weight was given to the rats and the amount of radioactivity excreted was 

monitored over 96 hours. At the end of the experiment the radioactivity remaining in the 

body tissues was also determined. The results are shown in Table 3.31. 

Table 3.31 Excretion of a C18, 50–53% wt. chlorinated paraffin in rats (Yang et 

al., 1987) 

Recovered Time (hours) 

radioactivity 24 48 72 96 

Urine 1.0±0.3% 1.5±0.3% 1.9±0.5% 1.9±0.6% 

Feces 22.2±21.5% 41.5±17.3% 70.2±7.1% 76.4±2.8%a 

Air (as 14CO2) 1.5±0.6% 3.1±1.7% 4.0±2.0% 4.5±2.3% 

Tissues not determined not determined not determined 3.3±2.7% 

Total 24.7±22.0% 46.1±16.2% 76.1±6.1% 86.2±5.6% 

Note: a Unabsorbed material accounted for approximately 16 per cent of the applied 

dose. 

Other information on the uptake, distribution and excretion of LCCPs is summarised in 

other reviews (BUA, 1992; WHO, 1996). For example, BUA (1992) reports the results 

of studies using C22–26, 43% wt. Cl and C22–26, 70% wt. Cl products in rats. Both 

products contained 14C-labelled chlorinated paraffin (the 14C was in the centre of the 

carbon chain) and were administered to rats by gavage at concentrations of 100 and 

3,750 mg/kg bw/day in corn oil. For the C22–26, 43% wt. Cl product, 82–96 per cent of 

the radio label was excreted in feces after seven days, with 0.1–0.8 per cent being 

excreted in urine and 0.1–1.6 per cent being exhaled. Similar results were found with 
116 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

the C22–26, 70% wt. Cl product, with 76–88 per cent of the radiolabel being excreted in 

feces, 0.1–1.6 per cent being excreted in urine and 0.1–0.6 per cent being exhaled, 

again after seven days. The high rate of excretion via feces found in these studies 

indicate that the test substances were poorly absorbed. 

3.2.9.4 Summary of accumulation 

The available bioconcentration results on LCCPs are not reliable as much of the data 

were obtained using exposure concentrations well in excess of the water solubility of 

the substance. It is generally unclear if the length of the studies was sufficient for 

steady state to be reached. Therefore, although these studies show that uptake does 

occur, it is not possible to obtain a reliable BCF value from them. As a result, the 

estimated data for the fish bioconcentration factor will be considered in the assessment 

as a precautionary approach. The following values will be used for the fish 

bioconcentration factor: 

 C18–20 liquid BCF = 1,096 l/kg 

 C>20 liquid BCF = 192 l/kg 

 C>20 solid BCF <1 l/kg 

Appendix E considers the effects of varying the log Kow value (and hence predicted 

BCF) on the overall outcome of the risk assessment. 

For the marine environment, there are data available on the accumulation of LCCPs by 

mussels in salt water and fish in brackish water. These show similar patterns of uptake 

as found for freshwater species. Again, no reliable BCF can be derived from the data, 

and so the estimated BCFs are considered the most relevant for the marine 

environment as a precautionary approach. 

In addition to bioconcentration, the TGD also provides methods to take into account 

biomagnification in the assessment of secondary poisoning. The method requires a 

biomagnification factor (BMF) for fish, preferably expressed on a lipid normalised basis. 

According to the TGD, an appropriate BMF for LCCPs would be 1 for all three types of 

LCCP considered, based on the fish BCF being <2,000 l/kg and the log Kow being >9. 

There is evidence from feeding studies that the LCCPs can be taken up via the diet, 

but in all cases the concentrations reached in the animals were less than those in the 

diet. This indicates that although uptake of the substance can occur via food, the levels 

should not increase through the food chain. These findings support the default BMF of 

1 determined above. Uptake via diet or the undissolved phase may also explain some 

of the uptake seen in the available bioconcentration studies. 

It should be recognised that the assessment of bioaccumulation/biomagnification 

according to the methods given in the TGD is at a relatively early stage of 

development. There is a general lack of experience in addressing some of the 

uncertainties that are associated with the methods used in fish feeding studies, and a 

number of important points need to be considered, discussed below. 

There is a fundamental difference in biomagnification/accumulation factors obtained 

from field studies/measurements and those obtained in laboratory feeding studies. 

Field-derived factors will take into account accumulation from water and by food, 

whereas laboratory feeding studies only consider the food route. No distinction is made 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 117

in the methods given in the TGD between these two types of factors (this is considered 

further in Section 3.3.4). 

The data obtained in the Fisk et al. (2000) study are lipid normalised. The fish food 

used in this study had a lipid content of 14 per cent, which was generally higher than 

that in the fish (e.g. 6–11 per cent). Thus if the accumulation factors were expressed in 

terms of a whole fish and whole food basis, they would be lower by around a factor of 

1.3–2.3 times. However, conversely, it could be argued that in the environment the 

food for a predatory species would be generally of lower lipid content than found in 

laboratory fish food (and may be of lower lipid content than the predatory species 

itself). It is therefore not possible to infer from these results (or other laboratory-based 

results using proprietary food of high lipid content) that the accumulation factor on a 

whole body and food basis would be lower in the environment than found in the 

laboratory studies. In terms of the TGD, the methods suggest that the lipid-normalised 

BMFs should be used. 

The uptake of a chemical from food depends on many factors including the feeding 

rate, the digestibility of the food, the lipid content of the food and the size of the 

organism (Environment Agency, 2003; Hendriks et al., 2001). The current methods 

given in the TGD give little or no guidance on how these factors should be considered 

within the risk assessment framework. Therefore the use of data from the available 

feeding studies in the current methods in the TGD requires careful consideration. 

Some of the studies (notably Fisk et al., 2000) have been corrected for growth dilution. 

The TGD is unclear on whether this is an appropriate basis on which to calculate 

accumulation or biomagnification factors. It could be argued that such a correction, in 

some circumstances, may make it virtually impossible for a steady state to be reached 

in fish that are growing. It is possible, for example, to have a situation where the actual 

concentrations in the fish remain constant from one sampling period to the next (i.e. 

steady state may have been reached) but if the fish grew by 10 per cent over the same 

sampling period, then the growth corrected concentrations would appear to increase by 

10 per cent due to the calculation method involved. The Environment Agency has 

reanalysed the growth corrected data for the C18 chlorinated paraffin from the Fisk et al.

(2000) study and estimated that the non-growth-corrected fish accumulation factors 

from the study would be in the range 0.10-0.11 on a lipid basis. It should be noted, 

however, that since the original raw concentration-time data were lacking in the paper 

(only the derived kinetic parameters were reported) the reanalysis is only approximate 

and may be subject to large errors. 

Some of the studies measuring accumulation are based on the concentration in fish at 

the end of the exposure period, where either a steady state was not reached or where 

there is no information as to whether or not a steady state was reached. These data 

may therefore underestimate the actual accumulation factor. Accumulation factors 

determined by kinetic methods do not suffer from this problem. 

Many of the results have been obtained using 14C-measurements and will include 

contributions from metabolites and so overestimate the accumulation of the LCCPs 

themselves. 

In summary, the measurement of the bioaccumulation/biomagnification factor is very 

difficult for complex substances such as LCCPs and so there are some uncertainties 

associated with many of the experiments. Taking into account all of the factors 

described above, it is not possible to determine reliable BMF values suitable for use in 

the risk assessment, based on the current understanding of the methods used in the 

available studies. Indeed many of the points outlined above are not specific to LCCPs. 
118 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Rather, they relate to how such data should be generated and treated within the 

current framework for secondary poisoning outlined in the TGD – an issue that is 

probably best addressed outside of this specific assessment. 

The available data for LCCPs do show that uptake into fish from food occurs in the 

laboratory, and that this uptake can be significant in some cases. The degree of uptake 

appears to be highest for the C18–20 liquid chlorinated paraffins, but uptake of C>20 liquid 

chlorinated paraffins has also been demonstrated. The uptake of the highly chlorinated 

C>20 solid chlorinated paraffins from food appears to be minimal. Based on the 

available data, a fish accumulation factor from food of around 1 on a lipid basis (based 

on the available laboratory studies) will be considered as a worst case in this risk 

assessment for both the C18–20 liquid and C>20 liquid chlorinated paraffins. For the C>20

solid chlorinated paraffins the fish accumulation factor from food will be assumed to be 

<<1. 

For uptake and accumulation in earthworms, the following accumulation factors will be 

used in the PEC calculations. These are based on the TGD default methodology but 

take into account the results of recent validation exercises. 

BAFearthworm (related to bulk Kplant-water (related to 

soil concentration) porewater 

concentration) 

C18–20 liquid 0.29 kg/kg 1.1×103

 m3/m3 

C>20 liquid 0.22 kg/kg 2.0×103 m3/m3 

C>20 solid 0.010 kg/kg 200 m3/m3 

3.3 Environmental concentrations 

3.3.1 Aquatic compartment (surface water, sediment and waste 

water treatment plant) 

3.3.1.1 Calculation of PEClocal

Using the emission data given in Table 3.11 for the estimated amounts released at a 

site for production and the various uses of LCCPs, it is possible to estimate a PEC for 

surface water by assuming that the amount released per site enters into waste water 

and this enters into a waste water treatment plant. The TGD suggests that the size of 

the waste water treatment plant should be around 2,000 m3

/day, and the effluent from 

the plant will be diluted by a factor of 10 in the receiving water. It is assumed that no 

biodegradation occurs during waste water treatment. 

Based on the physico-chemical properties of LCCPs, the predicted behaviour of the 

substance during waste water treatment (as estimated in EUSES 2.0.3) is shown in 

Table 3.32. These results show that all types of LCCPs would be expected to behave 

similarly during waste water treatment. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 119

Table 3.32 Predicted behaviour during waste water treatment 

 C18–20 liquid C>20 liquid C>20 solid 

% to air 0% 0% 0% 

% to sludge 92% 92% 92% 

% degraded 0% 0% 0% 

% to water 8% 8% 8% 

Information on the short-chain chlorinated paraffins indicates that the removal by 

adsorption onto sludge may be higher than predicted by EUSES 2.0.3 – around 93 per 

cent, based on the results of a coupled unit test (ECB, 2000). Since LCCPs are likely, if 

anything, to adsorb more strongly onto sludge, then the results obtained for the shortchain chlorinated paraffins will be used in preference to the values obtained by EUSES, 

i.e. for the PEC calculations in the following sections, 93 per cent adsorption onto 

sludge and seven per cent release to surface water from the waste water treatment 

plant will be assumed. 

Once released to surface water, the LCCPs will adsorb onto suspended sediment. The 

following equation from the TGD has been used in all calculations to take this into 

account: 

where Clocalwater = local concentration in surface water during an emission 

episode 

 Clocaleff = concentration in effluent from waste water treatment plant 

 SUSPwater = concentration of suspended matter in surface water = 15 mg/l 

DILUTION = dilution factor for effluent in receiving water = 10 for generic 

scenarios. 

 Kpsusp = solids-water partition coefficient for suspended matter 

 = 9.06×106

 l/kg for C18–20 liquid chlorinated paraffins 

 = 2.77×107

 l/kg for C>20 liquid chlorinated paraffins 

 = >1×109

 l/kg for C>20 solid chlorinated paraffins. 

The final PEClocal(water) is estimated from: 

 PEClocal(water) = Clocalwater + PECregional(water)

Where PECregional(water) = 3.9×10-4 μg/l for C18-20 liquid chlorinated paraffins 

 = 4.8×10-4 μg/l for C>20 liquid chlorinated paraffins 

= 8.5×10-7 μg/l for C>20 solid chlorinated paraffins 

 (based on the EUSES calculation: see later in this section) 

Finally the PEC for sediment PEClocal(sed) is estimated from: 

Where RHOsusp = bulk density of suspended matter = 1,150 kg/m3 

(1 Kp SUSP 10 ) DILUTION

C C 6 ×+ ×× = − susp water

eff

water

local local

susp-water local(water)

susp

local(sed) RHO

K PEC 1000

PEC

× × =
120 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Ksusp-water = suspended matter-water partition coefficient 

 = 2.27×106

 m3/m3 for C18–20 liquid chlorinated paraffin 

 = 6.93×106

 m3/m3 for C>20 liquid chlorinated paraffin 

 = >2.5×108

 m3/m3 for C>20 solid chlorinated paraffin 

Production sites 

Site specific information is currently available for several of the current production sites 

in the EU. This information is confidential, but has been used to derive emissions from 

a generic production site. The resulting PECs are shown in Table 3.33. 

Table 3.33 Summary of PECs estimated for a generic production site 

 C18–20 liquid C>20 liquid C>20 solid 

Local release to waste 

water (kg/day) 

0.063 0.32 0.0063 

No of days of 

release/year 

300 300 300 

Size of WWTP 

(m3

/day) 

2,000 2,000 2,000 

Influent concentration 

(μg/l) 

32 160 3.2 

% to water during 

WWTP 

7 7 7 

Clocaleff (μg/l) 2.2 11 0.22 

Dilution factor 10 10 10 

Clocalwater (μg/l) 1.6×10-3 2.7×10-3 1.5×10-6 

PEClocal(water) (μg/l) 2.0×10-3 3.2×10-3 2.3×10-6 

PEClocal(sediment) (mg/kg 

wet wt.) 

3.9 19 0.51 

Use in PVC 

In Section 3.1.2, releases of LCCPs to water have been estimated from several stages 

of production of PVC. These release estimates have been used here, along with the 

behaviour in the generic waste water treatment plant to estimate the PEClocal(water) and 

PEClocal(sediment) for these stages. The calculations are summarised in Table 3.34 to 

Table 3.37. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 121

Table 3.34 PEClocal for water and sediment for use in PVC (plastisol processes) 

Compounding site 

(formulation) 

Conversion site 

(processing) 

Combined 

compounding and 

conversion site 

C18–20 liquid C18–20 liquid C18–20 liquid 

Local release to waste 

water (kg/day) 

0.025 0.025 0.05 

No of days of 

release/year 

33 33 33 

Size of WWTP 

(m3

/day) 

2,000 2,000 2,000 

Influent concentration 

(μg/l) 

13 13 25 

% to water during 

WWTP 

7 7 7 

Clocaleff (μg/l) 0.88 0.88 1.8 

Dilution factor 10 10 10 

Clocalwater (μg/l) 6.4×10-4 6.4×10-4 1.3×10-3 

PEClocal(water) (μg/l) 1.0×10-3 1.0×10-3 1.7×10-3 

PEClocal(sediment) (mg/kg 

wet wt.) 

2.0 2.0 3.3 

Table 3.35 PEClocal for water and sediment for use in PVC (extrusion/other – 

open systems) 

Compounding site 

(formulation) 

Conversion site 

(processing) 

Combined 

compounding and 

conversion site 

C18–20 liquid C18–20 liquid C18–20 liquid 

Local release to waste 

water (kg/day) 

0.0445 0.037 0.0815 

No of days of 

release/year 

33 33 33 

Size of WWTP 

(m3

/day) 

2,000 2,000 2,000 

Influent concentration 

(μg/l) 

22 19 41 

% to water during 

WWTP 

7 7 7 

Clocaleff (μg/l) 1.6 1.3 2.9 

Dilution factor 10 10 10 

Clocalwater (μg/l) 1.1×10-3 9.5×10-4 2.1×10-3 

PEClocal(water) (μg/l) 1.5×10-3 1.3×10-3 2.5×10-3 

PEClocal(sediment) (mg/kg 

wet wt.) 

3.0 2.6 4.9 

 
122 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.36 PEClocal for water and sediment for use in PVC (extrusion/other – 

partially open systems) 

Compounding site 

(formulation) 

Conversion site 

(processing) 

Combined 

compounding and 

conversion site 

C18–20 liquid C18–20 liquid C18–20 liquid 

Local release to waste 

water (kg/day) 

0.24 0.040 0.28 

No of days of 

release/year 

33 33 33 

Size of WWTP 

(m3

/day) 

2,000 2,000 2,000 

Influent concentration 

(μg/l) 

120 20 140 

% to water during 

WWTP 

7 7 7 

Clocaleff (μg/l) 8.4 1.4 9.8 

Dilution factor 10 10 10 

Clocalwater (μg/l) 6.1×10-3 1.0×10-3 7.2×10-3 

PEClocal(water) (μg/l) 6.5×10-3 1.4×10-3 7.6×10-3 

PEClocal(sediment) (mg/kg 

wet wt.) 

13 2.8 15 

Table 3.37 PEClocal for water and sediment for use in PVC (extrusion/other – 

closed systems) 

Compounding site 

(formulation) 

Conversion site 

(processing) 

Combined 

compounding and 

conversion site 

C18–20 liquid C18–20 liquid C18–20 liquid 

Local release to waste 

water (kg/day) 

0.0204 0.034 0.0544 

No of days of 

release/year 

33 33 33 

Size of WWTP 

(m3

/day) 

2,000 2,000 2,000 

Influent concentration 

(μg/l) 

10 17 27 

% to water during 

WWTP 

7 7 7 

Clocaleff (μg/l) 0.71 1.2 1.9 

Dilution factor 10 10 10 

Clocalwater (μg/l) 5.2×10-4 8.7×10-4 1.4×10-3 

PEClocal(water) (μg/l) 9.1x10-4 1.3x10-3 1.8×10-3 

PEClocal(sediment) (mg/kg 

wet wt.) 

1.8 2.5 3.5 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 123

Use in rubber 

In Section 3.1.3, releases of LCCPs to water have been estimated from the use in 

rubber. These release estimates have been used here, along with the behaviour in the 

generic waste water treatment plant to estimate the PEClocal(water) and PEClocal(sediment) for 

this use. The calculations are summarised in Table 3.38. The calculations are based on 

the releases expected from plastic processing. The releases, and hence PECs 

expected from the processing of rubber would be expected to be lower than these 

values due to the lower processing temperatures generally used. 

Table 3.38 PEClocal for water and sediment for use in rubber 

Combined conversion and processing site 

C>20 liquid C>20 solid 

Local release to waste 

water (kg/day) 

0.040 0.51 

No of days of 

release/year 

251 21 

Size of WWTP (m3

/day) 2,000 2,000 

Influent concentration 

(μg/l) 

20 255 

% to water in WWTP 7 7 

Clocaleff (μg/l) 1.4 18 

Dilution factor 10 10 

Clocalwater (μg/l) 3.4×10-4 1.2×10-4 

PEClocal(water) (μg/l) 8.2×10-4 1.2×10-4 

PEClocal(sediment) (mg/kg 

wet wt.) 

4.9 26 

Use in sealants/adhesives 

The releases of LCCPs to water from sites formulating or using sealants/adhesives are 

likely to be very low. No PEClocal is therefore calculated for this use.

Use in paints and varnishes 

In Section 3.1.5, releases of LCCPs to water from the formulation and use of paints 

have been estimated using the default release estimates from the TGD, along with 

knowledge of the likely amounts of LCCPs formulated on a site. These default release 

estimates have been used here, along with the behaviour of LCCPs in the generic 

waste water treatment plant to estimate the PEClocal(water) and PEClocal(sediment) for these 

stages. The data available so far indicate that the releases of LCCPs to water from the 

formulation and use of paints should be very low. The default calculations are 

summarised in Table 3.39. 
124 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.39 PEClocal for water and sediment for formulation and use in paints 

Paint formulation site 

(formulation) 

Industrial application of 

paints (processing) 

C18–20

liquid 

C>20

liquid 

C>20

solid 

C18–20

liquid 

C>20

liquid 

C>20

solid 

Local release to waste 

water (kg/day) 

negligible negligible 0.0023 0.06 0.06 0.11 

No of days of 

release/year 

300 300 300 300 300 300 

Size of WWTP 

(m3

/day) 

2,000 2,000 2,000 2,000 2,000 2,000 

Influent concentration 

(μg/l) 

- - 1.2 30 30 55 

% to water in WWTP 7 7 7 7 7 7 

Clocaleff (μg/l) - - 0.081 2.1 2.1 3.9 

Dilution factor 10 10 10 10 10 10 

Clocalwater (μg/l) - - 5.4×10-7 1.5×10-3 5.0×10-4 2.6×10-5 

PEClocal(water) (μg/l) - - 1.4×10-6 1.9×10-3 9.8×10-4 2.7×10-5 

PEClocal(sediment) (mg/kg 

wet wt.)

- - 0.30 3.8 5.9 5.8 

Formulation and use in metal cutting/working fluids 

In Section 3.1.6, releases of LCCPs to water have been estimated from formulation 

and use in metal cutting/working fluids. These release estimates have been used here, 

along with the behaviour of LCCPs in the generic waste water treatment plant to 

estimate the PEClocal for water and sediment for these stages. The calculations are 

summarised in Table 3.40. 

For the intermittent release scenario for metal cutting/working fluids, the Technical TGD 

does not provide any guidance on how this should be treated for sediment. The value 

reported in Table 3.40 assumes that the substance in water instantly equilibrates with 

the sediment. However, in reality, this is unlikely to occur as the release will be over a 

short period of time. An alternative approach would be to average the concentration 

over the year and add this to the concentration arising from the continuous use in the 

metalworking fluids (2.0 mg/kg wet weight for C18–20 liquid chlorinated paraffins and 4.2 

mg/kg wet weight for C>20 liquid chlorinated paraffins). This method would give a 

PEClocal(sediment) of 8.9–23 mg/kg wet weight for C18–20 liquid chlorinated paraffins and 

11–25 mg/kg wet weight for C>20 liquid chlorinated paraffins, assuming that the 

intermittent disposal occurs between two and six times per year. 

Formulation and use in leather fat liquors 

In Section 3.1.7, releases of LCCPs to water from the formulation and use of leather fat 

liquors have been estimated. These release estimates have been used here, along 

with the behaviour of LCCPs in the generic waste water treatment plant to estimate the 

PEClocal for water and sediment for these stages. The calculations are summarised in 

Table 3.41. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 125

Table 3.40 Type PEClocal for water and sediment for use in metal cutting/workin

Formulation site Use in oil-based fluids (processing) Use in em

(formulation) Large site Small site Continuous 

C18–20

liquid 

C>20 liquid C>20 liquid C18–20

liquid 

C>20 liquid C18–20

liquid 

C>

Local release to waste water (kg/day) 

5×10-4 3.4×10-4 0.33a–0.66b 0.30a–

0.60b 

0.30a–

0.60b 

0.025 0.0

No of days of release/year 

<10 25 300 300 300 300 30

Size of WWTP (m3/day) 

2,000 2,000 2,000 2,000 2,000 2,000 2,0

Influent concentration (μg/l) 

0.25 0.17 165a–330b 150a–300b 150a–300b 13 13 

% to water in WWTP 7 7 7 7 7 7 7 Clocaleff (μg/l) 0.018 0.012 12a– 23b 11a–21b 11a–21b 0.88 0.8

Dilution factor 10 10 10 10 10 10 10 Clocalwater (μg/l) 1.3×10-5 2.9×10-6 2.8×10-3 –

5.6×10-3 

7.7×10-3–

0.015

2.5×10-3– 

5.0×10-3 

6.4×10-4 2.1

PEClocal(water) (μg/l) 4.0×10-4 4.8×10-4 3.3×10-3– 

6.0×10-3 

8.1×10-3–

0.016

3.0×10-3– 

5.5×10-3 

1.0×10-3 6.9

PEClocal(sediment) (mg/kg 

wet wt.) 

0.79 2.9 20–36 16–31 18–33 2.0 4.2 

Notes: a Assumes five per cent chlorinated paraffin content in fluid. 

b Assumes 10 per cent chlorinated paraffin in fluid. 
126 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.41 PEClocal for water and sediment for the formulation and use of leather 

Formulation site (formulation) Use sit

Industry-specific information 

Default generic calculation 

Complete processing oraw hides (processing)b 

C18–20 liquid C>20 liquid C18–20 liquid C>20 liquid C18–20 liquid C>20 liquid 

Local release to waste water (kg/day) 

- - 0.15 0.075 0.9 0.9 

No of days of release/year 

- - 300 300 100 46 

Size of WWTP (m3/day) 

2,000 2,000 2,000 2,000 2,000 2,000 

Influent concentration (μg/l) 

50a 50a 75 38 450 450 

% to water in WWTP 7 7 7 7 7 7 

Clocaleff (μg/l) 3.5 3.5 5.3 2.6 32 32 

Dilution factor 10 10 10 10 10 10 Clocalwater (μg/l) 2.6×10-3 8.4×10-4 3.8×10-3 6.3×10-4 0.023 7.6× 10-3 

PEClocal(water) (μg/l) 3.0×10-3 1.3×10-3 4.2×10-3 1.1× 10-3 0.023 8.0×10-3 PEClocal(sediment) (mg/kg 

wet wt.)

5.8 8.0 8.3 6.7 46 48 

Notes: a Industry-specific information indicates that the maximum total concentration of LCCPs in the waste wa

likely to be <500 μg/l. In the absence of water flow rates from a typical site, it has been assumed that the diluted by a factor of 10 in the influent to the waste water treatment plant. This value will be used in the 

b The calculation for complete processing of raw hides is considered to be the most realistic and is taken 

characterisation. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 127

Formulation and use in textiles 

In Section 3.1.8, releases of LCCPs to water have been estimated from use in textiles 

applications using default estimation methods. These release estimates have been 

used here, along with the behaviour of LCCPs in the generic waste water treatment 

plant to estimate the PEClocal for water and sediment for these stages. The calculations 

are summarised in Table 3.42. 

Table 3.42 PEClocal for water and sediment for use in textile applications 

 Textile use 

 C18–20 liquid 

Local release to waste water (kg/day) 4.3 

No of days of release/year 300 

Size of WWTP (m3

/day) 2,000 

Influent concentration (μg/l) 1,800 

% to water in WWTP 7 

Clocaleff (μg/l) 126 

Dilution factor 10 

Clocalwater (μg/l) 0.11

PEClocal(water) (μg/l) 0.11

PEClocal(sediment) (mg/kg wet wt.) 217 

3.3.1.2 Calculation of PECregional and PECcontinental

The predicted concentrations of LCCPs in the regional and continental scenarios have 

been estimated by EUSES 2.0.3, using the release data outlined in Table 3.11. The 

estimated PECregional and PECcontinental are shown in Table 3.43. 

Table 3.43 Estimated PECregional and PECcontinental for the aquatic compartment 

Compartment PEC C18–20 liquid C>20 liquid C>20 solid Total LCCPa 

Surface water Regional 3.2×10-4–

3.9×10-4 μg/l 

4.5×10-4– 

4.8×10-4 μg/l 

8.2×10-7– 

8.5×10-7 μg/l 

7.7×10-4– 

8.7×10-4 μg/l 

 Continental 4.0×10-5– 

5.0×10-5 μg/l 

5.5×10-5– 

5.9×10-5 μg/l 

1.0×10-7 μg/l 9.5×10-5–

1.1×10-4 μg/l 

Sediment Regional 1.3–1.5 mg/kg 

wet wt. 

5.4–5.8 mg/kg 

wet wt. 

0.36–0.37 

mg/kg wet wt. 

7.1–7.7 

mg/kg wet wt. 

 Continental 0.16–0.20 

mg/kg wet wt. 

0.66–0.71 

mg/kg wet wt. 

0.044–0.045 

mg/kg wet wt. 

0.86–0.96 

mg/kg wet wt. 

Note: a Total LCCPs is the sum of the three types of LCCPs. 
128 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

The contribution of the various types of LCCPs to the total regional concentrations are 

shown in Figure 3.5 

Appendix E considers the effects of the uncertainties and variability of some of the 

physico-chemical properties on the estimated concentrations. 

44.80%

19.00%

55.20%

75.00%

0.10%

4.80%

0% 20% 40% 60% 80% 100%

Surface water

Sediment

C18-20 liquid

C>20 liquid

C>20 solid

Figure 3.5 Relative contribution to the total regional concentration in surface 

water and sediment 

3.3.1.3 Measured levels in water and sediment 

The analysis of LCCPs in environmental media is complicated by the fact that there are 

a large number of possible chlorinated paraffins (of different carbon chain length, 

degrees of chlorination and position of chlorine atoms along the carbon chain) present 

in any given commercial product. Thus care has to be taken when comparing the 

results from one survey with another, since different reference compounds may have 

been used and hence different chemical species may have been measured. The main 

analytical methods used in the environmental analyses are discussed in Appendix D. 

Most of the reference compounds used in the analysis appear to have carbon chain 

lengths ≥C20. Few studies appear to have been carried out using a C18–20 product as 

the reference substance. 

Water 

A study of the inputs of chlorinated paraffins to a sewage treatment plant in Germany 

has been published (Rieger and Ballschmiter, 1995). The sewage treatment plant 

processed 100,000 m3

/day of municipal, industrial and mixed waste water. LCCPs 

(C18–20) were not detected (detection limit 0.1 mg/kg dry matter) in any of the sewage 

sludge samples taken at the plant (only short-chain chlorinated paraffins were found). 

Water samples taken from upstream and downstream of the plant also showed no 

detectable concentrations of LCCPs (detection limit 5 μg/l). 

The levels of C10–20 and C20–30 chlorinated paraffins have been measured in marine and 

fresh waters remote from industry and in freshwaters from industrialised areas in the 

United Kingdom (Campbell and McConnell, 1980). These results are shown in Table 

3.44 to Table 3.46. It should be noted that the C10–20 chlorinated paraffin levels are 

likely to be dominated by contributions from the short- and medium-chain chlorinated 

paraffins. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 129

Table 3.44 Concentration of chlorinated paraffins in marine waters in and 

around the UK (Campbell and McConnell, 1980) 

Concentration of chlorinated paraffins 

(μg/l) 

Location 

C10–20 C20–30 

Irish Sea: Site a 1.0 ND 

Irish Sea: Site b 0.5 ND 

Irish Sea: Site c 0.5 ND 

Irish Sea: Site d 0.5 ND 

Irish Sea: Site e ND ND 

Irish Sea: Site f ND ND 

Barmouth Harbour 0.5 ND 

Menai Straights, Caernarvon 0.5 0.5 

Tremadoc Bay, Llandanwg ND ND 

North Minch, Ardmair 0.5 1.0 

North Minch, Port Bùn a’ Ghlinne ND ND 

North Minch, Port of Ness 0.5 ND 

Goile Chròic, Lewis 0.5 0.5 

Sound of Taransay, Harris 4.0 2.0 

Sound of Arisaig 1.0 2.0 

North Sea: N55° 5.7' W1° 9.3' ND ND 

North Sea: N57° 26.2' W1° 17.0' ND ND 

North Sea: N57° 56.5' W1° 22.0' ND ND 

Notes: ND = not detected (detection limit = 0.5 μg/l). 
130 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.45 Concentration of chlorinated paraffins in fresh waters remote from 

industry in the UK (Campbell and McConnell, 1980) 

Location Concentration of chlorinated paraffins (μg/l) 

C10–20 C20–30 

River Banwy, Llangadfan 0.5 ND 

River Lea, Welwyn ND* NM 

River Lea, Batford ND* NM 

River Clwyd, Ruthin ND ND 

Bala Lake 1.0 0.5 

River Dee, Corwen ND ND 

River Wnion, Merioneth 0.5 0.5 

Firth of Lorne, Ganevan 0.5 ND 

Loch Linnhe, Corran Narrows ND ND 

Firth of Clyde, Ashcraig ND ND 

Firth of Clyde, Girvan 0.5 2.0 

An Garbh Allt 0.5 0.5 

Five drinking water reservoirs, 

Manchester area 

ND ND 

Notes: ND = not detected (detection limit = 0.5 μg/l). 

 ND* = not detected (detection limit 1.0 μg/l). 

 NM = not measured. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 131

Table 3.46 Concentration of chlorinated paraffins in waters in industrialised 

areas in the UK (Campbell and McConnell, 1980) 

Location Concentration of chlorinated paraffin (μg/l) 

C10–20 C20–30 

River Aire, Leeds 2.0 NM 

River Aire, Woodlesford 2.0 NM 

River Ouse, Boothberry edge 1–2 NM 

River Trent, West Bromwich 1–2 NM 

River Trent, Walton-upon-Trent 2–3 NM 

River Trent, Swarkestone 1–2 NM 

River Trent, Newark 4.0 NM 

River Trent, Gainsborough 2.0 NM 

River Trent, confluence with Humber 6.0 NM 

Humber Estuary, Hull 1–2 NM 

Humber Estuary, Grimsby 3.0 NM 

Mersey Estuary, New Brighton 3.0 NM 

Mersey Estuary, Liverpool Pier Head 4.0 NM 

River Thames, Oxford 2.0 NM 

River Thames, Sanford 1–2 NM 

Wyre Estuary ND–1.5 ND–0.5 

River Tees, Low Dinsdale ND ND 

River Tees, North Gare breakwater 0.5 ND 

River Tees, Middlesbrough ND ND 

Notes: ND = not detected (detection limit = 0.5 μg/l). 

 NM = not measured. 

The levels of LCCPs in surface water have been measured near to a chlorinated 

paraffin manufacturing site in the United States (Murray et al., 1988a and 1988b). The 

reference compound used in the study was a C20–30, 40–50% wt. Cl product. The 

effluent from the plant, after undergoing physical treatment, was discharged into Sugar 

Creek, via a surface impoundment lagoon and small ditch. The results of the analyses 

are shown in Table 3.47. Based on these measurements, Murray et al. (1988a) 

estimated a daily discharge to water of 1.46 g/day for LCCPs from the plant. 

A similar study was also undertaken by Murray et al. (1988a and 1988b) near to a 

metalworking facility that was thought to be using lubricating oils containing chlorinated 

paraffins. Due to analytical interferences, it was not possible to detect chlorinated 

paraffins in surface water at the site, however, LCCPs were detected at 2.2 μg/l in the 

process waste stream inside the plant that was collected near the end of the assembly 

process prior to discharge from the plant. 

Surveys of levels of chlorinated paraffins (unspecified chain length) in surface waters 

were carried out at numerous sites in Japan in 1979 and 1980. Chlorinated paraffins 

were not detected (detection limit 10 μg/l) in any of the 51 surface water samples taken 

in 1979 or any of the 120 surface water samples taken in 1980 (Environment Agency 

Japan, 1991). 
132 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.47 Measured levels of LCCPs near a production site in the United 

States (Murray et al., 1988a and 1988b) 

Location Concentration (μg/l) 

 Particulates Dissolved 

Surface lagoon near to its 

effluent to drainage ditch 

11 not detected (<0.15) 

Surface lagoon near to 

influent from plant 

3.6 not detected (<0.15) 

Middle of surface lagoon 7.7 0.61 

Drainage ditch, immediately 

above point of discharge into 

Sugar Creek 

3.7 trace (0.15–0.5) 

Sugar Creek, upstream of 

discharge 

nd (<0.05) nd (<0.05) 

Sugar Creek, just upstream 

of discharge 

trace (0.05–0.17) nd (<0.05) 

Sugar Creek, just 

downstream of discharge 

0.62 nd (<0.05) 

Sugar Creek, downstream of 

discharge 

0.35 nd (<0.05) 

Notes: Dissolved = concentration in dissolved phase. 

 Particulate = concentration in particulate phase (>0.45 μm). 

Sediment 

The levels of total chlorinated paraffin (short-, medium- and long-chain) have been 

determined in estuarine sediments from Western Europe. In all, samples from 22 

locations were analysed and the mean total level found in the <63 μm sediment fraction 

was 10.5 μg/kg dry weight in the Mersey and Seine estuaries, 5.5 μg/kg dry weight in 

the Schelde estuary, 4.8 μg/kg dry weight in the Liffey river estuary, 3.3 μg/kg dry 

weight in the Forth estuary and 1.2 μg/kg dry weight in the Humber estuary. 

Chlorinated paraffins were not detected (detection limit 0.5 μg/kg dry weight) at the 

remaining 16 sites. LCCPs, with chlorine contents of around 42% wt., were thought to 

be the predominant type of chlorinated paraffin found in the samples, with only traces 

of medium-chain and short-chain chlorinated paraffins being seen in the samples (van 

Zeijl, 1997). 

Greenpeace (1995) published the results of a survey of total chlorinated paraffin (C10–

24) levels in mud samples from Rotterdam Harbour, Hamburg Harbour and from offshore mud flats at Kaiser Wilhelm Koog and Den Helder. The total levels measured 

ranged between 25 and 125 μg/kg. Long-chain (i.e. C18–24) chlorinated paraffins were 

thought to account for 10–60 per cent of the total chlorinated paraffins present. Using 

these percentages, the concentrations of medium-chain chlorinated paraffin can be 

estimated as 22–29.4 μg/kg in Rotterdam Harbour samples, 25.2 μg/kg in the Hamburg 

Harbour sample, 12.3 μg/kg in the sample from Den Helder and 12.5 μg/kg in the 

sample from Kaiser Wilhelm Koog. It is not clear from the paper if the levels are 

reported on a wet or dry weight basis. 

The levels of C10–20 and C20–30 chlorinated paraffins have been measured in several 

types of sediment in the United Kingdom, often from the same areas where water 

concentrations were also measured (Campbell and McConnell, 1980; see above). The 

results of the analyses are shown in Table 3.48 to Table 3.50. It is not clear from the 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 133

paper if the levels found are expressed on a wet weight or dry weight sediment basis. 

Similar to the case with the water levels, the reported C10–20 chlorinated paraffin 

concentrations are likely to be dominated by contributions from short- and mediumchain chlorinated paraffins. 

Table 3.48 Concentration of chlorinated paraffins in marine sediments around 

the UK (Campbell and McConnell, 1980) 

Concentration of chlorinated paraffins 

(μg/kg) 

Location 

C10–20 C20–30 

Irish Sea: Site a 100 ND 

Irish Sea: Site b ND ND 

Irish Sea: Site c NM NM 

Irish Sea: Site d 100 ND 

Irish Sea: Site e ND ND 

Irish Sea: Site f ND 600 

Irish Sea: Site g NM ND 

Barmouth Harbour 500 ND 

Menai Straights, Caernarvon ND ND 

Tremadoc Bay, Llandanwg ND ND 

North Minch, Ardmair ND ND 

North Minch, Port Bùn á Ghlinne ND ND 

North Minch, Port of Ness ND ND 

Goile Chròic, Lewis ND ND 

Sound of Taransay, Harris ND ND 

Sound of Arisaig ND ND 

North Sea: N55° 5.7' W1° 9.3' ND ND 

North Sea: N57° 26.2' W1° 17.0' ND 100 

North Sea: N57° 56.5' W1° 22.0' 50 300 

Notes: ND = not detected (detection limit = 50 μg/kg). 

NM = not measured. 
134 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.49 Concentration of chlorinated paraffins in fresh and other nonmarine sediments remote from industry in the UK (Campbell and McConnell, 

1980) 

Concentration of chlorinated paraffins 

(μg/kg) 

Location 

C10–20 C20–30 

River Banwy, Llangadfan ND ND 

River Lea, Batford 1,000 NM 

River Clwyd, Ruthin ND ND 

River Dee, Corwen 300 50 

River Wnion, Merioneth ND ND 

Five drinking water reservoirs, 

Manchester area 

ND* ND* 

Notes: ND = not detected (detection limit = 50 μg/kg). 

ND*= not detected (detection limit 250 μg/kg). 

Table 3.50 Concentration of chlorinated paraffins in sediments in 

industrialised areas in the UK (Campbell and McConnell, 1980) 

Concentration of chlorinated paraffin 

(μg/kg) 

Location 

C10–20 C20–30 

River Aire, Leeds 10,000 NM 

River Ouse, Goole 2,000 NM 

River Trent, West Bromwich 6,000 NM 

River Trent, Walton-upon-Trent 1,000 NM 

River Trent, Swarkestone 14,000 NM 

River Trent, Newark 8,000 NM 

River Trent, Gainsborough 3,000 NM 

Humber Estuary, Hull 2,000 NM 

Humber Estuary, Stone Creek 2,000 NM 

Mersey Estuary, New Brighton 3,000 NM 

Mersey Estuary, Liverpool Pier Head 8,000 NM 

River Thames, Sanford 1,000 NM 

Wyre Estuary ND–1,600 ND–3,200 

Mersey Estuary, 14 sediment samples ND ND 

River Tees, Low Dinsdale 300 100 

River Tees, North Gare breakwater 50 50 

River Tees, Middlesbrough 15,000 3,000 

Notes: ND = not detected (detection limit = 50 μg/kg). 

 NM = not measured. 

Campbell and McConnell (1980) also reported levels of chlorinated paraffins in sewage 

sludge from the Liverpool area and the Manchester area. In sewage sludge from the 

Liverpool area, C10–20 chlorinated paraffins were found to be present at concentrations 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 135

of 4–10 mg/kg but C20–30 chlorinated paraffins were not detected (limit of detection was 

0.05 mg/kg). No chlorinated paraffins were detected in the sewage sludge from the 

Manchester area (limit of detection was 0.05 mg/kg for both the C10–20 and C20–30

chlorinated paraffins). 

Murray et al. (1988a and 1988b) reported the results of monitoring studies carried out 

near to a chlorinated paraffin manufacturing site and an industry using metalworking 

fluids in the United States. LCCPs (quantified using a C20–30, 40–50% wt. Cl product) 

were detected at 21, 84 and 170 mg/kg dry weight in sediment from an impoundment 

lagoon and 3.6 mg/kg dry weight in sediment from a drainage ditch at the production 

site. The levels in the stream sediments that received effluent from the lagoon via the 

drainage ditch were 8.1–11 μg/kg dry weight in sediments upstream of the discharge 

point and 9.8–21 μg/kg dry weight in sediments downstream of the discharge point. 

Due to analytical interferences, it was not possible to detect chlorinated paraffins at the 

site using metalworking fluids. 

Chlorinated paraffins (no information given as to type or chain length) were found in 24 

out of 51 sediment samples from Japan in 1979 at levels of 600–10,000 μg/kg dry 

weight. In a similar survey for 1980, chlorinated paraffins were found in 31 out of 120 

sediment samples at levels of 500–8,500 μg/kg dry weight. For both sets of analyses, 

the detection limit was 500 μg/kg dry weight. (Environment Agency Japan, 1991). 

Kemmlein et al. (2002) reported the results of a study looking at the levels of 

chlorinated paraffins in marine sediments from an area close to a chlorinated paraffin 

manufacturer in Australia. The levels of total chlorinated paraffins found in four 

sediment samples were in the range 2,139–18,872 μg/kg dry weight. LCCPs were 

found to make up around 11–52 per cent of the total. The results for LCCPs are 

summarised in Table 3.51. The analysis was carried out by dechlorination of the 

chlorinated paraffins found, followed by analysis of the n-paraffins formed. The same 

results appear to be given in OSPAR (2000) referenced to an unpublished study by 

Rotard et al. (1998). 

Table 3.51 Concentration of chlorinated paraffins in marine sediment close to 

a chlorinated paraffin production site in Australia 

Concentration of chlorinated paraffins (μg/kg dry weight)a Chain length 

Sample I Sample II Sample III Sample IV 

C18 51 48 169 268 

C19 21 47 69 82 

C20 30 33 66 81 

C21 24 20 102 48 

C22 55 42 230 84 

C23 74 43 342 124 

C24 91 43 393 136 

C25 111 59 417 154 

C26 128 80 377 206 

C27 159 89 348 222 

C28 199 138 350 279 

C29 308 254 329 337 

Total LCCP 1,251 896 3,192 2,021 
136 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Note: a It is not clear from the paper if these are four independent samples or two 

samples that have been analysed in duplicate. 

3.3.1.4 Comparison of predicted and measured levels 

The available monitoring data for LCCPs in surface water are limited. The most 

extensive dataset available is that of Campbell and McConnell (1980), which used a 

relatively crude thin layer chromatography analytical procedure. Here, levels up to 

around 1–2 μg/l of C>20 chlorinated paraffins were measured at some sites in the 

United Kingdom. These levels are higher than those predicted in the assessment, and 

may reflect the fact that the available measured data probably refer to total water 

concentrations (i.e. dissolved and particulate phase), whereas the PECs are calculated 

for the dissolved phase only. In this respect, the results of Murray et al. (1988a and 

1988b) are informative as they found the majority of the chlorinated paraffin was 

associated with the water-borne particulates, with only traces being generally found in 

the dissolved phase. 

Therefore, in order to carry out a comparison of the predicted and measured 

concentrations, it may be more informative to consider the predicted concentrations 

before the adsorption onto suspended solids is taken into account. When this is done, 

the predicted local concentrations generally fall into the range of around 0.002–2 μg/l 

for the C18–20 liquid chlorinated paraffins, 0.001–3 μg/l for the C>20 liquid chlorinated 

paraffins and 0.01–2 μg/l for the C>20 solid chlorinated paraffins. Given the limited 

scope of the available monitoring data, particularly for areas close to industry, these 

calculated values appear to be of the same order of magnitude as the measurements 

obtained. 

The monitoring data available for sediment indicate that LCCPs are generally found at 

concentrations <100 μg/kg dry weight, with higher levels of up to around 10 mg/kg dry 

weight being found near to sources of release. On a wet weight basis, these 

concentrations are approximately <22 μg/kg wet weight and 2.2 mg/kg wet weight, 

using the default sediment water contents from the TGD. The higher measured levels 

are of a similar order of magnitude as the predicted local and regional concentrations. 

As the coverage of the available monitoring data is fairly limited (in terms of areas close 

to sources of release), the predicted concentrations will be used in the risk 

characterisation. 

The monitoring data also indicate that LCCPs are present at low levels in some 

estuaries and marine waters from around the United Kingdom and the rest of Europe. 

3.3.2 Terrestrial compartment 

3.3.2.1 Predicted levels 

The estimated concentrations of LCCPs in soil are shown in Table 3.52. These have 

been estimated using the EUSES 2.0.3 program (see Appendix A). The vast majority of 

the LCCP is likely to enter soil via adsorption onto and subsequent spreading of 

sewage sludge, but for uses where atmospheric emissions occur (e.g. PVC), then 

these releases can also contribute to the concentrations found in soil over time. 

No degradation in soil was assumed in the model, and the local concentrations are 

calculated based on 10 years of continual application of sewage sludge containing the 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 137

chlorinated paraffin. After this time period the fraction of the steady state concentration 

reached is estimated as 2.5–2.6×10-3 (0.3 per cent) for agricultural soil and grassland. 

This indicates that over prolonged periods of exposure (either through atmospheric 

deposition and/or sewage sludge application) higher concentrations than predicted 

here could theoretically build up in the soil compartment if there is no removal 

mechanism for LCCPs from soil. 
138 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.52 Estimated concentrations in soil 

Scenario Step Predicted soil concentration (mg/kg 

Agric. soil 

(30 days and 180 days average) 

C18–20

liquid 

C>20

liquid 

C>20 solid Totald C18–20

liquid 

Production negligiblea negligiblea negligiblea negligiblea negligiblea 

Compounding (O) 1.1 NAc NAc 1.1 0.80 

Conversion (O) 1.1 NAc NAc 1.1 0.80 

Use in PVC – plastisol applications Compounding/conversion 

(O) 

1.5 NAc NAc 1.5 0.97 

Compounding (O) 1.4 NAc NAc 1.4 0.93 Compounding (PO) 4.8 NAc NAc 4.8 2.3 Compounding (C) 0.98 NAc NAc 0.98 0.77 Conversion (O) 1.3 NAc NAc 1.3 0.88 Conversion (PO) 1.3 NAc NAc 1.3 0.90 Conversion (C) 1.2 NAc NAc 1.2 0.86 Compounding/conversion (O) 

2.0 NAc NAc 2.0 1.2 

Compounding/conversion (PO) 

5.5 NAc NAc 5.5 2.6 

Use in PVC – extrusion/ other 

Compounding/conversion (C) 

1.6 NAc NAc 1.6 1.0 

Use in rubber 

Compounding/conversion NAc 0.91 8.8 9.7 NAc 

Use in sealants 

Formulation and use negligibleb negligibleb NAc negligibleb negligibleb 

Formulation negligibleb negligibleb 0.041 0.041 negligibleb 

Industrial application 1.7 1.3 1.9 4.9 1.0 

Use in paints 

Domestic application negligibleb negligibleb negligibleb negligibleb negligibleb 

Table 3.52 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 139

Table 3.52 continued Scenario Step Predicted soil concentration (mg/k

Agric. soil 

(30 days and 180 days average) 

C18-20

liquid 

C>20

liquid 

C>20 solid Totald C18-20

liquid 

Formulation 0.63 0.21 NAc 0.84 0.63 Use in oil-based fluids (large) NAc 5.9–12 NAc 5.9–12 NAc 

Use in oil-based fluids (small) 5.8–11 5.4–11 NAc 11–22 2.7–4.8 Use in emulsifiable fluids 1.1 0.64 NAc 1.7 0.80 

Use in metal cutting/ working fluids Use in emulsifiable fluids – 

intermittent release 

48 47 NAc 95 19 

Formulation 3.2 1.5 NAc 4.7 1.7 Use – complete processing of raw hidese 

16 16 NAc 32 6.9 

Use in leather fat liquors 

Use – processing of wet bluee 

63 63 NAc 126 26 

Use in textile applications 75 NAc NAc 75 31 

Notes: a Sewage sludge from production sites is not thought to be applied to agricultural land. 

b The process makes no significant contribution to the levels in soil. c NA = not applicable; no significant use of the substance in this application. d Total = total concentration assuming all types of chlorinated paraffin are released from a site. e The calculation for complete processing of raw hides is considered to be the more realistic scenario

characterisation. 

 O = open systems; PO = partially open systems; C = closed systems (as defined in OECD, 2004b). 
140 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

For the intermittent release scenario in Table 3.52 the calculation of the concentration 

on sludge assumes that 93 per cent of the chemical released on that day is adsorbed 

onto the amount of sludge produced in the waste water treatment plant on that day. 

However, the retention time of sludge in the default waste water treatment plant is 9.2 

days and so the calculation has assumed that this sludge is diluted by a factor of 

around 9.2 prior to being spread onto the land (the instantaneous estimated 

concentration on sludge is 29,400 mg/kg dry weight for both the C18–20 liquid and C>20

liquid chlorinated paraffins respectively, and so a value of 3,196 mg/kg dry weight is 

used in the subsequent calculations for both substances). 

The regional and continental soil concentrations are shown in Table 3.53. In the 

regional model, agricultural soil received input from both sewage sludge and aerial 

deposition, whereas the natural soil received input from aerial deposition only. Higher 

concentrations have been estimated in the regional model than in some of the local 

scenarios given in Table 3.52. This occurs because the concentrations calculated in 

the regional model are “steady-state” concentrations, and reflect the possible build up 

in soil due to continuous application over many years (rather than 10 years as 

assumed in the local calculations). The model does not give any indication as to the 

time period that may be necessary for these concentrations to be reached. 

A rough estimation of the time to steady state can be obtained from emission rate of 

the substance to the regional soil compartment and the volume of the regional soil 

compartment. For example the regional industrial/urban soil compartment covers an 

area of 4×103

 km2 (4×109 m2) and has a mixing depth of 0.05 m. Thus the volume of 

the regional industrial/urban soil compartment is 2×108

 m3. The bulk density of soil in 

the regional model is 1,700 kg/m3

, thus the regional mass of soil is 3.4×1011 kg wet 

weight. The estimated emission rates to industrial/urban soil are 7,791 kg/year for C18-

20 liquid chlorinated paraffins, 20,077 kg/year for C>20 liquid chlorinated paraffins and 

1,591 kg/year for C>20 solid chlorinated paraffins. Considering that chlorinated paraffins 

have been in production for around 50 years, and taking a future look for the 

concentration in 100 years from now, the total amount of chlorinated paraffins released 

to industrial/urban soil over this 150 year time period would be around 1,170 tonnes of 

C18-20 liquid chlorinated paraffins, 3,010 tonnes of C>20 liquid chlorinated paraffins and 

175 tonnes of C>20 solid chlorinated paraffins. 

Thus the resulting regional concentration in urban/industrial soil 100 years from now 

would be approximately 3 mg/kg wet weight for C18-20 liquid chlorinated paraffins, 

9 mg/kg wet weight for C>20 liquid chlorinated paraffins and 0.5 mg/kg wet weight for 

C>20 solid chlorinated paraffins. These are approximately 9–25 per cent of the predicted 

regional steady state concentrations, and would imply a time to steady state of >400 to 

>1,000 years. 

The calculations in the model, particularly at the regional level, are very sensitive to the 

degradation rate (the default degradation rate constant is 6.93×10-7 days-1 for an 

LCCP, corresponding to a half-life of 2,740 years). The effects of varying the 

degradation rate in the regional model are shown in Appendix E. Information on the 

actual degradation rates of LCCPs in soil would be useful to indicate whether or not the 

substance is likely to build up in the soil as indicated by the current model.

The concentrations predicted in urban/industrial soil result mainly from the contribution 

from particulate waste ("waste remaining in the environment") containing the 

chlorinated paraffins. The actual availability of the chlorinated paraffin in this form is 

unknown. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 141

Table 3.53 Predicted regional and continental soil concentrations 

Scale Soil type PEC (mg/kg wet wt.) 

C18-20 liquid C>20 liquid C>20 solid Total LCCPs 

Agricultural 0.42–0.55 2.8 0.016–0.017 3.2–3.4 

Natural 0.46–0.63 0.17–0.21 4.0×10-4 0.63–0.84 

Regional 

Urban/industrial 11–12 62–65 5.3–5.5 78–83 

Agricultural 0.052–0.068 0.28–0.29 1.7×10-3 0.33–0.36 

Natural 0.059–0.080 0.019–0.023 5.6×10-5 0.078–0.11 

Continental 

Urban/industrial 1.1–1.3 6.3–6.7 0.55–0.56 8.0–8.6 

Note: Measured levels 

No measured levels of LCCPs in soil were located in the literature. 

3.3.2.2 Comparison of predicted and measured levels 

No comparison of predicted and measured levels can be made at present. The 

predicted concentrations will therefore be considered in the risk characterisation. 

3.3.3 Atmospheric compartment 

3.3.3.1 Predicted levels 

The concentrations of LCCPs in the atmosphere have been predicted using EUSES 

2.0.3 (see Appendix A). The local concentrations arise from direct emissions of LCCPs 

from the various industrial processes involved (emissions to air from waste water 

treatment plants are considered to be negligible due to the physico-chemical properties 

of the substance). At the regional and continental level, diffuse source releases have 

also been considered in the model. The predicted atmospheric concentrations are 

shown in Table 3.54. 
142 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.54 Estimated air concentrations of LCCPs 

Air concentrations 

(Clocal – Emission episode) (mg/m3) 

(Cloc

Scenario Step 

C18-20

liquid 

C>20

liquid 

C>20 solid Totalc C18-20

liquid 

Production negligiblea negligiblea negligiblea negligiblea negligiblea 

Compounding (O) negligiblea NAb NAb negligiblea negligiblea 

Conversion (O) 7.0×10-6 NAb NAb 7.0×10-6 6.3×10-7 

Use in PVC – plastisol coating Compounding/conversion 

(O) 

7.0×10-6 NAb NAb 7.0×10-6 6.3×10-7 

Compounding (O) 2.1×10-6 NAb NAb 2.1×10-6 1.9×10-7 Compounding (PO) 1.1×10-5 NAb NAb 1.1×10-5 1.1×10-6 Compounding (C) 9.5×10-7 NAb NAb 9.5×10-7 8.6×10-8 Conversion (O) 1.0×10-5 NAb NAb 1.0×10-5 9.3×10-7 Conversion (PO) 1.1×10-5 NAb NAb 1.1×10-5 1.1×10-6 Conversion (C) 9.5×10-6 NAb NAb 9.5×10-6 8.6×10-7 Compounding/conversion (O) 

1.2×10-5 NAb NAb 1.2×10-5 1.1×10-6 

Compounding/conversion (PO) 

2.2×10-5 NAb NAb 2.2×10-5 2.0×10-6 

Use in PVC – extrusion/other 

Compounding/conversion (C) 

1.0×10-5 NAb NAb 1.0×10-5 9.4×10-7 

Use in rubber 

Compounding/conversion NAb 4.2×10-6 4.2×10-6 8.4×10-6 NAb 

Use in sealants 

Formulation and use negligibleb negligiblea NAb negligiblea negligibleb 

Formulation negligiblea negligiblea 1.1×10-6 1.1×10-6 negligiblea 

Industrial application negligiblea negligiblea negligiblea negligiblea negligiblea 

Use in paints 

Domestic application negligiblea negligiblea negligiblea negligiblea negligiblea 

Table 3.54 continued overleaf. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 143

Table 3.54 continued 

Scenario Step Air concentrations 

(Clocal – Emission episode) (mg/m3)

(Cloc

C18-20

liquid

C>20

liquid

C>20 solid Totalc C18-20

liquid

Formulation 1.1×10-7 1.1×10-8 NAb negligiblea 6.1×10-10 Use in oil-based fluids (large) 

NAb negligiblea NAb negligiblea NAb 

Use in oil-based fluids (small) 

negligiblea negligiblea NAb negligiblea negligiblea 

Use in emulsifiable fluids negligiblea negligiblea NAb negligiblea negligiblea 

Use in metal cutting/ working fluids 

Use in emulsifiable fluids – intermittent release 

negligiblea negligiblea NAb negligiblea negligiblea 

Formulation 1.5×10-5 7.0×10-6 NAb 2.2×10-5 1.3×10-5 

Use – complete processing of raw hides 

negligiblea negligiblea NAb negligiblea negligiblea 

Use in leather fat liquors 

Use – processing of wet blue 

negligiblea negligiblea NAb negligiblea negligiblea 

Use in textile applications 2.3×10-3 NAb NAb 2.3×10-3 1.9×10-3 

Regional sources 7.6×10-7–

1.0×10-6 

Notes: a The process makes no significant contribution to the local levels in air. 

b NA = not applicable; no significant use of the substance in this application. c Total = total concentration assuming all types of chlorinated paraffin are released from a site. 

 O = open systems; PO = partially open systems; C = closed systems (as defined in OECD, 2004b). 
144 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

3.3.3.2 Measured levels 

No measured levels for LCCPs in air have been found in the literature. 

3.3.3.3 Comparison of predicted and measured levels 

No comparison of predicted and measured levels can be made at present. The 

predicted concentrations will therefore be considered in the risk characterisation. 

3.3.4 Food chain exposure 

3.3.4.1 Predicted levels 

The levels of LCCPs in fish and earthworms for the secondary poisoning assessment 

have been calculated by EUSES 2.0.3 using the methods given in the TGD. For fish, 

no reliable measured BCF value is available for LCCPs and so estimated values have 

to be used. The values used are 1,096 l/kg for C18-20 liquid chlorinated paraffins, 192 

l/kg for C>20 liquid chlorinated paraffins and <1 for C>20 solid chlorinated paraffins (see 

Section 3.2.9). 

The TGD indicates that as well as the bioconcentration factor, the biomagnification 

factor (BMF) for fish should also be considered in determination of the PEC for 

secondary poisoning i.e.: 

 PECoral = PECwater×BCF×BMF 

A default BMF of 1 was used in the calculations for all LCCPs (see Section 3.2.9.4). 

This was supported by experimentally determined BMFs of the same order for C18–20

liquid chlorinated paraffins in laboratory feeding studies. The predicted concentrations 

are shown in Table 3.55. 

It should be noted, however, that the above equation given in the TGD may not be 

appropriate when considering actual BMF data from laboratory feeding studies. The 

intention in the TGD is to model the concentration in fish resulting from simultaneous 

exposure via both water and food, and this is represented by the scheme below (Figure 

3.6). The term food accumulation factor (FAF) is used in this scheme to distinguish it 

from the BMF given in the equation from the TGD. 

Figure 3.6 Model of fish exposure to LCCPs 

Water 

Aquatic organism 

(prey fish) 

Fish-eating predator 

Fish (PECoral, 

BCFaquatic organism predator) 

BCFfish

FAFfish 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 145

PECoral, predator = (PECwater×BCFaquatic organism×FAFfish)+(PECwater×BCFfish) equation 1. 

Assuming that the “aquatic organism” in the food chain is also a fish (as assumed in 

the TGD), then this equation simplifies to the following: 

PECoral, predator = (PECwater×BCFfish×(1+FAFfish) equation 2. 

Using a FAF (BMF) of 1 for C18–20 liquid and C>20 liquid chlorinated paraffins, and a FAF 

<<1 for C>20 solid chlorinated paraffins, the resulting PECs in predatory fish are shown 

in Table 3.55 (marked as “alternate method”). These values are derived using equation 

2, assuming that 50 per cent of the exposure comes from local sources and 50 per cent 

comes from regional sources (as stated in the TGD). 

For earthworms, no measured accumulation data are available for LCCPs and so 

predicted values are used in the assessment. As discussed in Section 3.2.9.2), a 

number of approaches have been considered for predicting the accumulation in 

earthworms and the following BAF values based on a correction to the TGD 

methodology (relating the concentration in earthworms to the concentration in soil) are 

thought to be most representative of the actual accumulation potential. The estimated 

concentrations in earthworms for secondary poisoning obtained using these values are 

summarised in Table 3.56. 

 BAFearthworm_corrected 

C18–20 liquid 0.29 kg/kg 

C>20 liquid 0.22 kg/kg 

C>20 solid 0.010 kg/kg 

The concentrations of LCCPs in food and other media for human consumption have 

been estimated using EUSES 2.0.3 (see Appendix A) and are shown in Table 3.57. 

The resulting estimated daily human intake figures, using the default consumption and 

bioavailability figures from the TGD, are summarised in Table 3.58. As is the case with 

earthworms, there are no experimental data available on the actual uptake of LCCPs 

through the food chain. 

For uptake into plants from soil, the following plant-water partition coefficient values are 

used (see Section 3.2.9.2). 

 Kplant-water (m3

/m3) 

 C18–20 liquid 1.1×103 

 C>20 liquid 2.0×103 

 C>20 solid 200 

For the other parts of the food-chain the default values from the TGD are used. The 

resulting concentrations in the food chain are therefore uncertain as the default 

methods rely mainly on the log Kow value and the reliability of these estimation 

methods at very high log Kow values is unclear. 
146 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.55 Estimated concentrations in fish for secondary poisonin

Scenario Step Predicted concentration in fish 

(mg/kg wet wt.)* – TGD method 

Predic

(mg/kg 

C18-20

liquid 

C>20

liquid 

C>20 solid Totald C18-20

liquid 

Production 1.2×10-3 3.0×10-4 1.5×10-9 1.5×10-3 2.4×10-3 

Compounding (O) 4.6×10-4 NAc NAc 4.6×10-4 9.2×10-4 

Conversion (O) 4.6×10-4 NAc NAc 4.6×10-4 9.2×10-4 

Use in PVC – plastisol applications Compounding/conversion 

(O) 

4.9×10-4 NAc NAc 4.9×10-4 9.8×10-4 

Compounding (O) 4.8×10-4 NAc NAc 4.8×10-4 9.6×10-4 Compounding (PO) 7.3×10-4 NAc NAc 7.3×10-4 1.5×10-3 Compounding (C) 4.5×10-4 NAc NAc 4.5×10-4 9.0×10-4 Conversion (O) 4.7×10-4 NAc NAc 4.7×10-4 9.4×10-4 Conversion (PO) 4.8×10-4 NAc NAc 4.8×10-4 9.6x10-4 

Conversion (C) 4.7×10-4 NAc NAc 4.7×10-4 9.4×10-4 

Compounding/conversion (O) 

5.3×10-4 NAc NAc 5.3×10-4 1.1×10-3 

Compounding/conversion (PO) 

7.8×10-4 NAc NAc 7.8×10-4 1.6×10-3 

Use in PVC – extrusion/ other 

Compounding/conversion (C) 

5.0×10-4 NAc NAc 5.0×10-4 1.0×10-3 

Use in rubber 

Compounding/conversion NAc 1.1×10-4 4.3×10-9 1.1×10-4 NAc 

Use in sealants 

Formulation and use negligibleb negligibleb NAc negligibleb negligibleb 

Formulation negligibleb negligibleb 1.1×10-9 1.1×10-9 negligibleb 

Industrial application 1.1×10-3 1.3×10-4 1.1×10-8 1.2×10-3 2.2×10-3 

Use in paints 

Domestic application negligibleb negligibleb negligibleb negligibleb negligibleb 

Table 3.55 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 147

Table 3.55 continued Scenario Step Predicted concentration in fish 

(mg/kg wet wt.)* – TGD method 

Pre

(mg/k

C18-20

liquid 

C>20

liquid 

C>20 solid Totald C18-20

liquid 

Formulation 4.3×10-4 9.2×10-5 NAc 5.2×10-4 8.6×10-4 Use in oil-based fluids (large) 

NAc 3.1×0-4– 

5.3×10-4 

NAc 3.1×0-4– 

5.3×10-4 

NAc 

Use in oil-based fluids (small) 

3.9×10-3–

7.3×10-3 

2.9×10-4– 

4.9×10-4 

NAc 4.2×10-3– 

7.8×10-3 

7.8×10-3–

0.015 

Use in emulsifiable fluids 7.2×10-4 1.1×10-4 NAc 8.3×10-4 1.4×10-3 

Use in metal cutting/ working fluids 

Use in emulsifiable fluids – intermittent release 

2.4×10-3 2.0×10-4 NAc 2.6×10-3 4.8×10-3 

Formulation 8.1x10-4 1.0×10-4 NAc 9.1×10-4 1.6×10-3 Use – complete processing of raw hidese 

3.9×10-3 1.8×10-4 NAc 4.1×10-3 7.8×10-3 

Use in leather fat liquors 

Use – processing of wet bluee 

0.014 4.6×10-4 NAc 0.014 0.028 

Use in textile applications 0.050 NAc NAc 0.050 0.10 

Notes: * 50 per cent from local and 50 per cent from regional concentrations. 

a Assumes dilution of sewage sludge at wwtp before application to soil. b The process makes no significant contribution to the levels in fish. c NA = not applicable; no significant use of the substance in this application. d Total = total concentration assuming all types of chlorinated paraffin are released from a site. e The calculation for complete processing of raw hides is thought to be the more realistic scenario, an

characterisation. 

 O = open systems; PO =partially open systems; C = closed systems (as defined in OECD, 2004b). 
148 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.56 Estimated concentrations in earthworms for secondary pois

Scenario Step Predicted concentration in earthworms (mg/kg wet wt.)* – 

C18–20 liquid C>20 liquid C>20 solid 

Production negligibleb negligibleb negligibleb 

Compounding (O) 0.24 NAc NAc 

Conversion (O) 0.24 NAc NAc 

Use in PVC – plastisol applications Compounding/conversion 

(O) 

0.30 NAc NAc 

Compounding (O) 0.28 NAc NAc Compounding (PO) 0.78 NAc NAc Compounding (C) 0.22 NAc NAc Conversion (O) 0.27 NAc NAc Conversion (PO) 0.27 NAc NAc Conversion (C) 0.25 NAc NAc Compounding/conversion (O) 

0.37 NAc NAc 

Compounding/conversion (PO) 

0.88 NAc NAc 

Use in PVC – extrusion/ other 

Compounding/conversion (C) 

0.31 NAc NAc 

Use in rubber 

Compounding/conversion NAc 0.41 0.044 

Use in sealants 

Formulation and use negligibleb negligibleb NAc 

Formulation negligibleb negligibleb 2.9×10-4 

Industrial application 0.33 0.45 9.6×10-3 

Use in paints 

Domestic application negligibleb negligibleb negligibleb 

Table 3.56 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 149

Table 3.56 continued Scenario Step Predicted concentration in earthworms (mg/kg wet wt.)* – c

C18–20 liquid C>20 liquid C>20 solid 

Formulation 0.17 0.33 NAc Use in oil-based fluids (large) 

NAc 0.96–1.6 NAc 

Use in oil-based fluids (small) 

0.92–1.7 0.90–1.5 NAc 

Use in emulsifiable fluids 0.24 0.38 NAc 

Use in metal cutting/working fluids 

Use in emulsifiable fluids – intermittent release 

7.0 5.5 NAc 

Formulation 0.54 0.47 NAc Use – complete processing of raw hidese 

2.4 2.1 NAc 

Use in leather fat liquors 

Use – processing of wet bluee 

0.99 7.2 NAc 

Use in textile applications 11 NAc NAc 

Notes: *50 per cent from local and 50 per cent from regional concentrations. 

a Assumes dilution of sewage sludge at wwtp before application to soil. b The process makes no significant contribution to the levels in earthworms. c NA = not applicable; no significant use of the substance in this application. d Total = total concentration assuming all types of chlorinated paraffin are released from a site. e The calculation for complete processing of raw hides is thought to be the more realistic scenario, an

characterisation. 

 O = open systems; PO = partially open systems; C = closed systems (as defined in OECD, 2004b). 
150 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.57 Estimated concentrations in food for human consumpti

Scenario Step Concentration 

Fish (mg/kg)e 

Root crops (mg/kg) 

Leaf crops (mg/kg) 

Drinking water (mg/l) 

Meat (mg/kg) 

C18–20 liquids Production Generic 1.9×10-3 negligibleb negligibleb negligibleb negligibleb 

Compounding (O) 4.9×10-4 1.0×10-3 1.7×10-4 6.6×10-7 0.030 

Conversion (O) 4.9×10-4 1.0×10-3 2.7×10-4 6.6×10-7 0.031 

Use in PVC – plastisol applications Compounding/conversion 

(O) 

5.5×10-4 1.5×10-3 2.7×10-4 9.3×10-7 0.037 

Compounding (O) 5.4×10-4 1.4×10-3 2.0×10-4 8.7×10-7 0.036 Compounding (PO) 1.0×10-3 4.7×10-3 3.3×10-4 3.0×10-6 0.086 Compounding (C) 4.8×10-4 9.6×10-4 1.8×10-4 6.1×10-7 0.029 Conversion (O) 5.2×10-4 1.2×10-3 3.2×10-4 7.9×10-7 0.034 Conversion (PO) 5.3×10-4 1.3×10-3 3.3×10-4 8.2×10-7 0.035 Conversion (C) 5.1×10-4 1.2×10-3 3.1×10-4 7.6×10-7 0.033 

Compounding/conversion (O) 

6.3×10-4 2.0×10-3 3.5×10-4 1.3×10-6 0.046 

Compounding/conversion (PO) 

1.1×10-3 5.4×10-3 4.9×10-4 3.4×10-6 0.097 

Use in PVC – extrusion/ other 

Compounding/conversion (C) 

5.7×10-4 1.5×10-3 3.2×10-4 9.8×10-7 0.039 

Use in rubber 

Compounding/conversion NAa NAa NAa NAa NAa 

Use in sealants 

Formulation and use negligibleb negligibleb negligibleb negligibleb negligibleb 

Formulation negligibleb negligibleb negligibleb negligibleb negligibleb Industrial application 1.8×10-3 1.6×10-3 1.7×10-4 1.0×10-6 0.039 

Use in paints 

Domestic application negligibleb negligibleb negligibleb negligibleb negligibleb 

Table 3.57 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 151

Table 3.57 continued Scenario Step Concentration 

Fish (mg/kg)e 

Root crops (mg/kg) 

Leaf crops (mg/kg) 

Drinking water (mg/l) 

Meat (mg/kg) 

Formulation 4.3×10-4 6.2×10-4 1.7×10-4 4.0×10-7 0.024 Use in oil-based fluids (large) 

NAa NAa NAa NAa NAa 

Use in oil-based fluids (small) 

7.3×10-3–

0.014 

5.7×10-3–

0.011 

1.7×10-4 3.6×10-6–

6.9×10-6 

0.10–0.18 

Use in emulsifiable fluids 1.0×10-3 1.0×10-4 1.7×10-4 6.6×10-7 0.030 

Use in metal cutting/ working fluids 

Use in emulsifiable fluids – intermittent release 

4.3×10-3 0.047 1.7×10-4 3.0×10-5 0.72 

Formulation 3.9×10-3 3.2×10-3 2.2×10-3 2.0×10-6 0.073 Use – complete processing of raw hidese 

7.3×10-3 0.016 1.7×10-4 1.0×10-5 0.25 

Use in leather fat liquors 

Use – processing of wet bluee 

0.028 0.062 1.7×10-4 3.9×10-5 0.94 

Use in textile applications 0.10 0.074 0.31 4.7×10-5 2.8 Regional sources 4.3×10-4 5.4×10-4 1.7×10-4 3.4×10-7 0.021 Table 3.57 continued overleaf 
152 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.57 continued Scenario Step Concentration 

Fish (mg/kg)e 

Root crops (mg/kg) 

Leaf crops (mg/kg) 

Drinking water (mg/l) 

Meat (mg/kg) 

C>20 liquids Production Generic 5.2×10-4 negligibleb negligibleb negligibleb negligibleb 

Compounding (O) NAa NAa NAa NAa NAa 

Conversion (O) NAa NAa NAa NAa NAa 

Use in PVC – plastisol applications Compounding/conversion 

(O) 

NAa NAa NAa NAa NAa 

Compounding (O) NAa NAa NAa NAa NAa Compounding (PO) NAa NAa NAa NAa NAa Compounding (C) NAa NAa NAa NAa NAa Conversion (O) NAa NAa NAa NAa NAa Conversion (PO) NAa NAa NAa NAa NAa Conversion (C) NAa NAa NAa NAa NAa Compounding/conversion (O) 

NAa NAa NAa NAa NAa 

Compounding/conversion (PO) 

NAa NAa NAa NAa NAa 

Use in PVC – extrusion/ other 

Compounding/conversion (C) 

NAa NAa NAa NAa NAa 

Use in rubber 

Compounding/conversion 1.4×10-4 5.3×10-4 2.6×10-4 1.9×10-7 0.020 

Use in sealants 

Formulation and use negligibleb negligibleb negligibleb negligibleb negligibleb 

Formulation negligibleb negligibleb negligibleb negligibleb negligibleb Industrial application 1.7×10-4 7.3×10-4 8.9×10-6 2.6×10-7 0.023 

Use in paints 

Domestic application negligibleb negligibleb negligibleb negligibleb negligibleb 

Table 3.57 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 153

Table 3.57 continued Scenario Step Concentration 

Fish (mg/kg)e 

Root crops (mg/kg) 

Leaf crops (mg/kg) 

Drinking water (mg/l) 

Meat (mg/kg) 

Formulation 9.2×10-5 1.3×10-4 8.9×10-6 1.2×10-7 8.0×10-3 Use in oil-based fluids (large) 

5.3×10-4–

9.7×10-4 

3.5×10-3–

6.8×10-3 

8.9×10-6–

9.0×10-6 

1.2×10-6–

2.4×10-6 

0.092–0.18 

Use in oil-based fluids (small) 

4.9×10-4–

8.9×10-4 

3.2×10-3–

6.2×10-3 

8.9×10-6 1.1×10-6–

2.2×10-6 

0.085–0.16 

Use in emulsifiable fluids 1.3×10-4 3.8×10-4 8.9×10-6 1.6×10-7 0.014 

Use in metal cutting/ working fluids 

Use in emulsifiable fluids – intermittent release 

3.1×10-4 0.028 9.2×10-6 9.7×10-6 0.70 

Formulation 1.9×10-4 8.8×10-4 5.0×10-4 3.1×10-7 0.030 

Use – complete processing of raw hidese 

2.8×10-4 9.2×10-3 9.0×10-6 3.2×10-6 0.24 

Use in leather fat liquors 

Use – processing of wet bluee 

8.2×10-4 0.037 9.3×10-6 1.3×10-5 0.93 

Use in textile applications NAa NAa NAa NAa NAa 

Regional sources 9.2×10-5 1.6×10-3 8.9×10-6 5.7×10-7 0.10 Table 3.57 continued overleaf 
154 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.57 continued Scenario Step Concentration 

Fish (mg/kg)e 

Root crops (mg/kg) 

Leaf crops (mg/kg) 

Drinking water (mg/l) 

Meat (mg/kg) 

C>20 solids Production Generic 2.1×10-9 negligibleb negligibleb negligibleb negligibleb 

Compounding (O) NAa NAa NAa NAa NAa 

Conversion (O) NAa NAa NAa NAa NAa 

Use in PVC – plastisol applications Compounding/conversion 

(O) 

NAa NAa NAa NAa NAa 

Compounding (O) NAa NAa NAa NAa NAa Compounding (PO) NAa NAa NAa NAa NAa Compounding (C) NAa NAa NAa NAa NAa Conversion (O) NAa NAa NAa NAa NAa Conversion (PO) NAa NAa NAa NAa NAa Conversion (C) NAa NAa NAa NAa NAa Compounding/conversion (O) 

NAa NAa NAa NAa NAa 

Compounding/conversion (PO) 

NAa NAa NAa NAa NAa 

Use in PVC – extrusion/ other 

Compounding/conversion (C) 

NAa NAa NAa NAa NAa 

Use in rubber 

Compounding/conversion 7.7×10-9 1.4×10-5 3.9×10-8 5.0×10-8 0.13 

Use in sealants 

Formulation and use NAa NAa NAa NAa NAa 

Formulation 1.3×10-9 6.6×10-8 1.9×10-10 3.2×10-10 6.4×10-4 

Industrial application 2.2×10-8 3.1×10-6 8.3×10-9 1.1×10-8 0.028 

Use in paints 

Domestic application negligibleb negligibleb negligibleb negligibleb negligibleb 

Table 3.57 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 155

Table 3.57 continued Scenario Step Concentration 

Fish (mg/kg)e 

Root crops (mg/kg) 

Leaf crops (mg/kg) 

Drinking water (mg/l) 

Meat (mg/kg) 

Formulation NAa NAa NAa NAa NAa Use in oil-based fluids (large) 

NAa NAa NAa NAa NAa 

Use in oil-based fluids (small) 

NAa NAa NAa NAa NAa 

Use in emulsifiable fluids NAa NAa NAa NAa NAa 

Use in metal cutting/ working fluids 

Use in emulsifiable fluids – intermittent release 

NAa NAa NAa NAa NAa 

Formulation NAa NAa NAa NAa NAa Use – complete processing of raw hidese 

NAa NAa NAa NAa NAa 

Use in leather fat liquors 

Use – processing of wet bluee 

NAa NAa NAa NAa NAa 

Use in textile applications NAa NAa NAa NAa NAa Regional sources 8.5×10-10 2.7×10-8 7.2×10-11 2.1×10-10 6.1×10-4 

Notes: a NA = not applicable; no significant use of the substance in this application. 

b The process makes no significant contribution to the levels in food. c Total = total concentration assuming all types of chlorinated paraffin are released from a site. d The calculation for complete processing of raw hides is considered to be the most realistic scenarioe No BMF or FAF has been assumed in the calculation here. This is in line with the methodology outlf For the local scenario, the concentrations in air are the annual average air concentration for a site (C

3.54 and do not include the regional contribution. The contribution of the inhalation route to the total dO = open systems; PO = partially open systems; C = closed systems (as defined in OECD, 2004b). 
156 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.58 Estimated total human food intake of LCCPs 

Scenario Step Estimated daily intake (m

C18–20 liquid C>20 liquid C>20 s

Production Generic 3.1×10-6 8.5×10-7 3.4x1

Compounding (O) 2.2×10-4 NAa NAa 

Conversion (O) 2.2×10-4 NAa NAa 

Use in PVC – plastisol applications Compounding/conversion (O) 2.7×10-4 NAa NAa 

Compounding (O) 2.6×10-4 NAa NAa Compounding (PO) 6.2×10-4 NAa NAa Compounding (C) 2.1×10-4 NAa NAa Conversion (O) 2.5×10-4 NAa NAa Conversion (PO) 2.5×10-4 NAa NAa Conversion (C) 2.4×10-4 NAa NAa Compounding/conversion (O) 3.3×10-4 NAa NAa 

Compounding/conversion (PO) 7.1×10-4 NAa NAa 

Use in PVC – extrusion/ other 

Compounding/conversion (C) 2.8×10-4 NAa NAa 

Use in rubber Compounding/conversion NAa 1.4×10-4 8.9×1Use in sealants 

Formulation and use negligibleb negligibleb NAa 

Formulation negligibleb negligibleb 4.6×1

Industrial application 2.8×10-4 1.6×10-4 1.9×1

Use in paints 

Domestic application negligibleb negligibleb neglig

Table 3.58 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 157

Table 3.58 continued Scenario Step Estimated daily intake (m

C18–20 liquid C>20 liquid C>20 s

Formulation 1.7×10-4 5.6×10-5 NAa Use in oil-based fluids (large) NAa 6.5×10-4–1.2×10-3 NAa 

Use in oil-based fluids (small) 7.3×10-4–1.3×10-3 6.0×10-4–1.1×10-3 NAa Use in emulsifiable fluids 2.2×10-4 1.0×10-5 NAa 

Use in metal cutting/ working fluids 

Use in emulsifiable fluids – intermittent release 

5.2×10-3 4.9×10-3 NAa 

Formulation 5.7×10-4 2.2×10-4 NAa 

Use – complete processing of raw hidesd

1.8×10-3 1.7×10-3 NAa 

Use in leather fat liquors 

Use – processing of wet blued 6.8×10-3 6.5×10-3 NAa 

Use in textile applications 0.026 NAa NAa Regional sources 1.5×10-4 7.1×10-4 4.2×1

Notes: a NA = not applicable; no significant use of the substance in this application. 

b The process makes no significant contribution to the levels in food. c Total = total concentration assuming all types of chlorinated paraffin are released from a site. d The calculation for complete processing of raw hides is considered to be the most realistic scena

O = open systems; PO = partially open systems; C = closed systems (as defined in OECD, 2004b
158 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

3.3.4.2 Measured data 

Murray et al. (1988a) reported the results of monitoring of chlorinated paraffins in 

mussels (Unionidae sp.) collected in a stream receiving effluent from a chlorinated 

paraffin production site in the United States. The levels of LCCPs found (using a C20–30, 

40–50% wt. Cl product as a reference) were 180 μg/kg in mussels from downstream of 

the discharge. LCCPs were not detected (<7 μg/kg) in mussels from upstream of the 

discharge. 

Kemmlein et al. (2002) reported the results of a study looking at the levels of 

chlorinated paraffins in marine mussels and crabs from an area close to a chlorinated 

paraffin manufacturer in Australia. The levels of total chlorinated paraffins found were 

25 mg/kg lipid in mussel and 109.5 mg/kg lipid in crabs. LCCPs were found to make up 

around 27 per cent of the total in mussel and 13 per cent of the total in crabs. The 

results for LCCPs are summarised in Table 3.59. The analysis was carried out by 

dechlorination of the chlorinated paraffins found, followed by analysis of the n-paraffins 

formed. The same results appear to be given in OSPAR (2000) referenced to an 

unpublished study by Rotard et al. (1998). 

Table 3.59 Concentration of chlorinated paraffins in marine mussels and crab 

close to a chlorinated paraffin production site in Australia 

Chain length Concentration of chlorinated paraffins (mg/kg lipid)

Mussel Crab 

C18 1.4 4.0 

C19 0.5 1.3 

C20 0.9 1.6 

C21 0.4 0.7 

C22 0.7 1.0 

C23 0.4 0.9 

C24 0.6 0.9 

C25 0.6 1.3 

C26 1.2 1.1 

C27 1.1 0.7 

C28 0.9 0.5 

C29 0.6 0.3 

Total LCCP 9.3 14.3 

Details of an unpublished study (Froescheis, 1997) were also reported by OSPAR 

(2000). This study detected chlorinated paraffins of all chain lengths in the deep sea 

fish Sebastolobus altivelis, but it was not possible to quantify the levels found. 

The levels of C10–20 and C20–30 chlorinated paraffins have been measured in seal, 

marine shellfish and salt and freshwater fish from around the United Kingdom 

(Campbell and McConnell, 1980). The results of the analyses are shown in Table 3.60. 

The same authors also determined the levels in several other parts of the (human) food 

chain. These data are shown in Table 3.61 to Table 3.64. The C10–20 levels are likely to 

be dominated by contributions from the short- and medium-chain chlorinated paraffins. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 159

Table 3.60 Concentrations of chlorinated paraffins in aquatic organisms 

(Campbell and McConnell, 1980) 

Concentration of chlorinated paraffin 

(μg/kg wet weight) 

C10–20 C20–30 

Species No. of 

specimens 

Mean Range Mean Range 

Plaice (Pleuronectes 

platessa) 

6 30 ND–200 30 ND–200 

Pouting (Trisopterus 

luscus) 

4 100 ND–200 ND ND 

Mussel (Mytilus 

edulis) 

9 3,250 100–

12,000 

10 ND–100 

Pike (Esox lucius) 2 25 ND–50 25 ND–50 

Grey seal (liver and 

blubber) (Halichoerus 

grypus) 

4 75 40–100 ND ND 

Note: ND = not detected (detection limit = 50 μg/kg wet weight). 

Table 3.61 Concentration of chlorinated paraffins in birds (Campbell and 

McConnell, 1980) 

Concentration of chlorinated paraffins 

(μg/kg wet weight) 

Species Organ 

C10–20 C20–30 

Heron (Ardea 

cinerea) 

Liver 100–1,200 ND–1,500 

Guillemot (Uria 

aalge)

Liver 100–1,100 ND 

Herring gull (Larus 

argentatus) 

Liver 200–900 100–500 

Note: ND = not detected (detection limit = 100 μg/kg wet weight). 
160 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.62 Concentration of chlorinated paraffins in seabirds' eggsa (Campbell 

and McConnell, 1980) 

Concentration (μg/kg) No of eggs containing chlorinated paraffins 

C10–20 C20–30 

Not detected (<50 μg/kg) 7 17 

50 3 3 

100 3 3 

200 5 0 

300 1 0 

400 2 0 

600 1 0 

>600 (=2,000 μg/kg) 1 0 

Note: a Species included were: Cormorant (Phalocrocoracidae carbo); Gannet (Morus 

bassanus); Great skua (Catharacta skua); Guillemot (Uria aalge); Kittiwake 

(Rissa tridactyla); Puffin (Frateruela arctica); Manx shearwater (Puffinus 

puffinus); Razorbill (Alca torda) and Shag (Phalacrocorax aristotelis). 

Table 3.63 Concentration of chlorinated paraffins in human foodstuffs 

(Campbell and McConnell, 1980) 

Concentration of chlorinated 

paraffin 

μg/kg wet weight) 

Foodstuff class No of 

samples 

analysed 

C10–20a C20–30

b 

Dairy products 13 300 190 

Vegetable oils and derivatives 6 150 ND 

Fruit and vegetables 16 5 25 

Beverages 6 ND ND 

Notes: ND = not detected (detection limit = 50 μg/kg). a C10–20 chlorinated paraffins detected in approximately 70 per cent of samples; 

average concentration given. 

b C20–30 chlorinated paraffins found in only one sample of cheese (190 μg/kg wet 

wt.), one sample of potato crisps (25 μg/kg wet wt.) and one sample of peach 

fruit (25 μg/kg wet wt.). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 161

Table 3.64 Concentration of chlorinated paraffins in sheep from areas near to 

and remote from a chlorinated paraffin production plant (Campbell and 

McConnell, 1980) 

Average concentration of 

chlorinated paraffin (μg/kg) 

Location of sheep Organ analysed 

C10–20 C20–30 

Remote from industry Liver, brain, 

kidney, mesenteric 

fat 

ND ND 

Close to a chlorinated 

paraffin 

Heart ND ND 

production plant Liver 200 ND 

 Lung ND ND 

 Mesenteric fat 50 ND 

 Kidney 50 ND 

 Perinephritic fat ND ND 

Note: ND = not detected (detection limit = 50 μg/kg). 

Campbell and McConnell (1980) also analysed some post-mortem human tissues for 

the presence of chlorinated paraffins. Of the 24 subjects analysed, C20–30 chlorinated 

paraffins were detected in fat tissues of three subjects (100 μg/kg wet wt.), the liver of 

one subject (80 μg/kg wet wt.) and the fat (3,500 μg/kg wet wt.) and liver (200 μg/kg 

wet wt.) of one further subject. The concentration of C20–30 chlorinated paraffins in the 

remaining samples analysed was less than the limit of detection of the method used 

(<50 μg/kg wet wt.). In contrast to this, the C10–20 chlorinated paraffins were frequently 

detected in liver tissues (up to 1,500 μg/kg wet wt.), adipose tissues (up to ~500–600 

μg/kg wet wt.) and kidney tissues (up to ~400–500 μg/kg wet wt.). No C10–20 chlorinated 

paraffins were detected in brain tissues (detection limit for these samples was 90 μg/kg 

wet wt.). 

The results of an unpublished survey of levels of LCCPs (average carbon chain length 

C24) in biota carried out by Baldwin and Bennett (1974) have been reported by Zitko 

(1980). In all, 52 samples were analysed, covering eggs from four species of aquatic 

bird, six species of fish and two species of shell fish and the LCCPs were detected only 

once, at 0.06 mg/kg, which was close to the detection limit of the method used. Few 

other details (for example location, analytical methods used) of this study are available. 

Jansson et al. (1993) reported the occurrence of chlorinated paraffins (of unspecified 

chain length, with 6–16 chlorine atoms/molecule) at levels of 570–1,600 μg/kg lipid in 

fish and 130–280 μg/kg lipid in seal from in and around Sweden. In addition they also 

reported levels of chlorinated paraffins of 2,900 μg/kg lipid in rabbit muscle, 4,400 

μg/kg lipid in moose muscle, 140 μg/kg in reindeer suet and 530 μg/kg in osprey 

muscle in pooled samples from the same area. The results are shown in Table 3.65. 

These levels will also include contributions from chlorinated paraffins other than 

LCCPs. 
162 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.65 Concentrations of chlorinated paraffins (unspecified chain length) 

in pooled samples from in and around Sweden (Jansson et al., 1993) 

Sample Number 

of 

samples 

Location/date Lipid 

content 

Concentration* 

(μg/kg lipid) 

Whitefish muscle 35 Lake Storvindeln, 

Lapland, 1986 

0.66% 1,000 

Arctic char muscle 15 Lake Vättern, Central 

Sweden, 1987 

5.3% 570 

Herring muscle 100 Bothnian Sea, 1986 5.4% 1,400 

Herring muscle 60 Baltic proper, 1987 4.4% 1,500 

Herring muscle 100 Skagerrak, 1987 3.2% 1,600 

Ringed seal blubber 7 Kongsfjorden, Svalbard, 

1981 

88% 130 

Grey seal blubber 8 Baltic Sea, 1979–85 74% 280 

Rabbit muscle 15 Revingehed, Skåne, 

1986 

1.1% 2,900 

Moose muscle 13 Grimsö, Västtmanland, 

1985–86 

2.0% 4,400 

Reindeer suet 31 Ottsjö, Jämtland, 1986 56% 140 

Osprey muscle 35 Sweden, 1982–1986 4.0% 530 

Note: * Refers to chlorinated paraffins with 6–16 chlorine atoms and so may contain 

chlorinated paraffins other than LCCPs. 

Levels of total (C10–24) chlorinated paraffins in food, fish and marine animals have been 

reported by Greenpeace (1995). The total levels measured (on a fat weight basis) were 

271 μg/kg in mackerel, 62 μg/kg in fish oil (herring), 98 μg/kg in margarine containing 

fish oil, 16–114 μg/kg in common porpoise, 963 μg/kg in fin whale, 69 μg/kg in pork, 74 

μg/kg in cows milk and 45 μg/kg in human breast milk. The average chlorine content of 

the chlorinated paraffins detected was around 33 per cent. LCCPs were thought to 

make up between 53.5 and 94 per cent of the total chlorinated paraffins found. The 

concentrations of LCCPs present can be estimated from the data as 225 μg/kg in 

mackerel, 50 μg/kg in fish oil, 58 μg/kg in margarine, 13–107 μg/kg in porpoise, 819 

μg/kg in fin whale, 37 μg/kg in pork, 43 μg/kg in cows’ milk and 35 μg/kg in mothers’ 

milk. 

In a survey of 108 fish samples from Japan, chlorinated paraffins (of unspecified type) 

were not found in any of the samples analysed (detection limit 500 μg/kg wet wt.) 

(Environment Agency Japan, 1991). 

3.3.4.3 Comparison of predicted and measured levels 

The comparison of the predicted and measured concentrations in biota is complicated 

by the fact that some of the analyses carried out so far have not tested specifically for 

LCCPs, and are generally not related to specific sources of release. From the available 

studies where LCCPs have been specifically identified, concentrations up to around 

100–200 μg/kg lipid in fish have been measured, but higher levels (up to around 

800 μg/kg lipid) have been measured in a whale sample, and up to 14.3 mg/kg lipid 

have been reported in crabs. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 163

These few measured levels in fish agree reasonably well with the predicted 

concentrations. For example, most predicted concentrations in fish for the secondary 

poisoning scenario are in the range of around 0.5–10 μg/kg wet weight, with a 

maximum of 50 μg/kg wet weight. Using a typical lipid content of fish as 8 per cent, 

these concentrations are equivalent to 6–125 μg/kg lipid, with a maximum of 625 μg/kg 

lipid. 

The predicted concentrations in fish are calculated using estimated fish 

bioconcentration factors, which are themselves uncertain. These indicate that the types 

of LCCPs present are likely to be dominated by the C18–20 liquid and to a lesser extent 

the C>20 liquid products. The estimates of total LCCP concentrations in fish obtained 

using this approach appear to agree reasonably well with the available monitoring data. 

However, the available monitoring data are not always able to distinguish between the 

C18–20 liquid, C>20 liquid and C>20 solid chlorinated paraffins, so it is not possible to 

determine if the relative contribution of the three types is as predicted here. 

The analytical methods currently available for LCCPs all have potential drawbacks that 

result mainly from the lack of any analytical reference material that would allow 

unambiguous identification of the chlorinated paraffins either by chlorine content or 

carbon chain length (see Appendix D). Currently, the analytical data can only give an 

approximation to the actual concentrations present, and provide little information on the 

types of chlorinated paraffin present (either in terms of the chlorine content and in 

some cases the chain length distribution). Therefore it is not possible to confirm the 

expected pattern of uptake of the various types of LCCPs from the currently available 

monitoring data. 

The predicted data will be considered in the risk characterisation for secondary 

poisoning. 

The available monitoring data for levels in food indicate that levels up to about 

200 μg/kg wet weight have been determined in some dairy products and up to around 

25 μg/kg in fruit and vegetables. 

3.3.5 Marine compartment 

3.3.5.1 Predicted environmental concentrations 

The predicted concentrations of LCCPs in the marine environment (resulting from the 

production and use of LCCPs) have been estimated using the methodology outlined in 

the TGD. The method essentially assumes that the adsorption/desorption, degradation 

and accumulation behaviour of a substance in the marine environment can, in the 

absence of specific information for the marine environment, be adequately described 

by the properties of same substance in the freshwater environment. 

The starting point for the local marine assessment is the concentration of LCCP in 

effluent from the site of discharge. This effluent from industrial sites is assumed to 

enter into the marine environment without further waste water treatment. The one 

exception to this situation is when the substance is found in products used by the 

general population, where discharge via a waste water treatment plant can be 

assumed (in these circumstances the effluent concentration from the waste water 

treatment plant is used as a starting point for the assessment). For LCCPs the disposal 

of LCCPs via waste water treatment applies only in the case of DIY paints. 
164 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

The predicted concentrations are summarised in Table 3.66 (marine water), Table 3.67

(marine sediment), Table 3.68 (predators) and Table 3.69 (top predators). 

For the intermittent release scenario for metal cutting/working fluids, the TGD does not 

provide any guidance on how releases should be treated for sediment. The value 

reported in Table 3.66 assumes that the substance in water instantly equilibrates with 

the sediment. However, in reality, this is unlikely to occur as the release will be over a 

short period of time. 

An alternative approach would be to average the concentration of the released LCCP 

over the year and add this value to the concentration arising from the continuous use of 

LCCPs in the metalworking fluids (2.0 mg/kg wet weight for C18–20 liquid chlorinated 

paraffins and 2.5 mg/kg wet weight for C>20 liquid chlorinated paraffins). This approach 

gives a PEClocal(sediment) of 12–32 mg/kg wet weight for C18–20 liquid chlorinated paraffins 

and 12–32 mg/kg wet weight for C>20 liquid chlorinated paraffins, assuming that the 

intermittent disposal occurs 2–6 times/year. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 165

Table 3.66 Predicted concentrations in marine water 

Scenario Step PEClocal(seawater) (μg/l) 

C18–20 

liquid 

C>20 liquid C>20 solid Totalc 

Production Generice 2.4×10-3 4.0×10-3 2.3×10-6 6.4×10-3 

Compounding – O 1.0×10-3 NAa NAa 1.0×10-3 

Conversion – O 1.0×10-3 NAa NAa 1.0×10-3 

Use in PVC 

– plastisol 

applications Compounding/ 

conversion – O 

1.9×10-3 NAa NAa 1.9×10-3 

Compounding – O 1.7×10-3 NAa NAa 1.7×10-3 

Compounding – 

PO 

8.9×10-3 NAa NAa 8.9×10-3 

Compounding – C 8.5×10-4 NAa NAa 8.5×10-4 

Conversion – O 1.5×10-3 NAa NAa 1.5×10-3 

Conversion – PO 1.6×10-3 NAa NAa 1.6×10-3 

Conversion – C 1.4×10-3 NAa NAa 1.4×10-3 

Compounding/ 

conversion – O 

3.1×10-3 NAa NAa 3.1×10-3 

Compounding/ 

conversion – PO 

0.010 NAa NAa 0.010

Use in PVC 

– extrusion/ 

other 

Compounding/ 

conversion – C 

2.1×10-3 NAa NAa 2.1×10-3 

Use in 

rubber 

Compounding/ 

conversion 

NAa 6.0×10-4 1.7×10-4 7.7×10-4 

Use in 

sealants 

Formulation and 

use 

negligibleb negligibleb NAa negligibleb

Formulation negligibleb negligibleb 9.8×10-7 9.8×10-7 

Industrial 

application 

2.3×10-3 8.4×10-4 3.7×10-5 3.2×10-3 

Use in 

paints 

Domestic 

application 

negligibleb

 negligibleb negligibleb negligibleb

Formulation 1.2×10-4 1.2×10-4 NAa 2.4×10-4 

Use in oil-based 

fluids (large) 

NAa 4.1×10-3–

8.0×10-3 

NAa 4.1×10-3–

8.0×10-3

Use in oil-based 

fluids (small) 

0.011–

0.022

3.7×10-3–

7.3×10-3 

NAa 0.015–

0.029 

Use in 

emulsifiable fluids 

1.0×10-3 4.2×10-4 NAa 1.2×10-3 

Use in metal 

cutting/ 

working 

fluids 

Use in 

emulsifiable fluids 

– intermittent 

release 

0.91 0.30 NAa

 1.2 

continued overleaf 
166 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.66 continued

Scenario Step PEClocal(seawater) (μg/l) 

C18–20 

liquid 

C>20 liquid C>20 solid Totalc 

Formulation 3.8×10-3 1.3×10-3 NAa 5.1×10-3 Use in 

leather fat 

liquors Use – complete 

processing of raw 

hidesd 

0.033 0.011 NAa 0.044 

Use in textile applications 0.16 NAa NAa 0.16 

Regional sources 1.1×10-4 1.2×10-4 2.2×10-7 2.3×10-4 

Notes: a NA = not applicable; no significant use of the substance in this application. 

b

 The process makes no significant contribution to the levels in marine water. 

c

 Total = total concentration, assuming all types of chlorinated paraffin are 

released from a site. 

d

 The calculation for complete processing of raw hides is considered to be the 

most realistic scenario. 

e

 Calculation for a generic site. It is known that there is only one chlorinated 

paraffin production site that discharges into the sea after on-site treatment of 

the effluent. A confidential calculation for this site indicates that the maximum 

concentration in seawater would be <<4×10-4 μg/l. 

O = open systems; PO = partially open systems; C = closed systems (as 

defined in OECD, 2004b). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 167

Table 3.67 Predicted concentrations in marine sediment 

Scenario Step PEClocal(marine sediment) (mg/kg wet wt.) 

C18–20 

liquid 

C>20 liquid C>20 solid Totalc 

Production Generice 4.7 24 0.50 29

Compounding (O) 2.0 NAa NAa 2.0

Conversion (O) 2.0 NAa NAa 2.0

Use in PVC 

– plastisol 

applications Compounding/ 

conversion (O) 

3.8 NAa NAa 3.8

Compounding (O) 3.4 NAa NAa 3.4

Compounding 

(PO) 

18 NAa NAa 18

Compounding (C) 1.7 NAa NAa 1.7

Conversion (O) 2.9 NAa NAa 2.9

Conversion (PO) 3.1 NAa NAa 3.1

Conversion (C) 2.7 NAa NAa 2.7

Compounding/ 

conversion (O) 

6.1 NAa NAa 6.1

Compounding/ 

conversion (PO) 

20 NAa NAa 20

Use in PVC 

– extrusion/ 

other 

Compounding/ 

conversion (C) 

4.1 NAa NAa 4.1

Use in 

rubber 

Compounding/ 

conversion 

NAa 3.6 37 41

Use in 

sealants 

Formulation and 

use 

negligibleb negligibleb NAa negligibleb

Formulation negligibleb negligibleb 0.21 0.21

Industrial 

application 

4.5 5.1 8.0 18

Use in 

paints 

Domestic 

application 

negligibleb

 negligibleb negligibleb negligibleb

Formulation 0.24 0.75 NAa

 1.0

Use in oil-based 

fluids (large) 

NAa 25–48 NAa 25–48 

Use in oil-based 

fluids (small) 

22–43 22–44 NAa

 44–87 

Use in 

emulsifiable fluids 

2.0 2.5 NAa

 4.5

Use in metal 

cutting/ 

working 

fluids 

Use in 

emulsifiable fluids 

– intermittent 

release 

1,800 1,810 NAa

 3,610 

Table 3.67 continued overleaf 
168 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.67 continued

Scenario Step PEClocal(marine sediment) (mg/kg wet wt.) 

 C18–20 

liquid 

C>20 liquid C>20 solid Totalc

Formulation 7.4 8.0 NAa Use in 15

leather fat 

liquors Use – complete 

processing of raw 

hidesd 

65 66 NAa 131 

Use in textile applications 310 NAa NAa 310 

Regional sources 0.42 1.4 0.092 1.9

Notes: a NA = not applicable; no significant use of the substance in this application. 

b

 The process makes no significant contribution to the levels in sediment. 

c

 Total = total concentration assuming all types of chlorinated paraffin are 

released from a site. 

d

 The calculation for complete processing of raw hides is considered to be the 

most realistic scenario. 

e

 Calculation for a generic site. It is known that there is only one chlorinated 

paraffin production site that discharges into the sea after on-site treatment of 

the effluent. A confidential calculation for this site indicates that the maximum 

concentration in sediment would be >>10 times smaller than for the generic 

site. 

O = open systems; PO = partially open systems; C = closed systems (as 

defined in OECD, 2004b). 

For secondary poisoning, the concentrations in predators and top predators have been 

estimated using the following equations given in the TGD. 

PECoral(predator) = 0.5 × (PEClocal(seawater, ann) + PECregional(seawater, ann)) × BCFfish × BMF1 

PECoral(top predator) = (0.1×PEC local(seawater, ann) + 0.9 × PECregional(seawater, ann)) × BCFfish ×

BMF1 × BMF2 

Similar to the situation for secondary poisoning discussed in Section 3.3.4.1, the above 

equations given in the TGD may not be appropriate when considering actual BMF data 

from feeding studies. The intention in the TGD is to model the concentration in fish 

resulting from simultaneous exposure via both water and food in a simplified food 

chain. An example scheme which uses this available food uptake data for LCCPs is 

presented in Figure 3.7. The term food accumulation factor (FAF) is used in this 

scheme to distinguish it from the BMF given in the equation from the TGD. It should be 

noted that this scheme differs from the one used in the TGD, where the top predator 

could be a predatory mammal or bird that feeds on other marine mammals or birds (a 

different equation would be needed for such food chains). However, the scheme 

presented does allow the available food uptake data for LCCPs by fish to be used in an 

extended food chain. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 169

Figure 3.7 Feeding scheme with simultaneous exposure via both water and 

food 

Assuming that the “aquatic organism” in the food chain is also a fish, then the 

appropriate equations for this scheme are as follows. 

PECoral(predator) = PECwater × BCFfish × (1 + FAFfish) - equation 3. 

PECoral(top predator) = (1+FAFfish)

2 ×BCFfish × PECwater - equation 4. 

Using a FAF (BMF) of 1 for both C18–20 liquid and C>20 liquid chlorinated paraffins, and a 

value <<1 for C>20 solid chlorinated paraffins as before, the resulting PECs for 

predators and top predators using equations 3 and 4 would be around two times higher 

using this alternate method than using the TGD method for predators, and around four 

times higher for top predators for both the C18–20 liquid and C>20 liquid chlorinated 

paraffins, but would lead to essentially the same PECs as the TGD method for the C>20 

solid chlorinated paraffins. 

Aquatic

organism 

(prey fish)

BCFaquatic organism

BCFfish

FAFfish

BCFfish

Predatory fish

(PECoral(top predator)) 

Water

Fish 

(PECoral(predator)) 

Fish-eating 

predator 

Fish-eating 

top predator 

FAFfish
170 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.68 Predicted concentrations for marine predators 

Scenario Step PEClocal(marine predators) (mg/kg wet wt.) 

C18–20 

liquide 

C>20

liquide 

C>20 solid Totalc 

Production Generic 1.2×10-3 3.3×10-4 1.1×10-9 1.5×10-3 

Compounding (O) 1.6×10-4 NAa NAa 1.6×10-4 

Conversion (O) 1.6×10-4 NAa NAa 1.6×10-4 

Use in PVC 

– plastisol 

applications Compounding/ 

conversion (O) 

2.1×10-4 NAa NAa 2.1×10-4 

Compounding (O) 2.0×10-4 NAa NAa 2.0×10-4 

Compounding 

(PO) 

5.5×10-4 NAa NAa 5.5×10-4 

Compounding (C) 1.5×10-4 NAa NAa 1.5×10-4 

Conversion (O) 1.8×10-4 NAa NAa 1.8×10-4 

Conversion (PO) 1.9×10-4 NAa NAa 1.9×10-4 

Conversion (C) 1.8×10-4 NAa NAa 1.8×10-4 

Compounding/ 

conversion (O) 

2.6×10-4 NAa NAa 2.6×10-4 

Compounding/ 

conversion (PO) 

6.2×10-4 NAa NAa 6.2×10-4 

Use in PVC 

– extrusion/ 

other 

Compounding/ 

conversion (C) 

2.1×10-4 NAa NAa 2.1×10-4 

Use in 

rubber 

Compounding/ 

conversion 

NAa 5.5×10-5 5.1×10-9 5.5×10-5 

Use in 

sealants 

Formulation and 

use 

negligibleb negligibleb NAa negligibleb

Formulation negligibleb negligibleb 5.3×10-10 5.3×10-10 

Industrial 

application 

1.1×10-3 8.0×10-5 1.5×10-8 1.2×10-3 

Use in 

paints 

Domestic 

application 

negligibleb

 negligibleb negligibleb negligibleb

Formulation 1.2×10-4 2.3×10-5 NAa 1.4×10-4 

Use in oil-based 

fluids (large) 

NAa 3.4×10-4–

6.5×10-4 

NAa 3.4×10-4–

6.5×10-4

Use in oil-based 

fluids (small) 

5.1×10-3–

0.010 

3.1×10-4–

5.9×10-4 

NAa 5.4×10-3–

0.011 

Use in 

emulsifiable fluids 

5.3×10-4 4.7×10-5 NAa 5.8×10-4 

Use in metal 

cutting/ 

working 

fluids 

Use in 

emulsifiable fluids 

– intermittent 

release 

2.9×10-3 1.8×10-4 NAa 3.1×10-3 

Table 3.68 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 171

Table 3.68 continued

Scenario Step PEClocal(marine predators) (mg/kg wet wt.) 

 C18–20 

liquide

C>20

liquide

C>20 solid Totalc

Formulation 6.6×10-4 3.8×10-5 NAa 7.0×10-4 Use in 

leather fat 

liquors Use – complete 

processing of raw 

hidesd 

5.1×10-3 1.5×10-4 NAa 5.3×10-3 

Use in textile applications 0.071 NAa NAa 0.071 

Notes: a NA = not applicable; no significant use of the substance in this application. 

b

 The process makes no significant contribution to the levels in fish. 

c

 Total = total concentration assuming all types of chlorinated paraffin are 

released from a site. 

d

 The calculation for complete processing of raw hides is considered to be the 

most realistic scenario. 

e

 The PECs for C18–20 liquid and C>20 liquid chlorinated paraffins would be 

around two times higher using the alternate method of calculation. 

O = open systems; PO = partially open systems; C = closed systems (as 

defined in OECD, 2004b). 
172 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 3.69 Predicted concentrations for marine top predators 

Scenario Step PEClocal(marine top predators) (mg/kg wet wt.) 

C18–20 

liquide 

C>20

liquide 

C>20 solid Totalc 

Production Generic 3.2×10-4 8.4×10-5 3.9×10-10 4.0×10-4 

Compounding (O) 1.3×10-4 NAa NAa 1.3×10-4 

Conversion (O) 1.3×10-4 NAa NAa 1.3×10-4 

Use in PVC 

– plastisol 

applications Compounding/ 

conversion (O) 

1.3×10-4 NAa NAa 1.3×10-4 

Compounding (O) 1.3×10-4 NAa NAa 1.3×10-4 

Compounding 

(PO) 

2.0×10-4 NAa NAa 2.0×10-4 

Compounding (C) 1.2×10-4 NAa NAa 1.2×10-4 

Conversion (O) 1.3×10-4 NAa NAa 1.3×10-4 

Conversion (PO) 1.3×10-4 NAa NAa 1.3×10-4 

Conversion (C) 1.3×10-4 NAa NAa 1.3×10-4 

Compounding/ 

conversion (O) 

1.5×10-4 NAa NAa 1.5×10-4 

Compounding/ 

conversion (PO) 

2.2×10-4 NAa NAa 2.2×10-4 

Use in PVC 

– extrusion/ 

other 

Compounding/ 

conversion (C) 

1.4×10-4 NAa NAa 1.4×10-4 

Use in 

rubber 

Compounding/ 

conversion 

NAa 2.9×10-5 1.2×10-9 2.9×10-5 

Use in 

sealants 

Formulation and 

use 

negligibleb negligibleb NAa negligibleb

Formulation negligibleb negligibleb 2.8×10-10 2.8×10-10 

Industrial 

application 

3.1×10-4 3.4×10-5 3.2×10-9 3.4×10-4 

Use in 

paints 

Domestic 

application 

negligibleb

 negligibleb negligibleb negligibleb

Formulation 1.2×10-4 2.3×10-5 NAa 1.4×10-4 

Use in oil-based 

fluids (large) 

NAa 8.6×10-5–

1.5×10-4 

NAa 8.6×10-5–

1.5×10-4

Use in oil-based 

fluids (small) 

1.1×10-3–

2.1×10-3 

8.0×10-5–

1.4×10-4 

NAa 1.2×10-3–

2.2×10-3 

Use in 

emulsifiable fluids 

2.0×10-4 2.8×10-5 NAa 2.3×10-4 

Use in metal 

cutting/ 

working 

fluids 

Use in 

emulsifiable fluids 

– intermittent 

release 

6.6×10-4 5.5×10-5 NAa 7.2×10-4 

Table 3.69 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 173

Table 3.69 continued 

Scenario Step PEClocal(marine top predators) (mg/kg wet wt.) 

 C18–20 

liquide

C>20

liquide

C>20 solid Totalc

Formulation 2.3×10-4 2.6×10-5 NAa 2.6×10-4 Use in 

leather fat 

liquors Use – complete 

processing of raw 

hidesd 

1.1×10-3 4.9×10-5 NAa 1.1×10-3 

Use in textile applications 0.014 NAa NAa 0.014 

Notes: a NA = not applicable; no significant use of the substance in this application. 

b

 The process makes no significant contribution to the levels in fish. 

c

 Total = total concentration assuming all types of chlorinated paraffin are 

released from a site. 

d

 The calculation for complete processing of raw hides is considered to be the 

most realistic scenario. 

e

 The PECs for C18–20 liquid and C>20 liquid chlorinated paraffins would be 

around two times higher using the alternate method of calculation. 

O = open systems; PO = partially open systems; C = closed systems (as 

defined in OECD, 2004b). 

3.3.5.2 Measured data 

The available measured data for LCCPs are summarised in Section 3.3.1.3 (water and 

sediment) and Section 3.3.4.2 (biota). 

For marine water, LCCPs have been found at concentrations up to 2 μg/l in samples 

from around the United Kingdom (Campbell and McConnell, 1980). LCCPs have also 

be found to be present in marine sediments. A range of concentrations have been 

measured, for example: 

• around 12.3–12.5 μg/kg were measured in off-shore mudflats at Kaiser Wilhelm 

Koog and Den Helder (Greenpeace (1995) estimation from the total chlorinated 

paraffin concentrationm, assuming that the LCCPs accounted for 10–60 per 

cent of the total); 

• up to 10.5 μg/kg dry weight in estuarine samples from Western Europe (van 

Zeijl (1997) measured the total chlorinated paraffin concentration, but LCCPs 

with chlorine contents around 42% wt. were thought to be the predominant type 

of chlorinated paraffin found in the samples); 

• up to 600 μg/kg in marine sediments from around the UK (Campbell and 

McConnell, 1980); 

• up to 3.2 mg/kg dry weight in marine sediments close to a chlorinated paraffin 

manufacturing site in Australia (Kemmlein et al., 2002). 

For marine biota, LCCPs have been detected in marine fish (up to 200 μg/kg wet wt.) 

and mussels (up to 100 μg/kg wet wt.) from around the UK (Campbell and McConnell, 

1980); mussels (9.3 mg/kg lipid) and crab (14.3 mg/kg lipid) from close to a chlorinated 

paraffin production site in Australia (Kemmlein et al., 2002). They have also been 

detected in mackerel (at 225 μg/kg lipid), fish (herring) oil (at 50 μg/kg lipid), porpoise 

(at 13–107 μg/kg lipid) and fin whale (at 819 μg/kg lipid) samples (Greenpeace (1995), 
174 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

estimated from the total chlorinated paraffin concentration, assuming that the LCCPs 

accounted for 53.4–94 per cent of the total). 

3.3.5.3 Comparison of predicted and measured levels 

The comparison of the predicted and measured levels is complicated by the fact that 

some of the analyses carried out so far have not analysed specifically for LCCPs, and 

the data are often not related to specific sources of release. From the available studies 

where LCCPs have been specifically identified, concentrations up to around 225 μg/kg 

lipid have been measured in marine fish, with higher concentrations of up 14.3 μg/kg 

lipid and 819 μg/kg lipid being reported in crabs and whales respectively. 

The limited data available for fish agree reasonably well with the predicted 

concentrations. For example the PECs for marine predators are in the general range 

0.1–10 μg/kg wet weight, with a maximum of 71 μg/kg wet weight, and those for marine 

top predators are in the general range 0.1–2 μg/kg wet weight, with a maximum of 14 

μg/kg wet weight. Taking 8 per cent as a typical lipid content for fish, these 

concentrations are equivalent to 1–125 μg/kg lipid (predators) and 1–25 μg/kg lipid (top 

predators), with a maximum of 890 μg/kg lipid (predators) and 175 μg/kg lipid (top 

predators). 

For surface water and sediment, few data are available and it is not possible to carry 

out a meaningful comparison of the predicted and measured concentrations. For 

sediment it is, however, worth noting that the predicted concentrations of LCCPs are 

generally of a similar order to the concentration measured in marine sediment close to 

a known potential emission source in Australia (a chlorinated paraffin manufacturing 

site). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 175

4. Effects assessment: Hazard 

identification and dose 

(concentration) – response 

(effect) assessment 

4.1 Aquatic compartment (including sediment) 

The following sections review the available toxicity data for aquatic organisms. Where 

possible, a validity marking is given for each study (this appears in the summary tables 

within each section). 

The following validity markings have been used: 

1 Valid without restriction

The test is carried out to internationally recognised protocols (or 

equivalent protocols) and all or most of the important experimental 

details are available. 

2 Use with care

The test is carried out to internationally recognised protocols (or 

equivalent protocols), but either some important experimental details are 

missing, or the method used or the endpoint studied in the test means 

that interpretation of the results is not straightforward. 

3 Not valid

There is a clear deficiency in the test that means that the results cannot 

be considered as valid. 

4 Not assignable

Insufficient detail is available on the method used to allow a decision to 

be made on the validity of the study. 

In terms of the risk assessment, toxicity data assigned a validity marking of 1 or 2 will 

be considered suitable for deriving the PNEC. 

Several of the tests are unpublished studies carried out by industry or other 

organisations. It has not been possible to validate all of these tests within the scope of 

this report and these are assigned a validity marking of 4 unless it is clear that there 

are some aspects of the test that invalidate the results (for these, a validity marking of 3 

is given). The studies given a validity marking of 4 have also been considered along 

with the studies assigned a validity marking of 1 and 2 when deriving the PNEC. 
176 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

4.1.1 Toxicity to fish 

The toxicity of LCCPs to fish is summarised in Table 4.1. 

Madeley and Birtley (1980) summarised the results of acute toxicity tests using a C20–

30, 42% wt. Cl product with rainbow trout (Oncorhynchus mykiss). A concentrated 

emulsion of the chlorinated paraffin was prepared and dilutions of this emulsion were 

used in the test. No further information is available on the media preparation technique. 

A semi-static test system was used, with the test solution being renewed every 24 

hours. The tests were carried out at a temperature of 15±1°C for 96 hours with 10 fish 

at each exposure concentration. The emulsion concentration was verified by 

measurement (using infrared spectrophotometry after solvent extraction of the 

chlorinated paraffin). Some loss of chlorinated paraffin from the test emulsions was 

seen, particularly at the higher concentrations tested, so the results are based on the 

mean measured level found in the emulsions. No toxicity or unusual behaviour was 

seen at the highest concentration tested (the mean measured emulsion concentration 

was 770 mg/l). 

Johnson and Finley (1980) summarised the results of acute toxicity tests carried out by 

the Columbia National Fisheries Research Laboratory over the years 1965–1978. Few 

details of the test methods are available, and so it is not possible to validate these data. 

The 96-hour LC50 values reported for LCCPs with both rainbow trout (Oncorhynchus 

mykiss) and bluegill sunfish (Lepomis macrochirus) were >300 mg/l for a C>20, 40–42% 

wt. Cl product, >300 mg/l for a C>20, 48–54% wt. Cl product and >300 mg/l for a C>20, 

70% wt. Cl product. The paper also reports similar results for a commercial product 

(Chlorowax LV) with rainbow trout and bluegill sunfish. The IUCLID (2000a) datasheet 

indicates that this substance is a C>17, 39% wt. Cl product. 

Hoechst AG (1976 and 1977) reported the results of acute toxicity tests using several 

LCCPs with golden orfe (Leuciscus idus). Few details of the test methodology are 

available and so it is not possible to validate these data. The results are reported in 

Table 4.1 as supporting information. 

The IUCLID (2000a) datasheet contains a further 96h LC50 value of >300 mg/l for 

channel catfish (Ictalurus punctatus), but the substance tested was not identified. It has 

not been possible to trace the origin of this resultm, although it is possible that it is part 

of the Johnson and Finley (1980) dataset. If this is the case, then the result most 

probably refers to a short-chain chlorinated paraffin (C10–13, 60–65% wt. Cl), and so the 

result is not considered further in this assessment. 

Lindén et al. (1979) studied the toxicity of a C22–26, 42% wt. Cl product over 96 hours 

with bleak (Alburnus alburnus) in brackish water. The tests were carried out under 

static conditions with no aeration (the dissolved oxygen level was measured at the end 

of the test and was considered to be acceptable if the concentration was ≥5 mg/l). The 

water used in the test had a salinity of 7‰, a temperature of 10°C and a pH of around 

7.8. Six test concentrations and one control were used in the test, with groups of 10 

fish exposed at each concentration. The test substance was firstly dissolved in acetone 

prior to addition to the test chamber; the concentration of acetone in the final solution 

was ≤0.5 mg/l. No monitoring of the actual concentration of the test substance was 

carried out during the test, and the 96h LC50 was determined as >5,000 mg/l based on 

the nominal concentration added at the start of the test.

Bengtsson et al. (1979) also studied the toxicity of an LCCP in bleak (Alburnus 

alburnus) as part of a bioaccumulation study. The chlorinated paraffin tested was a 

C18–26, 49% wt. Cl substance. The tests were performed at 10°C using a semi-static 

procedure in which the test solutions containing 125 μg/l of the substance were 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 177

renewed every two to three days over the 14-day exposure period. The water used in 

the experiment was Baltic Sea water with a salinity of 7‰, and acetone was present in 

all aquaria, including controls at a concentration of 0.1 ml/l. The fish used in the 

experiment had an average weight of 4.5 g and were not fed during the exposure 

period. Six groups of 15 fish were used for both the exposure and control solutions. No 

mortality or effect on behaviour was seen in fish exposed to the LCCP during the test. 

The toxicity of two LCCPs in rainbow trout (Oncorhynchus mykiss) has been studied 

over 60 days in a GLP study (Madeley and Maddock, 1983a and 1983b). The 

substances tested were a C22-26, 43% wt. Cl commercial product and a C>20, 70% wt. Cl 

product. Both products were mixed with an n-pentacosane-13-14C that had been 

chlorinated to a similar degree. Neither of the commercial products tested contained a 

stabiliser. A flow-through system was used for each test and the concentrations of 

chlorinated paraffin were determined by both radioactivity measurements and parent 

compound analysis (using a TLC technique). The tests were carried out at 12±1°C. For 

the tests with the 43% wt. Cl product the water quality parameters were: dissolved 

oxygen 9.3–11.4 mg/l; pH 7.4–8.55; hardness 42–71 mg/l as CaCO3. Similarly for the 

tests with the 70% wt. Cl product the water quality parameters were: dissolved oxygen 

10.4–12.5 mg/l; pH 7.5–8.1; hardness 36–46 mg/l as CaCO3. The fish were fed a diet 

of proprietary trout food throughout the test at a rate of two per cent of body weight per 

day. The major endpoint determined at the end of the studies was mortality. 

Qualitative observations were also made in these studies on behaviour (the control fish 

were assumed to show "normal" behaviour) in terms of: 

• swimming behaviour; 

• general behaviour of individuals (e.g. intense activity, sluggishness, 

quiescence, position in test vessel); 

• response to presence of food; 

• skin pigmentation. 

These observations were made because certain tests using another type of chlorinated 

paraffin (e.g. short-chain chlorinated paraffins) had shown effects on behaviour in 

similar tests. 

In both tests, fish were introduced into the exposure vessels one week prior to addition 

of the test substance. At the start of the test, the chlorinated paraffin (as an acetone 

solution) was added to the in-flowing water. The flow-through system had a 95 per cent 

replacement time of around seven hours, so the actual exposure concentration would 

have reached the steady state level within a relatively short space of time. The fish 

used in the study weighed 1.4–3.2 g (for the experiments with 43% wt. Cl substances) 

and 0.53–2.77 g (for the experiments with the 70% wt. Cl substance) at the start of the 

study; groups of 30 fish were used at each exposure concentration. 

For the C22–26, 43% wt. Cl substance (Madeley and Maddock, 1983a), two nominal 

exposure concentrations of 1.0 and 3.2 mg/l were used. Acetone at a concentration of 

500 ppm (0.5 ml/l) was also present in the test solutions and so acetone controls were 

also run in the test. The actual mean measured exposure concentrations during the 

test were 0.97 mg/l and 4.0 mg/l at the two exposure concentrations respectively. 

These values were based on 14C measurements (parent compound analysis was in 

general agreement with these values). 
178 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

No fish died during the study. One fish was lost from the acetone control (assumed to 

have escaped), and no significant effects were seen on behaviour of the exposed fish 

compared with controls. The NOEC from this study was therefore reported as 4.0 mg/l, 

the highest concentration tested. The test report gives details of the fish weights and 

lengths at the end of the study. These were 9.46 g and 84.2 mm in the freshwater 

controls; 9.23 g and 81.2 mm in the acetone controls, 8.59 g and 81.5 mm in the 0.97 

mg/l exposure group and 8.38 g (this is incorrectly given as 7.38 g in the original report) 

and 80.7 mm in the 4.0 mg/l exposure group. These weight data are not commented on 

in the report but have subsequently been analysed statistically to show that there were 

no significant (p=0.05) differences in mean fish weights between the exposed 

populations or the control or solvent control populations (Thompson, 2001). The mean 

length of the fish was similar in all exposed and control populations. 

For the C>20, 70% wt. Cl substance (Madeley and Maddock, 1983b), three nominal 

exposure concentrations of 1.0 mg/l, 2.1 mg/l and 4.2 mg/l were used. Acetone at a 

concentration of 500 ppm (0.5 ml/l) for the two lower exposure concentrations or 

1,000 ppm (1 ml/l) for the higher exposure concentration was also present (two 

acetone controls were also run). The mean measured exposure concentrations by 14C 

analysis were 0.84 mg/l, 1.9 mg/l and 3.8 mg/l in the three test solutions respectively 

(parent compound analysis gave similar values). 

No significant mortalities occurred as a result of the exposures. A small number of 

deaths or losses did occur in all exposure vessels, but this was not considered unusual 

in a 60-day study. Abnormal behaviour (a few individuals were slow to respond to the 

presence of food and showed a darkening of skin pigmentation) was observed in all 

populations, including controls. These symptoms became apparent on day 3 and had 

disappeared by day 7. A similar behaviour re-occurred in the acetone control 

populations between days 12–16. Subsequently, all populations behaved normally 

except for isolated occurrences. In the early part of the study, the fish in the 3.8 mg/l 

group, and to a lesser extent the 1.9 mg/l group, found it difficult to locate their food 

due to the cloudy nature of the suspensions tested, however they later appeared to 

become acclimatised to the test conditions. It was concluded that no chemical-related 

effects on the behaviour of the fish was seen in the study. Although the test report 

provides no comment, mean fish weights and lengths were also reported. These were 

3.87 g and 59.2 mm in the freshwater controls, 4.14 g and 60.9 mm in the 500 ppm 

acetone controls, 3.70 g and 59.5 mm in the 1,000 ppm acetone controls, 4.74 g and 

65.3 mm in the 0.84 mg/l exposure group, 5.05 g and 66.0 mm in the 1.9 mg/l exposure 

group and 4.11 g and 62.4 mm in the 3.8 mg/l exposure group. Although it is not 

possible to analyse these data statistically, it is clear that no effects on growth were 

seen as a result of the chlorinated paraffin treatments in this test. The NOEC from this 

study is therefore 3.8 mg/l. 

Zitko (1974) determined LT50 values (time for 50 per cent of the fish to die) for juvenile 

Atlantic salmon (Salmo salar) in a long-term feeding study. Two LCCPs were used in 

the study; a C>20, 42% wt. Cl product and a C>20, 70% wt. Cl product. In the study, 20 

juvenile fish were kept in 20 litre tanks with a continuous flow of fresh water 

(500 ml/minute). The chlorinated paraffins were administered in the diet (trout chow) for 

181 days. The concentrations of the chlorinated paraffins used were either 10 or 

100 mg/kg food, and around 8 g of the food was added to the tanks during the course 

of a week. 

During the experiment mortalities occurred in all fish populations, including the control 

groups. The authors suggested that the mortalities seen in the control group were a 

result of the use of nutritionally deficient food in the test. In particular, the lipid content 

of the fish food used was later found to have decreased from the normal value of 5–8 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 179

per cent to ~2.5 per cent towards the end of the study; it was thought that this decrease 

may have been caused by auto-oxidation of the lipids present in the food, possibly 

forming toxic products. The LT50 value for the control population was determined as 

138 days. The LT50 values for the exposed populations were lower than this at 47 and 

80 days for the C>20, 42% wt. Cl substance and 71 and 39 days for the C>20, 70% wt. Cl 

substance for doses of 10 and 100 mg/l respectively. The authors interpreted these 

results as providing an indication that the LCCPs are toxic to salmon via the diet. 

However, given the deficiencies of the study, particularly the response of the control 

population, the validity of these findings is questionable. 
180 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 4.1 Toxicity to fish 

Species Substance tested Comments Results 

C22-26, 42% wt. Cl Static test; acetone as cosolvent; 10°C, 

brackish water (7‰), nominal concentrations. No effects seen at solubility. 

96h LC50 >5,000 mg

C18-26, 49% wt. Cl Semi-static bioaccumulation test, 10°C, 

brackish water (7‰), nominal concentrations. No effects seen at solubility. 

14-day NOEC ≥0.12

Bleak (Alburnus 

alburnus) 

C18-26, 49% wt. Cl Observations as part of an accumulation 

study. No mortalities seen during 91 days exposure in food. No effects seen. 

91-day LC0 >3,400 m

food 

Chlorowax LV Static test, 20°C, nominal 

concentrations. Test substance tentatively identified as C>17, 39% wt. Cl. 

No effects seen at solubility. 

96h LC50 >300 mg/l 

C>20, 40–42% wt. Cl Static test, 20°C, nominal 

concentrations. No effects seen at solubility. 

96h LC50 >300 mg/l 

C>20, 48–54% wt. Cl Static test, 20°C, nominal 

concentrations. No effects seen at solubility. 

96h LC50 >300 mg/l 

Bluegill sunfish (Lepomis 

macrochirus) 

C>20, 70% wt. Cl Static test, 20°C, nominal 

concentrations. No effects seen at solubility. 

96h LC50 >300 mg/l 

Table 4.1 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 181

Table 4.1 continued Species Substance tested Comments Results 

C18-20, 35% wt. Cl Static test, substance added directly to 

test vessel. Effects seen at concentrations above solubility. 

48h toxic threshold = mg/l 

C18-20, 44% wt. Cl Static test, substance added directly to 

test vessel Effects seen at concentrations above solubility. 

48h toxic threshold = mg/l 

C18-20, 49% wt. Cl Static test, substance added directly to 

test vessel. No effects seen at solubility. 

48h toxic threshold >mg/l 

Golden orfe (Leuciscus idus) 

C18-20, 52% wt. Cl Static test. No effects seen at solubility. 48h toxic threshold >

mg/l 

Chlorowax LV Static test; 10°C, nominal concentration. 

Test substance tentatively identified as C>17, 39% wt. Cl. No effects seen at 

solubility. 

96h LC50 >300 mg/l 

C>20, 40–42% wt. Cl Static test; 10°C, nominal concentration. 

No effects seen at solubility. 

96h LC50 >300 mg/l 

C20-30, 42% wt. Cl Substance tested as an emulsion. Semistatic test; 15°C, measured emulsion 

concentrations. No effects seen at solubility. 

96h LC50 >770 mg/l 

C>20, 48–54% wt. Cl Static test; 10°C, nominal 

concentrations. No effects seen at solubility. 

96h LC50 >300 mg/l 

Rainbow trout (Oncorhynchus 

mykiss) 

C>20, 70% wt. Cl Static test; 10°C, nominal 

concentrations. No effects seen at solubility. 

96h LC50 >300 mg/l 

Table 4.1 continued overleaf 
182 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 4.1 continued Species Substance tested Comments Results 

C22-26, 43% wt. Cl Flow-through test; acetone as 

cosolvent; measured concentrations. No effects seen at solubility. 

60-day NOEC ≥4 mg

Rainbow trout (Oncorhynchus 

mykiss) 

C>20, 70% wt. Cl Flow-through test; acetone as 

cosolvent; measured concentrations. No effects seen at solubility. 

60-day NOEC ≥3.8 m

C>20, 42% wt. Cl Feeding study. A high level of mortality 

was seen in the control population. The results are not considered valid. 

LT50 = 47 days at 10 

mg/kg food LT50 = 80 days at 10mg/kg food 

Atlantic salmon (Salmo salar) 

C>20, 70% wt. Cl Feeding study. A high level of mortality 

was seen in the control population. The results are not considered valid. 

LT50 = 71 days at 10 

mg/kg food LT50 = 39 days at 10mg/kg food 

Note: a Validity markings: 1 – Valid without restriction; 2 – Use with care; 3 – Not valid; 4 – Not assignable. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 183

In contrast to these results, Bengtsson and Baumann Ofstad (1982) found no mortality 

occurred in bleak (Alburnus alburnus) fed on a diet containing a C18-26, 49% wt. Cl 

product at concentrations up to 3,400 mg/kg food for 91 days. Although this study was 

designed to investigate bioaccumulation rather than toxicity, it does provide further 

evidence that the results from the Zitko (1974) are uncertain. 

4.1.2 Toxicity to aquatic invertebrates 

The results of the available toxicity tests with aquatic invertebrates are summarised in 

Table 4.2. 

Frank (1993) carried out a series of acute and longer-term studies with Daphnia magna

using a commercial C18-20, 52% wt. Cl product. The tests were carried out using 

dilutions of the water-soluble fraction of the chlorinated paraffin. Stock solutions of the 

chlorinated paraffin were made up in water to give nominal concentrations of either 100 

mg/l or 10 g/l. The 100 mg/l solution was sonicated for one hour and then left to stand 

in the dark for 48 hours before use. The 10 g/l solution also stood for 48 hours in the 

dark before use, but this time without sonication. After this period, both solutions were 

filtered firstly with glass filters and then with membrane filters to remove undissolved 

test material (microscopic and spectroscopic investigation of the filtered solutions gave 

no indication of the presence of droplets) to give the respective water-soluble fractions. 

The concentration of the chlorinated paraffin in the water-soluble fractions was 

determined by AOX (adsorbable organic halogen) analysis. The detection limit of the 

method used was around 10 μg Cl/l, which is equivalent to around 20 μg/l of the 

chlorinated paraffin. This analysis showed that the concentration of chlorinated paraffin 

present in the water-soluble fraction was around 462–519 μg/l for the 10 g/l nominal 

solution but was not detectable in the 100 mg/l solution (i.e. <20 μg/l). 

Experiments were carried out to show that in the test vessels, although the 

concentration of chlorinated paraffin present fell over time, it remained within 80 per 

cent of the initial concentration over 2–3 days. This time period was used in the longterm tests as the renewal period for the solution (semi-static method). 

Acute (48-hour) toxicity tests were carried out using dilutions of the two prepared 

water-soluble fractions (the actual dilutions used are not explicitly stated in the paper 

but there was a factor of 2 between each dilution step used). The method used was 

DIN 38 412, Teil 11, which is equivalent to the OECD 202 method. In the test using the 

water-soluble fraction from the 100 mg/l nominal solutions, no toxicity was seen at 

concentrations up to the undiluted stock solution. In the experiment using the 10 g/l 

nominal stock solution an EC0 of 360 μg/l and an EC15 of 500 μg/l was determined 

(maximum mortality seen was 15 per cent). 
184 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 4.2 Toxicity to invertebrates 

Species Substance 

tested 

Comments Results 

C18-20, 52% wt. Cl Tested as water-soluble fraction; 

measured results; variable results. 

48h EC0 = 0.36 mg/l 

48h EC15 = 0.4–0.5 m

Tested as water-soluble fraction from a 10 g/l nominal solution; semi-static test; measured dissolved concentrations 

21-day NOEC = 0.020.032 mg/l 

Tested as water-soluble fraction from a 100 mg/l nominal solution; semi-static test; dissolved concentrations based on detection limit of analytical method 

Result unreliable due inappropriate statisticanalysis. 

C18-20, 52% wt. Cl 

Tested as water-soluble fraction from a 1 mg/l nominal solution; semi-static test; actual dissolved concentrations unknown 

No effects seen in 21study. 

C18–20, 52% wt. Cl Saturated test solution was generated 

using a column method. Substance tested contained a stabiliser. The mean number of young per adult was reduced compared to the control groups, but it is not clear if this was statistically significant or not. 

Effects on reproductiomay have occurred aaround 2 μg/l 

C18-27, 60% wt. Cl Static test; unstabilised product; 

emulsifier. Effects seen at concentrations above solubility. 

24h NOEC = 23 mg/l 24h EC50 = 102 mg/l 

Water flea (Daphnia magna) 

C18-27, 60% wt. Cl Static test; stabilised product; emulsifier. 

Effects seen at concentrations above solubility. 

24h NOEC = 45 mg/l 24h EC50 = 149 mg/l 

Table 4.2 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 185

Table 4.2 continued Species Substance 

tested 

Comments Results 

Water flea (Daphnia magna) 

– continued 

C18-27, 60% wt. Cl Static test; unstabilised product; acetone 

as cosolvent. Effects seen at concentrations above solubility. 

24h NOEC = 100 mg24h EC50 = 553 mg/l 

 C18-27, 60% wt. Cl Static test; stabilised product; acetone as 

cosolvent. Effects seen at concentrations above solubility. 

24h NOEC = 100 mg24h EC50 = 1,024 mg

C18-27, 60% wt. Cl Emulsifier. Effects seen at concentrations 

above solubility. 

21-day NOEC = 4.2 m21-day EC50 = 40.8 m

C>20, 43% wt. Cl Water accommodated fraction tested. No 

effects seen at initial loadings of 0.21, 1.0 and 5.1 mg/l. It is not clear if the equilibration time was sufficient to allow a saturated solution to be prepared. 

No adverse effects seover 48 hours. 

 C>20, 43% wt. Cl No effects were seen on reproduction. 

The adult survival in some of the exposures was lower than the control and solvent control populations but this was not statistically significant. 

21-day NOEC for reproduction ≥55 μg/l 

C22-26, 43% wt. Cl No mortality seen. Endpoint = decreased 

filtration activity. No effects seen at solubility. 

60-day NOEC/LOEC 2.18 mg/l 

Mussel (Mytilus 

edulis) 

C>20, 70% wt. Cl No mortality seen. Endpoint = decreased 

filtration activity. No effects seen at solubility. 

60-day NOEC/LOEC 1.33 mg/l 

Marine crustacean C22-26, 42% wt. Cl No details available. 96h LC50 >1,000 mg/(Nitocra spinipes) C18-26, 49% wt. Cl No details available. 96h LC50 >10,000 mg

Note: a Validity markings: 1 – Valid without restriction; 2 – Use with care; 3 – Not valid; 4 – Not assignable. 
186 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

These same results (recalculated as EC0 of 357 μg/l and EC15 of 400 μg/l for the 10 g/l 

nominal stock solution), along with the results of another acute test using the same 

methodology, are reported in Frank and Steinhäuser (1994). In this case, the mean 

concentration of the chlorinated paraffin in the 10 g/l nominal and 100 mg/l nominal 

stock solutions was given as 578 μg/l and 35 μg/l respectively. No effects were seen in 

the repeat acute toxicity tests with the 100 mg/l nominal stock solution (EC0 ≥26 μg/l) or 

the 10 g/l nominal stock solution (EC0 ≥877 μg/l). The authors noted that the effects 

seen in the acute tests showed poor reproducibility, probably because effects were 

seen only around the solubility limit in the test system used. However, the authors 

thought that the possibility of undissolved droplets affecting the results could be ruled 

out as floating Daphnia were only sporadically observed in the test. Nevertheless, the 

results of this test should be treated with caution, as the effects were mainly seen in the 

saturated solutions only. 

Long-term (21-day) reproduction studies were also performed using dilutions of the 

water-soluble fractions of the two stock solutions. The dilutions used were 1:2, 1:4, 1:8 

and 1:16 for the 100 mg/l loading and 1:4, 1:8, 1:16, 1:32 and 1:64 for the 10 g/l 

loading. In these experiments, the test medium was changed three times per week and 

10 animals were used per concentration. The tests were carried out at 20°C and a pH 

of 7.79–8.44. 

Two endpoints were determined in the study: effects on parent mortality and effects on 

reproduction (number of offspring per adult). Parent mortality in the controls was 0 per 

cent in the test carried out with the 10 g/l nominal stock solution and 10 per cent in the 

test carried out with the 100 mg/l nominal stock solution. 

Elevated mortality was seen in the exposed populations. For the 10 g/l stock solution 

the LOEC was determined as the 1:8 dilution (approximately 58–65 μg/l) and the 

NOEC was determined as the 1:16 dilution (approximately 29–32 μg/l). For the 100 

mg/l nominal stock solution the LOEC was determined as the 1:4 dilution and the 

NOEC was determined as the 1:8 dilution. These dilutions are based on the detection 

limit for the analysis of the 100 mg/l stock solution, and equate to LOEC and NOEC of 

<5 and <2.5 μg/l respectively). From the dose response curves it appears that 100 per 

cent parent mortality occurred at a concentrations of around <10 μg/l in the 100 mg/l 

nominal stock solution experiments and around 125 μg/l in the 10 g/l nominal stock 

solution experiments. 

For the reproduction endpoint, the average number of young per adult in controls was 

72.3 (variability 17.8 per cent) in the 100 mg/l nominal stock solution series of 

experiments and 73.5 (variability 6.2 per cent) in the 10 g/l nominal stock solution 

experiments. A significant reduction in the number of young per adult was seen in 

some of the exposed organisms. For the 100 mg/l nominal stock solution, this effect on 

reproduction was significantly different from the control groups at the lowest 

concentration tested (a 1:16 dilution which is equivalent to a chlorinated paraffin 

concentration of <1.2 μg/l, based on the detection limit of the analytical method used). 

Thus the NOEC/LOEC for this series of experiments was <1.2 μg/l. Similarly, for the 10 

g/l nominal stock solution effects were again seen at the lowest concentration tested (a 

1:64 dilution, which is equivalent to a chlorinated paraffin concentration of 7.3–8.1 μg/l). 

This value is treated as the LOEC for this series of experiments. The report also 

indicates that the NOEC is very close to this value, since using a different statistical 

method (Dunnett’s Test rather than Williams’ Test), the effects seen at this 

concentration were not statistically significantly different from controls. 

The same 21-day results were reported by Frank and Steinhäuser (1994). In addition, 

this paper also reports the results of a similar test carried out using the water-soluble 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 187

fraction from a 1 mg/l nominal stock solution. This stock solution appears to have been 

prepared in a different manner from those previously. A solution of the chlorinated 

paraffin in pentane was prepared and a portion of this was added to the water, followed 

by stirring for one hour at 40°C to evaporate the solvent, prior to filtration. This showed 

no effects on parent mortality or reproduction in the test. However, it was not possible 

to determine the concentration of AOX (and hence chlorinated paraffins) present in 

these solutions, and so the actual exposure concentration is unknown. 

The raw data from the 10 g/l loading used in the 21-day Frank (1993) and the Frank 

and Steinhäuser (1994) studies have been obtained and reanalysed (Thompson, 2001; 

Environment Agency, 2001). These reanalyses revealed a number of issues that were 

not apparent from the published reports. Firstly, on day 8 of the study, the temperature 

appeared to have reached 37°C, although this must have occurred only for a short 

period otherwise the animals would have all died at this temperature and invalidated 

the study. 

The second point was that parent mortality at the 1:8 dilution was 20 per cent. As 

groups of 10 animals per treatment were used, the statistical significance of this effect 

compared with controls is debatable. This was considered as the LOEC in the original 

paper, but this is a marginal effect at best. The NOEC for parent mortality could be 

considered to be the 1:8 dilution (equivalent to 58–65 μg/l). 

Thirdly, a serious error was found in the statistical method (Williams’ Test) used to 

analyse the reproduction data. This error appears to have arisen in the way the data 

were entered into the statistical software, leading to the software mis-interpreting 

increasing dilutions as increasing concentrations. The software associated the 

apparent lowest concentration with the highest effect and hence, in accordance with 

the Williams procedure, compared the control with the mean reproduction rate across 

all the dilutions. 

Re-analysis of the data by both Dunnett’s test, Williams’ test and the Steel test showed 

that effects were statistically significant (p=0.05) compared with controls only at the 1:8 

dilution. Therefore the NOEC from the study is the 1:16 dilution (equivalent to a 

concentration of 29–32 μg/l). The mean number of offspring per parent at this dilution 

was 95 per cent of the control value and the mean number of offspring per parent at 

the 1:8 dilution was 74 per cent of the control value. The mean number of offspring per 

parent at the 1:64 dilution, which is treated as the LOEC in the original publication, was 

98 per cent of the control value. 

This problem with the statistical analysis may also explain why the NOEC/LOEC from 

the 100 mg/l stock appeared to be below the lowest concentration tested. The 

NOEC/LOEC reported of <1.2 μg/l is therefore questionable. 

The method for administering the test substance in the original studies also makes 

interpretation of the results difficult for a number of reasons, as discussed below. 

It is not clear if the method of preparation of the test solutions would have achieved the 

maximum possible concentration of the test substance. For example, substances with 

very low solubility may take many days or weeks to dissolve. This phenomenon may 

not be so much of a concern for the 100 mg/l and 10 g/l loadings, as effects were seen 

in these tests (indicating that sufficient test substance was present in the test solution 

even if it may not be the maximum theoretically possible). However, this may not be 

true for the 1 mg/l loading; only a very short (one hour at 40°C) equilibration period was 

allowed, which may explain the lack of effects seen in tests at this loading rate. 
188 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

The interpretation of the results is further complicated by the relatively crude analytical 

method used. The AOX method would detect chlorinated substances present in the 

solution, but provides no information on their identity. Further, the method would 

provide no indication of whether or not non-chlorinated substances were present in the 

test solutions. Therefore, although effects were seen in some of the tests, it is not at all 

clear what caused these effects. 

For example, as these tests were carried out using water-soluble fractions (also known 

as water-accommodated fractions or WAFs), toxic impurities or additives present in the 

commercial product may be preferentially extracted into the water phase, thus 

complicating the interpretation of the results. The C18-20 chlorinated paraffins are known 

to contain relatively large amounts of C17 and, to a lesser extent, C16 chlorinated 

paraffins (although these themselves would be of limited water solubility (up to 

approximately 27 μg/l)). Medium-chain (C14-17) chlorinated paraffins are known to be 

toxic to Daphnia, and a 21-day NOEC of around 10 μg/l has been determined for these 

substances. Therefore, it is possible that at least some of the effects seen in these 

tests could be due to the presence of other chlorinated paraffin impurities (or other 

more soluble unidentified chlorinated impurities) in the commercial product. 

Similarly, the method of preparation of the test solution (dilution of a WAF) would 

enhance the more water-soluble C18-20 chlorinated paraffins over the less soluble 

components; the composition of the C18-20 chlorinated paraffin in solution may not have 

been the same as that in the commercial product, and may even be different at 

different loadings rates. Dilution of WAFs is not generally recommended because it is 

likely that the more soluble components will be over-represented relative to the 

composition of the bulk material tested. In this case, the shorter chain-length 

components of the material (which are likely to be more soluble) – or any more soluble 

impurity – would be present at greater concentrations relative to the proportions of 

chain-length found in the commercial material. 

With regard to the effect of different WAF loading rates, Frank (1993) reported higher 

concentrations of measured AOX from the 10 g/l loading rate compared to the 100 mg/l 

loading rate, but the measured AOX may represent more soluble lower chain-length 

components of the test material (or indeed more soluble impurities) simply because a 

far greater quantity of these preferentially dissolved components was available10. In the 

end, the material tested in solution may not be entirely representative of the 

commercial substance. 

Whilst these factors make the studies far from ideal , they may be considered to 

represent a worst case because: 

• the bioavailability of chlorinated paraffins as a group appears to decrease with 

increasing carbon chain length and chlorine content; 

• the BCF values of the group as a whole appear to generally decrease with 

increasing carbon chain length and chlorine content; 

• the water solubility of the group as a whole appears to decrease with increasing 

carbon chain length (and also probably increasing chlorine content). 

These points therefore indicate that using the water-soluble fraction should enhance 

the relative contribution of the more accumulative and bioavailable chlorinated paraffin 

components (or impurities) of the product (i.e. those components most likely to be 

toxic). 

 

10. Assuming that the water solubility of the components is not exceeded in the solution. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 189

It is not clear from the test report whether the chlorinated paraffin used in the tests 

contained a stabiliser. If one was present and had a higher water solubility than the 

chlorinated paraffin itself, this may have preferentially dissolved during the preparation 

of the saturated solutions and would also not be detectable by the AOX analytical 

method used. A common stabiliser in this type of product is epoxidised soybean oil. 

This is reported to be of very low water solubility, and also shows low toxicity in acute 

toxicity tests (24h EC0 >100 mg/l) with Daphnia (IUCLID, 2000b). This information is 

insufficient to rule out the possibility of at least a contribution from any stabiliser present 

to the effects seen in the 21-day tests. 

There are many uncertainties in the actual values obtained in the Frank (1993) study, 

not least because the actual exposure concentration in the 100 mg/l nominal stock 

solution is uncertain, and the significance of the effects seen at the low concentrations 

is unclear. It is also worth noting that the actual measured chlorinated paraffin 

concentration in the 10 g/l nominal stock solution of around 500 μg/l is well in excess of 

the expected water solubility for this type of substance. Further, the analytical method 

used provides no real indication of what actual substances were present in the test 

solutions. 

If the toxicity seen in the Frank (1983) and Frank and Steinhäuser (1994) study was 

due to impurities or additives present in the chlorinated paraffin tested, then it is 

possible that the concentration of these additives or impurities – and hence their effect 

– would have been heightened as the amount added to the nominal stock solution 

increased. However, the LOEC was reported in the original paper to be lower in the 

test using the 100 mg/l stock solution than seen in the 10 g/l stock solution. This may 

again reflect the uncertainty in the actual exposure concentration in the 100 mg/l stock 

solution, but is more likely a reflection of the inappropriate statistical analysis carried 

out on the data. 

Overall, the results of the Frank (1983) and Frank and Steinhäuser (1994) studies are 

extremely difficult to interpret in terms of the effects of the C18–20 liquid chlorinated 

paraffins. However, given that effects were seen in the test, and the known toxicity of 

other chlorinated paraffins to Daphnia, it is difficult to dismiss the results at this stage. 

These results from these studies are considered further in the PNEC determination 

(Section 4.1.9.1). 

Another long-term toxicity test has come to light, using a similar (possibly the same) 

C18-20 52% wt. Cl product to the one used by Frank (1983) and by Frank and 

Steinhäuser (1994). This study was carried out by TNO (1993). The substance tested 

was a commercial product containing 1.5 per cent epoxidised soybean oil. The test was 

carried out according to the OECD 202 methodology using a semi-static test procedure 

(test solution renewal was carried out every 48–72 hours). The dilution water used was 

a synthetic medium (DSWL) prepared by the addition of various salts to ground water. 

The hardness of the medium was 214 mg/l as CaCO3. 

The test was carried out using saturated solutions of the chlorinated paraffin. These 

were prepared using a column technique. The column was prepared by firstly 

dissolving/suspending 0.1 g of the test substance in 25 ml of acetone. This solution 

was then added to 10 g of the packing material for the column (chromosorb 60/80 

mesh) and the acetone removed by rotation evaporation. The coated packing material 

was stored at room temperature in the dark until needed. The columns were stainless 

steel (25 cm long with an internal diameter of 4.3 mm) filled with 1 g of the coated 

packing material. The column was conditioned by pumping dilution water through at a 

flow rate of 6.2 ml every three minutes; the first 500 ml was collected and discarded. 

Around 18 litres of dilution water was then collected in a bottle and continually 
190 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

recirculated through the column at a flow rate of 3.4 ml per minute throughout the test. 

The required amount of the saturated solution needed for the start of the test, and at 

each renewal period, was then taken from the bottle. 

The test was carried out using the saturated solution, a blank control (DSWL medium 

only) and a column control (DSWL medium pumped through a column containing 

unspiked chromosorb 60/80 mesh). Four replicates (10 daphnids in 400 ml of test 

solution) were carried out for each treatment. The tests were performed in 600 ml 

beakers and these were conditioned to the test solutions for two days prior to the start 

of the test. The solutions were renewed every Monday, Wednesday and Friday during 

the test. From day 10 the test solutions were gently aerated. 

The concentration of test substance was determined at each renewal time in both the 

“fresh” solution and the “spent” solution. The analytical method used was based on 

extractable organic halogen (EOX; similar in principle to AOX) analysis. The mean 

EOX measured in the test solution over the course of the test was around 1 μg/l (the 

range found in the “fresh” solutions was 1.0–1.5 μg/l and the range in the “spent” 

solutions was 0.5–1.5 μg/l. The EOX concentrations in the control solutions were 

generally <0.5 μg/l in the “fresh” solution but the range found in the spent solutions was 

<0.5–1.0 μg/l for the blank control and 0.5–2.0 μg/l for the column control. These levels 

of EOX in the “spent” column control solution throw some uncertainty over the actual 

level of EOX that can be attributed to the chlorinated paraffin tested in the saturated 

solution. Assuming that the EOX present in the saturated test solution was related to 

the chlorinated paraffin, then an EOX level of around 1 μg/l is equivalent to a 

chlorinated paraffin concentration of around 2 μg/l (the chlorinated paraffin tested had a 

halogen content of 52% by weight). 

The temperature, dissolved oxygen concentration and pH during the test were between 

19.2 and 20.3, ≥7.1 mg/l and between 7.6 and 8.5 mg/l, respectively, throughout the 

test. The mortality and reproduction data determined in the study are summarised in 

Table 4.3. Also shown in this table are data obtained using a saturated solution of a 

medium-chain chlorinated paraffin (C14–17, 52% wt. Cl) using the same test system 

(these data are relevant to the statistical analysis of the data for the C18–20, 52% wt. Cl 

substance). 

Table 4.3 Summary of survival and reproduction in the 21-day study with 

Daphnia magna (TNO, 1993) 

Treatment group Number of surviving adults 

at day 21 

Cumulative number of 

living young per living 

female 

(mean±standard deviation) 

Blank control 97.5% 113.6±11.8 

Column control 97.5% 127.3±14.3 

C18–20, 52% wt. 92.5% 100.8±11.4 

Medium-chain 

chlorinated paraffin 

37.5% 99.8±22.1 

The parent survival in both of the control groups was 97.5 per cent. In the C18–20, 52% 

wt. Cl treatment group the parent survival was 92.5 per cent. This survival was not 

significantly different (at the p=0.05 level) from the control group. Therefore it was 

concluded that no treatment-related effects on parent morality were seen in the study. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 191

The reproduction rate (expressed as the cumulative number of young per living female) 

in the study was 113.6 in the blank control and 127.3 in the column control. The 

response of the two controls was not significantly different (at the p=0.05 level). The 

reproduction rate in the C18–20, 52% wt. Cl treatment group was 100.8. This was 88.7 

per cent of the blank control response and 79.1 per cent of the column control 

response. These responses were analysed statistically in TNO (1993) using the twotailed Dunnett-test with a 95 per cent significance level. No statistically significant 

differences were found between the C18–20, 52% wt. Cl treatment group and the blank 

control, but it is not entirely clear from the report whether the reduction in the 

reproduction rate in the treatment group compared to the column control was 

statistically significant or not. In various parts of the report (including the overall 

summary) it is stated that this difference was statistically significant, but in other places 

there are statements that no statistically significant differences were found. 

In order to investigate these results further, Thompson (2007) carried out a re-analysis 

of the data from this study. The statistical analysis was carried out on the same dataset 

as summarised in the TNO (1993) study and incorporated the dataset for a mediumchain chlorinated paraffin that was also tested at the same time as the C18–20, 52% wt. 

Cl substance. The data were found to be normally distributed and the variances were 

homogenous, satisfying the requirements for the use of ANOVA (with Dunnett’s 

procedure to maintain a family error rate of 0.05) to determine significant differences 

from the column control. Using this procedure, no significant difference was seen 

between the reproduction rate in the C18–20, 52% wt. Cl treatment group (or the 

medium-chain chlorinated paraffin treatment group) and the column control. In addition, 

a further analysis was carried out comparing the treatment groups with the pooled 

control group (the combined blank control and column control); no statistically 

significant differences for the C18–20, 52% wt. Cl treatment group were found. 

As part of this assessment, the Thompson (2007) re-analysis has been carefully 

checked; it appears to have been carried out appropriately. These data have been reanalysed using ANOVA with Dunnett’s procedure in the same way as in Thompson 

(2007), confirming that the response from the C18–20, 52% wt. Cl treatment group was 

not significantly different (at the p=0.05 level) from the column control group, the blank 

control group or the pooled control. However when the medium-chain chlorinated 

paraffins dataset was omitted from the same ANOVA procedure, a statistically 

significant difference was found between the C18–20, 52% wt. Cl treatment group and 

the column control and pool control, but not the blank control.11

The dependence of the statistical analysis on inclusion of the medium-chain chlorinated 

paraffin dataset may explain the apparent discrepancies found in the TNO (1993) 

compared with the Thompson (2007) re-analysis (it is not clear if the analysis in the 

TNO (1993) report included the medium-chain chlorinated paraffin dataset or not). 

Another consideration to take into account when considering the results of the TNO 

(1993) study is that the tests were carried out using a saturated solution. In this case 

 

11In the TNO (1993) dataset the number of young per adult were estimated based on 

the mean number of adults surving over the 2–3 day observation period (in line with the 

test guideline). In order to investigate the sensitivity of the data to this method of 

calculation, an anaysis of the dataset was also performed using the number of adults 

present at the end of the observation period to estimate the mean number of young per 

adult (for example, if there were 10 live adults at the start of the 2–3 day observation 

period, and nine at the end, the mean number of young per adult were estimated by 

dividing the total number of young over the period by nine rather than 9.5. This lead to 

essentially the same findings as for the original dataset. 
192 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

the saturated solution was prepared using a column technique, whereby an excess of 

the chlorinated paraffin was adsorbed onto column material and allowed to equilibrate 

with the water phase. There are some similarities between this method of preparation 

and the method used in the Frank (1993) and Frank and Steinhäuser (1994) series of 

studies. In particular, the composition tested in solution may not be representative of 

the composition in the bulk material. In the TNO (1993) the effective “loading rate” used 

was around 0.1 g in 18 litres of water (~6 mg/l) which is much lower than those used in 

the Frank (1993) and Frank and Steinhäuser (1994) studies (loading rates of 10 g/l and 

100 mg/l). This difference in loading would suggest that the test solutions prepared in 

the TNO (1993) may have resulted in a lower preferential extraction of the more soluble 

components (or impurities) than in the Frank (1993) and Frank and Steinhäuser (1994) 

studies. 

However, it also should be considered that the test solution in the TNO (1993) study 

was continually circulated through the column during the test and so had a much longer 

time to equilibrate with the chlorinated paraffin than was the case in the Frank (1993) 

and Frank and Steinhäuser (1994) studies (which had a 48 hour equilibration period 

with, in one case, sonication for one hour). Furthermore, in the TNO (1993) study the 

volume of water circulating through the column would have reduced during the test as 

samples of water were taken for renewal of the test solution and so the effective 

“loading rate” would have increased as the test progressed. Based on the renewal 

rates given in the test report, the amount of solution circulating through the column at 

the end of the test would have been around two litres, which would give an effective 

“loading rate” of around 50 mg/l. 

These differences in the method of preparation of the test solution mean it is very 

difficult to make a direct comparison over the likelihood of the enhanced extraction of 

the more water-soluble components (or impurities) between the TNO (1993) study and 

the Frank (1993) and Frank and Steinhäuser (1994) studies. However it is likely that all 

of these studies suffer from the same problem, to a greater or lesser extent: the 

components present in solution may not be entirely representative of the commercial 

substance. 

Overall, the results of the TNO (1993) study indicate that although a reduction in 

reproduction rate occurred in the study compared with the control group, the statistical 

significance of this reduction is marginal, and depends on the exact method used to 

analyse the data. Either way, the study can be interpreted as showing a NOEC (or a 

response close to a NOEC) at a concentration of 2 μg/l. It should also be noted that 

there are other uncertainties associated with this study, notably the presence of EOX in 

the “spent” column control solutions at concentrations similar to or higher than those in 

the C18–20, 52% wt. treatment groups. The identity of the EOX in the column control 

group is unknown. These results and uncertainties will be considered in Section 4.1.9.1 

in relation to the PNEC derivation. 

BUA (1992) reports the results of unpublished studies carried out by Hüls. The 

substance tested was a C18-27, 60% wt. Cl substance and was tested in both a 

stabilised and non-stabilised form (the stabiliser was not stated). The tests were carried 

out over 24 hours using either an emulsifier or acetone as cosolvent. The method used 

was DIN 38412 Teil 11, which is reportedly equivalent to OECD 202, Part I. The results 

are shown in Table 4.2. In addition, the same chlorinated paraffin (stabilised) was 

tested in a 21-day Daphnia reproduction study (OECD 202, Part II). The test was 

carried out with an emulsifier. The toxicity values obtained in the study were: NOEC = 

4.2 mg/l, EC50 = 40.8 mg/l and EC100 = 395 mg/l. There are few other experimental 

details available about this study. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 193

The concentrations tested in this study are clearly well above the water solubility of the 

substance and so the results need to be treated with caution. Two possibilities exist: 

i. The effects seen were indirect physical effects caused by the high test 

concentrations used, for example entrapment in a surface film. 

ii. The effects were direct toxicity of the substance in the dissolved phase. 

In this study the results do not provide any information on the actual NOEC and EC50 in 

terms of the dissolved substance. It is not possible from the available data to 

distinguish between these two possibilities, but given the high concentrations tested 

and the physical nature of the test substance it is most likely that the effects seen in 

this test were physical effects rather than direct toxicity. 

A further acute toxicity test with Daphnia magna has recently been carried out for a 

C>20, 43% wt. Cl chlorinated paraffin (Thompson, 2005). The test was carried out using 

the OECD Guideline 202 methodology using water accommodated fractions. The water 

accommodated fractions were prepared by placing a small amount of the test 

substance onto a pre-weighed glass microscope slide (the substance was distributed 

across an area of approximately 1–3 cm2

) and then each slide was placed in a support 

frame within a glass vessel containing 1.8 litres of dilution water which was stirred for 

24 hours. After stirring, the vessels were allowed to settle for 50 minutes (no visible 

signs of undissolved test substance were present), and 200 ml aliquots of each water 

accommodated fraction were drawn off for use in the test. Three different water 

accommodated fractions were prepared using initial chlorinated paraffin loading rates 

of 0.21, 1.0 and 5.1 mg/l. 

The tests were carried out using a static system with a total of 20 animals per treatment 

(four replicates of five animals were used) along with a control. No mortalities were 

seen in the control over the 48 hour experiment. Around 10-15 per cent of the animals 

in the 0.21 and 1.0 mg/l water accommodated fractions were found to be floating on the 

surface after 24 hours exposure, but these were found to be re-submerged by 48 hours 

and no further floatation was observed. No immobilised animals were seen in any 

treatment group. The 48h EC50 was therefore taken to be >5.1 mg/l, expressed as a 

water accommodated fraction loading rate. It was therefore concluded that the 

substance was not toxic at the water solubility limit. 

It should be noted, however, that there are some possible limitations with this study. 

For example, only 24 hours was allowed for preparation of the water accommodated 

fraction, and no analytical verification of the actual amount of test substance dissolved 

was carried out in the toxicity test. Overall, it is therefore difficult to judge how much 

chlorinated paraffin was dissolved in the toxicity test. 

Another 21-day reproduction test with Daphnia magna has recently been completed 

(Sharpe and Penwell, 2007). The substance tested in this study was prepared by 

mixing a 14C-labelled, C25 paraffin (~1 g) with unlabelled C>20 paraffin feedstock (~3.7 

per cent) and chlorinating the mixture to a final chlorine content of 43% by weight. The 

test was carried out according to the OECD 211 method using a semi-static test 

procedure. A stock solution of the test substance was firstly prepared in 

dimethylformamide and aliquots of this were added to Elendt’s M4 medium for use in 

the test (the amount of dimethylformamide in the test solution was 0.1 ml/l). The test 

medium had a hardness of 234 mg/l as CaCO3. Test solutions were renewed every 48 

hours during the test. 

The exposures were carried out using borosilicate glass beakers each containing one 

organism and 80 ml of test solution. A total of 10 replicates per treatment group were 
194 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

carried out. The nominal concentrations tested were 2.0, 4.0, 8.0, 16, 32 and 64 μg/l 

and a dilution water control and solvent control group were also run. The actual 

concentration of chlorinated paraffin present was determined in “fresh” and “spent” 

solution at days 0–2, 4–6, 10–12 and 18–20. The analytical method used was 

radiochemical analysis (direct scintillation counting of the test solution). The measured 

concentrations in “fresh” solutions ranged from 85 per cent to 105 per cent of the 

nominal values and the measured concentrations in the “spent” solutions ranged from 

39 per cent to 84 per cent of the nominal values. The mean measured concentrations 

found in the six treatment groups were 1.6, 3.0, 5.4, 13, 27 and 55 μg/l respectively. It 

should be noted that this analytical method would not necessarily distinguish between 

truly dissolved chlorinated paraffin and non-dissolved chlorinated paraffin, as discussed 

further below. 

During the test the temperature, pH and dissolved oxygen concentration were in the 

ranges 19.9–20.9°C, 7.33–8.12 and 8.2 to 9.2 mg/l respectively. The endpoints 

determined in the study were adult length, reproduction (number of live offspring 

produced per parent animal surviving to the end of the study) and adult mortality. The 

results are summarised in Table 4.4. No statistically significant differences (at the 

p=0.05 level) were seen between the treatment groups and the control groups for 

either adult length or reproduction. 

Table 4.4 Summary of survival, adult length and reproduction data from in 

the 21-day study with Daphnia magna using a C>20, 43% wt. Cl chlorinated 

paraffin (Sharpe and Penwell, 2007) 

Treatment 

group 

Percentage of 

surviving adults at 

day 21 

Adult length 

(mean±standard 

deviation) 

Number of live 

offspring per 

surviving adult 

(mean±standard 

deviation) 

Dilution water 

control 

90% 4.5±0.2 mm 108±31 

Solvent control 80% 4.4±0.1 mm 123±27 

1.6 μg/l 100% 4.6±0.1 mm 123±22 

3.0 μg/l 60% 4.5±0.2 mm 114±19 

5.4 μg/l 70% 4.3±0.5 mm 97±44 

13 μg/l 80% 4.5±0.1 mm 113±11 

27 μg/l 60% 4.7±0.1 mm 152±15 

55 μg/l 80% 4.5±0.2 mm 130±32 

For the parent survival, the mortality seen in the control groups was 10 per cent in the 

dilution water control group and 20 per cent in the solvent control group; this level of 

mortality falls within the guidelines for a valid test. Higher mortalities were evident in 

some of the chlorinated paraffin treatment groups. The test report indicates that the 

mortality seen in the treatment groups was not dose-related and not statistically 

significant compared with the solvent control group when tested using the Fisher’s 

exact test. 

Whilst it is evident that no clear dose response was obtained, the mortality seen in 

some of the treatment groups was substantial (up to 40 per cent) and, although this 

difference from the solvent control response was not statistically significant, this 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 195

observation warrants further consideration.12 The concentrations of the chlorinated 

paraffin used in this study were up to 55 μg/l. Based on the limited information 

available on the water solubility of LCCPs, at least some of the test concentrations 

used are likely to have exceeded the water solubility of the test substance. It is worth 

noting here that, although the concentrations present during the test were confirmed by 

measurement, the analytical method used would not necessarily distinguish between 

dissolved and undissolved test substance. Therefore it is possible that a lack of a clear 

dose response could relate to the fact that the actual “dissolved” concentration of the 

test substance was similar in most of the treatment groups once the solubility limit had 

been reached, and that concentrations at or close to this solubility limit (i.e. from 3.0 

μg/l and above) resulted in 20–40 per cent parent mortality. Alternatively, it is possible 

that the mortality seen was a result of undissolved test substance or a chance 

occurrence. 

Overall, it can be concluded from this test that the NOEC for parent mortality is at least 

1.6 μg/l, and is probably higher than this value. These results will be considered in 

relation to the PNEC derivation in Section 4.1.9.1. 

The results of tests with the brackish water harpacticoid Nitocra spinipes have been 

reported (Tarkpea et al., 1981; as quoted in WHO, 1996). The results reported were a 

96h LC50 of >1,000 mg/l for a C22–26, 42% wt. Cl compound and a 96h LC50 of 

>10,000 mg/l for a C18–26, 49% wt. Cl compound. No other details of the test were 

reported by WHO (1996), but the test method was probably the same as reported by 

Tarkpea et al. (1986), where a static method was employed using water of salinity 7‰ 

at a temperature of 20–22°C without aeration, probably using acetone as cosolvent. 

The toxicity of two LCCPs to common mussel (Mytilus edulis) has been determined 

over 60 days (Madeley and Thompson, 1983a and 1983b). The compounds tested 

were the same C22–26, 43% wt. Cl and C>20, 70% wt. Cl products (mixed with a small 

amount of radiolabelled n-pentacosane that had been chlorinated to a similar degree) 

as used in the 60-day rainbow trout study (see Section 4.1.1). The test used a flowthrough system with filtered natural seawater (salinity 35‰, pH 8.0–8.3, dissolved 

oxygen 6.1–8.25 mg/l) at 15°C. Acetone was present in the test solutions at a 

concentration of 0.5 ml/l (500 ppm), and acetone controls were also run using this 

concentration. Groups of 30 mussels were used for each exposure concentration and 

controls and they were constantly fed during the test (algal cells were added to the inflowing water at a rate of 1.0–1.1×109

 cells/day). 

For the C22–26, 43% wt. Cl substance, two nominal concentrations of 0.32 mg/l and 

3.2 mg/l were tested. The mean measured concentrations for these two exposures 

over the duration of the test were determined as 0.12 mg/l and 2.18 mg/l respectively 

by 14C-analysis. Measurements by parent compound analysis (using a TLC method) at 

various times during the test were in general agreement with these values. The 

2.18 mg/l exposure solution was reported to be cloudy in appearance, with a fine white 

deposit being observed, indicating that the solubility of the substance in the test system 

 

12 The test design used on the OECD 211 methodolgy (particularly the use of 10 

replicates of one organism each per treatment group) does not appear to be 

particularly sensitive for identifying statistically significant effects on mortality. For 

example, hypothetical calculations using Fischer’s exact test for this test design 

indicate that a mortality rate of around 70% may be required in a treatment group 

before it is significantly different from a solvent control group of 10 organisms with 20 

per cent mortality. A mortality rate of around 60 per cent would be needed in a 

treatment group before it is significantly different from a pooled control group of 20 

organisms with 15–20 per cent mortality. 
196 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

had been exceeded. No significant mortality occurred in the test. Reduced filter feeding 

activity compared to control populations was consistently observed in the 2.18 mg/l 

exposure group from the seventh day onwards, but this effect was thought to stem from 

the "particulate" nature of the test solution. 

For the C>20, 70% wt. Cl substance, the two nominal concentrations tested were 

0.56 mg/l and 1.8 mg/l. The mean measured concentrations at these two exposures 

were determined as 0.46 mg/l and 1.33 mg/l by 14C-measurements. Occasional parent 

compound analyses were in general agreement with these values. Some deposition of 

the test substance was noted at the highest concentration, indicating that the solubility 

of the substance in the test system had been exceeded. No mortality as a result of 

exposure to the chlorinated paraffin was seen in the test. Again, reduced filtration 

activity was seen in the 1.33 mg/l exposure group when compared with the control 

populations, particularly during the second half of the exposure period. However, this 

observation was variable, and on a number of occasions the filter feeding activity was 

comparable to controls; this reduction in activity was considered to be minimal and 

tentative. 

4.1.3 Toxicity to algae and plants 

No data appear to be available on the toxicity of LCCPs to freshwater algae or plants. 

Craigie and Hutzinger (1975) determined the toxicity of a C>20, 50% wt. Cl product to 

three species of marine algae (Dunaliella tertiolecta, Olisthodiscus sp. and

Thalassiosira fluviatilis). The tests were carried out for six days at 20°C. The 

chlorinated paraffin was dissolved in acetone and an appropriate volume of this 

solution was added to the flask and evaporated to dryness under a jet of air. Natural 

sea water (30 ml) was then added to the flasks and the flasks were stoppered with a 

cotton wool bung and autoclaved. The nominal chlorinated paraffin concentrations 

tested were 1 mg/l and 100 mg/l but no measurements were carried out to verify the 

actual exposure concentration. The test was started by adding a 1 ml inoculum of 3–4 

day old algal culture to the flask and each flask was shaken by hand twice daily. Each 

concentration was tested in duplicate. The algal biomass was determined by turbidity 

measurements after a six day exposure. No effects on biomass was seen in any of the 

exposed populations (the turbidity of the solutions was within 96–105 per cent of the 

control values. 

The validity of this test is highly questionable as the method of administration of the test 

substance may not have been appropriate. It appears that an acetone solution of the 

substance was added directly to the test vessel and evaporated to dryness before the 

test water was added, and then the vessel was autoclaved (the temperature was not 

stated). As this substance is likely to be highly adsorptive onto the glass vessel used, 

and twice daily shaking of the vessel was the only method used to effect mixing, it is 

highly uncertain that all the chlorinated paraffin added would be in solution, or even in 

suspension and it is possible that most of it remained adsorbed onto the test vessel. As 

no monitoring was carried out during the test it is not possible to determine if any 

substance was lost during the autoclaving procedure. 

4.1.4 Quantitative structure-activity relationships (QSARs) 

The log Kow values of LCCPs are well outside the validity range of most of the 

available QSAR methods for estimating toxicity to aquatic organisms (for example the 

methods given in the TGD are valid only for log Kow values up to 6). Therefore no 

QSAR estimates of toxicity have been carried out. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 197

Another approach that can be considered here is that of the critical body burden. This 

approach is being developed in the Reference TGD in relation to the assessment of 

substances with persistent, bioaccumulative and toxic (PBT) properties under 

REACH13. The approach is still in the draft stage but the current approach is outlined 

below. 

The approach is based on the assumption that, for substances acting by a common 

mechanism such as narcosis, the toxicity is expressed only when a critical internal 

body burden of the chemical is reached, and that this critical body burden, when 

expressed on a molar basis, is similar for all chemicals acting by that mechanism. 

Critical body burdens have been defined by several groups for substances acting by 

narcotic (and other) modes of action. These are summarised in Table 4.5 below. 

Although the data show considerable variability (particularly for the more specific 

modes of action other than narcosis), it is still useful to compare the critical body 

burden for narcosis with the expected maximum body burden for LCCPs. 

Table 4.5 Summary of critical body burdens for lethality (taken from the draft 

Reference Technical Guidance Document being developed for REACH) 

Critical body burden for lethality by mode of action 

(mmol/kg wet weight) 

Reference 

Narcosis AChE inhibitors Respiratory 

inhibitors 

Sijm (2004) 2 0.01 0.001 

Thompson and 

Stewart (2003) 

2–8 1×10-6–10 1×10-6–10 

Barron et al. (2002) 0.03–450 4×10-5–29 2×10-5–1.1 

(CNS seizure agents) 

McCarty and 

Mackay (1993) 

1.7–8 0.05–27 5×10-5–0.02 

(CNS seizure agents) 

Notes: AChE = acetylcholinesterase. 

 CNS = central nervous system. 

 

13 Regulation (EC) No. 1907/2006 of the European Parliament and of the Council of 18 

December 2006 concerning the Registration, Evaluation, Authorisation and Restriction 

of Chemicals (REACH), establishing a European Chemicals Agency, amending 

Directive 1999/45/EC and repealing Council Regulation (EEC) No 793/93 and 

Commission Regulation (EC) No 1488/94 as well as Council Directive 76/769/EEC and 

Commission Directive 91/155/EEC, 93/105/EC and 2000/21/EC. Official Journal of the 

European Union, L396, 30.12.2006, pp1-849. 
198 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Assuming a water solubility of around 5 μg/l, the following body burdens can be 

estimated in fish exposed to a saturated solution of LCCPs: 

 C18–20 liquid BCF = 1,096 l/kg 

 Molecular weight = ~500 g/mole 

 Internal body burden = ~0.01 mmol/kg wet weight 

 C>20 liquid BCF = 192 l/kg 

 Molecular weight = ~700 g/mole 

 Internal body burden = ~1×10-3 mmol/kg wet weight 

 C>20 solid BCF = 1 l/kg 

 Molecular weight = ~1,000 g/mole 

 Internal body burden = ~5×10-6 mmol/kg wet weight 

As can be seen from this analysis, the body burdens predicted are all below the ranges 

for critical body burdens for narcosis defined by Sijm (2004), Thompson and Stewart 

(2003), Barron et al. (2002) and McCarty and Mackay (1993). This indicates that none 

of the LCCPs would be expected to be toxic (lethal) to fish over long-term exposure to 

concentrations at or below the water solubility if they act by a narcotic mode of action.14

It should be noted, however, that the above approach requires a reliable value for the 

water solubility and the BCF. The available data for LCCPs is limited, particularly for 

the C18–20 liquid chlorinated paraffins (see Section 1.4.5 and Section 3.2.9.1). 

4.1.5 Overall summary of standard endpoint toxicity data 

There is a relatively large amount of aquatic toxicity data available for LCCPs. The 

substance generally shows little or no toxicity at concentrations well in excess of its 

water solubility in acute tests. Effects have been seen on Daphnia at high 

concentrations, but these are likely to be physical effects rather than direct toxicity of 

the substance itself. However, there is no fully valid algal test available for LCCPs. 

In long-term tests, significant effects have only been seen in Daphnia reproduction 

studies. Here a 21-day NOEC of 29–32 μg/l was determined for a C18–20, 52% wt. Cl 

product. This result was obtained using water-soluble fractions from a loading rate of 

10 g/l and, as such, is difficult to interpret as the toxicity seen could be due to impurities 

or additives present in the substance tested rather than the chlorinated paraffin itself. It 

should be noted that this value is slightly above the expected water solubility for LCCPs 

of around 5 μg/l (see Section 1.4.5), but no experimental water solubility data for the 

C18–20 liquid chlorinated paraffins are available. Another 21-day Daphnia reproduction 

study using a loading rate of 100 mg/l gave an apparent NOEC/LOEC of <1.2 μg/l. A 

third 21-day Daphnia reproduction study with a C18–20, 52% wt. Cl product, this time 

using a single concentration prepared by a column method, resulted in reduced 

reproduction compared with the control population at a concentration around 2 μg/l but 

the statistical significance of this result is debatable and the NOEC from this study can 

be taken as ≥2 μg/l. A 21-day Daphnia reproduction study is also available for a C>20, 

43% wt. Cl substance. This showed no effects on reproduction at concentrations up to 

55 μg/l. 

No effects were reported to be seen in 60-day studies with fish and mussels using both 

a C22–26, 43% wt. Cl product and a C>20, 70% wt. Cl product. This finding is in 

 

14 Given the relatively non-polar nature of LCCPs, and the lack of reactive groups 

present in the molecule, it would be expected that a non-specific narcotic mode of 

action would be most applicable. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 199

accordance with calculations for lethality using the critical body burden concept 

assuming a narcotic mode of toxic action. However, the fish toxicity test is not 

equivalent to the fish early lifestage test that is currently recommended in the TGD to 

assess the long-term toxicity potential of this type of substance. In particular, the 60-

day tests reported do not include any of the potentially sensitive early lifestages. 

4.1.6 Endocrine disruption 

No tests investigating the effects of LCCPs on the endocrine system in aquatic 

organisms have been located. 

4.1.7 Waste water treatment plant (WWTP) microorganisms 

Madeley and Birtley (1980) found that a C20–30, 42% wt. Cl caused no significant 

increase or decrease in bacterial activity in laboratory-scale digesters over 30 days at 

concentrations of the chlorinated paraffin of up to 10% by weight of dry sludge solids. 

The toxicity of several C18–20 chlorinated paraffins has been tested in a three-hour 

respiration inhibition test (unpublished study). The chlorinated paraffin was emulsified 

in water using 0.5 g/l nonylphenol ethoxylate surfactant and then incubated for three 

hours with activated sludge from a municipal sewage treatment plant. No effect on 

respiration was seen up to the highest concentration tested (2,000 mg/l) with a C18–20, 

35% wt. Cl product or a C18–20, 44% wt. Cl product, but inhibition was seen at 

concentrations above 1,000 mg/l with a C18–20, 49% wt. Cl product (Hoechst AG, 1985; 

BUA, 1992). 

The toxicity of LCCPs to anaerobic bacteria from a domestic waste water treatment 

plant (wwtp) has been studied using the ETAD fermentation tube method (Hoechst AG, 

1976 and 1977). The full details of the test are not available and so it is not possible to 

fully validate the results. The reported results are shown in Table 4.6. 

Howard et al. (1975) report the results of tests carried out by Hildebrecht (1972) on the 

toxicity of two LCCPs to sewage microorganisms. The two chlorinated paraffins tested 

were a C>20, 40–42% wt. Cl product and a C>20, 70% wt. Cl product. The experiments 

were carried out using bottles containing potassium acid phthalate (reported to be 

readily biodegradable), bionutrients and bacterial seed (sewage). The effect of various 

concentrations (1, 10, 50, 100 and 200 mg/l) of the chlorinated paraffins on the residual 

dissolved oxygen level in the bottles was determined after five days of incubation. In 

the controls (containing no chlorinated paraffin), the residual dissolved oxygen 

concentration at the end of the test was 4.6 mg/l. The residual dissolved oxygen 

concentration in the chlorinated paraffin treatments were all less than 1 mg/l, indicating 

that the substance had no effect on the degrading bacteria. Few other details of this 

test are available. The overall 5-day NOECs for both chlorinated paraffins from this test 

can be tentatively set as >200 mg/l. 
200 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 4.6 Summary of toxicity data for microorganisms 

Substance Comments Result Reference 

Activated Sludge 

Respiration Inhibition 

Test (equivalent to 

OECD 209) 

3 hour NOEC >2,000 

mg/l 

Hoechst AG, 

1985 

C18–20, 35% wt. 

Cl 

Anaerobic bacteria from 

a domestic wwtp – 

ETAD Fermentation 

Tube Method 

24 hour harmful 

threshold = 1,250 mg/l 

Hoechst AG, 

1976 

C20–30, 42% wt. 

Cl 

Anaerobic bacteria in 

laboratory-scale 

digester 

30 day NOEC >10% by 

weight of dry sludge 

solids 

Madeley and 

Birtley, 1980 

Activated Sludge 

Respiration Inhibition 

Test (equivalent to 

OECD 209) 

3 hour NOEC >2,000 

mg/l 

Hoechst AG, 

1985 

C18–20, 44% wt. 

Cl 

Anaerobic bacteria from 

a domestic wwtp – 

ETAD Fermentation 

Tube Method 

24 hour harmful 

threshold = 600 mg/l 

Hoechst AG, 

1976 

Activated Sludge 

Respiration Inhibition 

Test (equivalent to 

OECD 209) 

3 hour EC0 = 1000 mg/l Hoechst AG, 

1985 

C18–20, 49% wt. 

Cl 

Anaerobic bacteria from 

a domestic wwtp – 

ETAD Fermentation 

Tube Method 

24 hour harmful 

threshold = 1,250 mg/l 

Hoechst AG, 

1976 

C18–20, 52% wt. 

Cl 

Anaerobic bacteria from 

a domestic wwtp – 

ETAD Fermentation 

Tube Method 

24 hour harmful 

threshold = 1,250 mg/l 

Hoechst AG, 

1977 

4.1.8 Toxicity to sediment organisms 

No data are available on the toxicity of LCCPs to sediment organisms. 

4.1.9 Derivation of PNEC for the aquatic compartment 

4.1.9.1 PNEC for surface water 

In long-term tests, significant effects have only been seen in Daphnia reproduction 

studies. Here a 21-day NOEC of 29–32 μg/l was determined for a C18–20, 52% wt. Cl 

product. This result was obtained using water-soluble fractions from a loading rate of 

10 g/l and, as such, is difficult to interpret because the observed toxicity could be due 

to impurities or additives present in the substance tested rather than the chlorinated 

paraffin itself. In addition, the high loading rate used in this test could affect the 

composition of the substance(s) present in the solutions tested such that they may not 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 201

have been entirely representative of the commercial substance. The proportion of more 

soluble (e.g. shorter-chain length) components present in solution may have been 

enhanced compared to the composition of the commercial product). 

It should be noted that this NOEC value is slightly above the expected water solubility 

for LCCPs of around 5 μg/l (see Section 1.4.5), but no experimental water solubility 

data for the C18–20 liquid chlorinated paraffins are available. Another 21-day Daphnia

reproduction study using a loading rate of 100 mg/l gave an apparent NOEC/LOEC of 

<1.2 μg/l. Despite the shortcomings associated with the WAF technique in this case, of 

these two studies the value obtained from the 10 g/l loading is considered to be more 

reliable for use in the risk assessment because: 

i. The concentration in the water-soluble fraction for the 10 g/l loading was 

measured at the start of the test and was shown to contain at least a 

chlorinated compound (as determined by AOX measurement). The level of 

AOX in the water-soluble fraction from the 100 mg/l loading was below the 

limit of detection and so this solution is much less well categorised for 

chlorinated substances. 

ii. It was shown that the AOX concentration for the 10 g/l loading was 

maintained within 80 per cent of the starting concentration over the 2–3 day 

renewal period used in the test. 

iii. The statistical methodology used to obtain the NOEC/LOEC of <1.2 μg/l 

was probably similar to that used in the 10 g/l loading in the original paper 

and is therefore questionable. The NOEC of 29–32 μg/l has been obtained 

using several reliable statistical techniques. 

A third 21-day Daphnia reproduction study with a C18–20, 52% wt. Cl product, this time 

using a single concentration prepared by a column method, resulted in reduced 

reproduction compared with the control population at a concentration around 2 μg/l but 

the statistical significance of this result is debatable. Unfortunately, as only one 

concentration was tested, no dose-response was generated in this study. Overall the 

value of 2 μg/l from this study will be taken as a NOEC or a value close to the NOEC. It 

should be noted that, as this was the highest concentration tested, it is possible that the 

true NOEC for this substance could be higher than 2 μg/l. 

A C18–27, 60% wt. Cl product was also found to caused effects on Daphnia in a 21-day 

study, but these are most likely to be due to physical effects as a result of the high 

concentrations tested. 

A further 21-day Daphnia reproduction study is available for a C>20, 43% wt. Cl 

substance. Overall, this test gave a NOEC for reproduction of 55 μg/l but the 

interpretation of this result is complicated; it is likely that some of the concentrations 

used were above the water solubility of the test substance. 

No effects were reported to be seen in 60-day studies with fish and mussels using both 

a C22-26, 43% wt. Cl product and a C>20, 70% wt. Cl product. However, the fish toxicity 

test is not equivalent to the fish early lifestage test that is currently recommended in the 

TGD to assess the long-term toxicity potential of this type of substance. In particular, 

the 60-day tests reported do not include any of the potentially sensitive early lifestages. 

Based on the available data, there are considerable uncertainties over the toxicity of 

LCCPs to aquatic organisms. The pattern of toxicity appears to be similar to that 

observed for medium-chain chlorinated paraffins, where again effects were seen 
202 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

mainly in Daphnia. The database for LCCPs is smaller, however, and the available 

long-term Daphnia results appear to be conflicting. 

As a preliminary approach, it is suggested that the 21-day Daphnia NOEC should be 

taken as 29 μg/l for the C18–20, chlorinated paraffin. This is the result from the study 

using a water-soluble fraction derived from a 10 g/l loading, where the actual exposure 

concentration in terms of AOX (i.e. chlorine-containing substances) was best 

determined. This value may represent the more reliable value from the available 

studies using water-soluble fractions. The shortcomings of this study have been 

discussed previously, and although the value is in excess of the water solubility values 

used in the assessment15, a clear dose-response was evident in this study, and the 

statistical significance of the effects seen was clearly established. 

There are two NOEC values for C18–20 chlorinated paraffins below this value. One was 

a NOEC of <1.2 μg/l from a water-soluble fraction using a 100 mg/l loading, but there 

are uncertainties over the actual exposure concentrations and the statistical method 

used to analyse the data in this particular study. The second is a NOEC of ≥2 μg/l 

obtained in a study using a single concentration prepared using a column method. 

Since there are no reliable long-term NOECs for alga, and the available long-term fish 

test does not include exposure to potentially sensitive early lifestages, an assessment 

factor of 100 would normally be applied to the Daphnia NOEC when deriving a PNEC 

using the TGD methodology. However, in this case it can be argued that a lower 

assessment factor should be applied to the data, as Daphnia appear to be the most 

sensitive species for chlorinated paraffins as a whole. 

Table 4.7 outlines the available data for short-, medium and long-chain chlorinated 

paraffins. A PNEC of 0.5 μg/l and a PNEC of 1 μg/l have been derived for short-chain 

chlorinated paraffins (ECB, 2000) and medium-chain chlorinated paraffins (ECB, 

2005a), respectively. These have been derived from more complete and reliable 

datasets using an assessment factor of 10 in both cases. When the underlying data 

behind these PNECs are considered it can be seen that Daphnia appears to be the 

most sensitive species for chlorinated paraffins as a whole, and that the toxicity to 

Daphnia decreases with increasing carbon chain length. This provides some 

justification for deriving the PNEC for the C18–20 liquid chlorinated paraffins using an 

assessment factor of 10 on the Daphnia NOEC of 29 μg/l. This gives a PNEC for the 

C18–20 liquid chlorinated paraffins of 2.9 μg/l, and, as can be seen from Table 4.7, this 

value appears to be consistent with the trend in PNEC seen for short- and mediumchain chlorinated paraffins. 

The PNEC of 2.9 μg/l could also be taken to apply to the C>20 liquid and C>20 solid 

chlorinated paraffins. However, in the case of the C>20 liquid chlorinated paraffin, the 

available Daphnia data indicate that toxicity does not occur until concentrations well in 

excess of the water solubility are used and so the effects seen in the Daphnia tests 

with this substance may be due to physical effects rather than direct toxicity. Thus, a 

PNEC of 2.9 μg/l may be overprotective for this type of chlorinated paraffin. No 

Daphnia data are available for the C>20 solid chlorinated paraffin. Therefore it is not 

possible to derive reliable PNECs from the available data. 

An approach that could be used for the C>20 liquid and C>20 solid chlorinated paraffins is 

to calculate a tentative screening PNEC based on the NOEC of 55 μg/l from the recent 

study with a C>20 43% wt. Cl substance, recognising that this NOEC value is likely to be 

in excess of the water solubility of the substance tested. Applying an assessment factor 

 

15 The actual water solubility of the substance tested is not known. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 203

of 10 to this value (using similar arguments as above i.e. that Daphnia are likely to be 

the most sensitive species overall for chlorinated paraffins) would give a PNEC of 

around 5.5 μg/l. This screening PNEC is then reasonably consistent with those derived 

for other chlorinated paraffins (see Table 4.7) and is also consistent with the fact that 

toxic effects are considered unlikely from the C>20 liquid and C>20 solid chlorinated 

paraffins at concentrations up to their water solubility (around 5 μg/l). 

These values will be used here in a provisional assessment of these substances to 

determine if more reliable toxicity data for the substances themselves are required. 

This approach should be conservative and protective for these C>20 substances 

because they are expected, based on QSAR estimates, to be less accumulative, and 

hence have a lower potential to cause long-term effects, than the shorter-chain length 

chlorinated paraffins. 
204 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 4.7 Comparison of long-term NOEC data for chlorinated paraffins 

Endpoint Chlorinated paraffin type 

Shortchain Mediumchain C18–20 liquid C>20 liquid C>20 solid 

21-day 

Daphnia

reproduction 

study 

NOEC = 5 

μg/l 

NOEC =10 

μg/l 

NOEC = 29 

μg/l 

NOEC = 55 

μg/l (or ≥1.6 

μg/l) 

32-day early 

lifestage study 

with 

Cyprinodon 

variegatus 

280 μg/l 

60-day study 

with

Oncorhynchus 

mykiss 

LC50 340 

μg/l 

no effects 

at solubility 

 no effects 

at solubility 

no effects 

at solubility 

20-day 

embryo-larval 

study with 

Oryzias 

latipes 

NOEC = 

9.6–62 μg/l 

(four 

substances 

tested) 

no effects 

at solubility 

(two 

substances 

tested) 

 

Algal NOEC 12 μg/l no effects 

at solubility

 

Assessment 

factor used to 

derive PNEC 

10 10 10 10 

PNEC 0.5 μg/l 1 μg/l 2.9 μg/l 5.5 μg/l 5.5 μg/l 

(taken to be 

the same 

as for C>20

liquid 

products) 

To summarise, the PNECs that will be used for the initial assessment of the aquatic 

compartment are: 

 C18–20 liquid PNECwater = 2.9 μg/l 

 C>20 liquid PNECwater(screening) = 5.5 μg/l 

 C>20 solid PNECwater(screening) = 5.5 μg/l 

An alternative approach that could be used for the C>20 liquid and C>20 solid chlorinated 

paraffins would be to derive no PNEC at all for such substances and carry out a 

qualitative assessment for surface water. However, although a qualitative assessment 

for surface water would be possible, it would not necessarily be possible to extend this 

to other relevant compartments (for example sediment and soil). Therefore, on 

balance, although it is accepted that there are uncertainties associated with the 

PNECwater(screening) values for the C>20 liquid and C>20 solid products, it is useful to 

consider these in the risk characterisation as they allow the PECs calculated for 

surface water (and sediment and soil) to be put into context. Although such values 

cannot be used to determine whether a risk actually exists, they are useful in 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 205

determining where no risk is likely to occur and for identifying where further work might 

be needed to determine better the PNEC for these substances. These issues are 

considered further in the risk characterisation. 

4.1.9.2 PNEC for sediment 

There are no toxicity data available for LCCPs on sediment-dwelling organisms. In the 

absence of any ecotoxicological data, the PNEC can provisionally be calculated using 

the equilibrium partitioning method as follows. 

 PNECsed = Ksusp-water × PNECwater × 1000 

 RHOsusp 

 

where Ksusp-water = suspended matter-water partition coefficient 

 = 2.27×106

 m3/m3 for C18–20 liquid chlorinated paraffin 

 = 6.93×106

 m3/m3 for C>20 liquid chlorinated paraffin 

 = >2.5×108

 m3/m3 for C>20 solid chlorinated paraffin 

 RHOsusp = bulk density of suspended matter = 1,150 kg/m3

Using this equation, the following PNECsed can be derived: 

C18–20 liquid chlorinated paraffin PNECsed = 5,710 mg/kg wet wt. 

C>20 liquid chlorinated paraffin PNECsed(screening) = 33,100 mg/kg wet wt. 

C>20 solid chlorinated paraffin PNECsed(screening) = >1,200,000 mg/kg wet wt. 

These PNECs assume that the exposure, and hence effects of the substance, occurs 

mainly via sediment pore water. The ingestion of sediment-bound substance by the 

exposed organisms may not be sufficiently explained by this relationship for 

substances with a log Kow >5. The TGD suggests that in such cases, the PEC/PNEC 

ratio should be increased by a factor of 10. 

Toxicity tests using medium-chain chlorinated paraffins with sediment organisms 

(Chironomus riparius, Hyalella azteca and Lumbriculus variegatus) have been carried 

out (Thompson et al., 2001a, 2001b and 2002). The lowest NOEC for these species 

was 50 mg/kg wet wt. obtained for both Lumbriculus variegatus and Hyalella azteca in 

a sediment with a 4.9–5 per cent organic carbon content. A PNECsed of 5 mg/kg wet wt. 

was derived from these data using an assessment factor of 5 (ECB, 2005a). This was 

very similar to the PNECsed of 12.6 mg/kg derived for medium-chain chlorinated 

paraffins using the equilibrium partitioning method (the value is different by a factor of 

2.6). At least some of the difference between the two values could be explained by the 

fact that the NOECs underlying both PNEC determinations depend to some extent on 

the actual concentrations and concentration intervals used in the various tests. Similar 

agreement is also evident in a comparative study of the toxicity of different mediumchain chlorinated paraffins to soil organisms (see Section 4.2). Taking these results 

into account, the equilibrium partitioning method appears to be appropriate for mediumchain chlorinated paraffins and direct ingestion of sediment-bound substance is only a 

minor contributor to the toxicity seen for this class of substance. 

However, LCCPs are predicted to adsorb onto sediment to a greater extent than 

medium-chain chlorinated paraffins and so it is possible that direct ingestion of 

sediment-bound substance could become a more important route of exposure for these 

substances than was seen in the experiments with medium-chain chlorinated paraffins. 
206 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Therefore, the PEC/PNEC ratios based on the equilibrium partitioning method will be 

increased by a factor of 10 to take this possibility into account in this assessment. 

4.1.9.3 PNEC for WWTP 

There are toxicity data available for the effects of various LCCPs on bacteria. In these 

experiments, the lowest threshold concentration reported to cause effects 

(approximates to a NOEC/LOEC) was 600 mg/l for a C18–20 liquid chlorinated paraffin 

on anaerobic bacteria. The NOECs for C>20 liquid and C>20 solid chlorinated paraffins 

are >200 mg/l (no effects seen). The TGD suggests that an assessment factor of 10 

can be applied to the NOEC or EC10 from a test using mixed bacterial populations. 

Therefore, the PNEC for waste water treatment plants can be estimated at 60 mg/l. 

This PNEC is protective for all types of LCCPs. 

Considerations for the marine environment 

The available dataset contains several results with marine and brackish water species. 

These data generally show a similar pattern of toxicity as with freshwater species. The 

most sensitive freshwater species to LCCPs appears to be Daphnia magna, where 

effects were seen in 21-day tests with a C18–20 liquid chlorinated paraffin. There are 

acute toxicity data available for marine crustaceans (the brackish water harpacticoid 

Nitocra spinipes). There are few details available for this test, but no effects were seen 

with either a C22–26, 42% wt. Cl compound or a C18–26, 49% wt. Cl compound at 

concentrations in excess of the substances’ solubility. 

In addition, a 60-day study is available with mussels for a C22–26, 43% wt. Cl substance 

and a C>20, 70% wt. Cl substance, both showing no effects at water solubility. As the 

related C14–17 chlorinated paraffins also showed effectively little or no effects at water 

solubility with mussels (ECB, 2005a) it can be concluded that the C18–20, liquid 

chlorinated paraffins are also unlikely to be toxic to mussels at concentrations below 

their water solubility limit. 

According to the TGD, an assessment factor of 1,000, 500, 100 or 50 could be 

considered for this dataset, depending on the confidence to which the most sensitive 

species has been tested. An assessment factor of 5016 will be used on the NOEC of 29 

μg/l from the 21-day Daphnia study with the C18–20, 52% wt. Cl substance. Thus the 

PNECmarine water will be taken to be 0.58 μg/l for the C18–20 liquid chlorinated paraffins. 

Similarly, for the C>20 liquid and C>20 solid products, a PNECmarine water(screening) of 1.1 μg/l 

will be used (based on an assessment factor of 50 applied to the Daphnia NOEC of 

55 μg/l for a C>20 43% wt. Cl product).17 

 

16 An assessment factor of 50 is used as there is a long-term NOEC for a freshwater 

species (Daphnia), the read-across from short- and medium-chain chlorinated paraffins 

suggests that Daphnia are likely to be the most sensitive freshwater species (see 

Section 4.1.9.1). There is also data to indicate that an additional marine taxonomic 

group (molluscs) is unlikely to be more sensitive than Daphnia. 17 This is consistent with the approach taken to derive the freshwater PNEC for these 

substances (see Section 4.1.9.1). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 207

No data are available on the toxicity to marine sediment organisms. According to the 

TGD, the PNEC for marine sediment can be estimated using the equilibrium 

partitioning approach. The following values for the PNECmarine sediment are therefore 

obtained: 

 C18–20 liquid PNECmarine sediment = 1,140 mg/kg wet wt. 

 C>20 liquid PNECmarine sediment = 6,620 mg/kg wet wt. 

 C>20 solid PNECmarine sediment >239,000 mg/kg wet wt. 

For substances with log Kow >5, the TGD indicates that the PEC/PNEC ratios should 

be increased by a factor of 10 to take into account the possible direct ingestion of 

sediment-bound substance. This factor will be taken into account in the risk 

characterisation. 

4.2 Terrestrial compartment 

4.2.1 Terrestrial toxicity data 

There are no studies available on the toxicity of LCCPs to plants, earthworms or other 

soil-dwelling organisms. 

4.2.2 PNEC for the soil compartment 

In the absence of any ecotoxicity data, the PNEC may be calculated provisionally using 

the equilibrium partitioning method as follows. 

 PNECsoil = Ksoil-water × PNECwater × 1000 

 RHOsoil 

Where Ksoil-water = soil-water partition coefficient 

 = 2.72×106

 m3/m3 for C18–20 liquid chlorinated paraffins 

 = 8.31×106

 m3/m3 for C>20 liquid chlorinated paraffins 

 >3.0×108

 m3/m3 for C>20 solid chlorinated paraffins 

RHOsoil = bulk density of soil = 1,700 kg/m3

 

The following PNECsoil can be estimated: 

C18–20 liquid PNECsoil = 4,640 mg/kg wet wt. 

C>20 liquid PNECsoil(screening) = 26,900 mg/kg wet wt. 

C>20 solid PNECsoil(screening) >971,000 mg/kg wet wt. 

Similar to the case with sediment, these PNECs assume that the exposure, and hence 

effects, is mainly through the soil pore water. The ingestion of soil-bound substance by 

soil dwelling organisms may not be sufficiently explained by this relationship for 

substances with log Kow >5. The TGD suggests that the PEC/PNEC ratio should be 

increased by a factor of 10 to take into account this route of exposure. 

Toxicity tests using medium-chain chlorinated paraffins with soil organisms (plants 

Triticum aestivum, Brassica napus and Phaseolus aureus, earthworms Eisenia fetida,

and soil nitrification processes) have recently been carried out (Thompson et al., 2001c 

and 2001d; Thompson, 2002). The lowest NOEC from these tests was 248 mg/kg 

wet wt. for Eisenia fetida in a soil with a 4.7 per cent organic carbon content. When this 

value is normalised to the organic carbon content of 2 per cent used in the TGD, the 
208 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

NOEC becomes 106 mg/kg wet wt. A PNECsoil of 10.6 mg/kg wet wt. was derived from 

these data using an assessment factor of 10 (ECB, 2005a). This value was almost 

identical to the PNECsoil of 10.4 mg/kg derived for medium-chain chlorinated paraffins 

using the equilibrium partitioning method. This agreement suggests that the equilibrium 

partitioning method is appropriate for medium-chain chlorinated paraffins and that 

direct ingestion of soil-bound substance is only a minor contributor to the toxicity seen. 

LCCPs are, however, predicted to adsorb onto soil to a larger extent than mediumchain chlorinated paraffins and so it is possible that direct ingestion of soil-bound 

substance could become a more important route of exposure for these substances 

than was seen in the experiments with medium-chain chlorinated paraffins. Therefore, 

the PEC/PNEC ratios based on the equilibrium partitioning method will be increased by 

a factor of 10 to take this possibility into account. 

4.3 Atmosphere 

4.3.1 Toxicity data relevant to the atmospheric compartment 

No data are available on possible effects of the substance on the atmosphere. 

4.3.2 PNEC for the atmospheric compartment 

It is not currently possible to derive a PNEC for the atmospheric compartment for 

LCCPs. However, given the low predicted environmental concentrations, neither biotic 

nor abiotic effects are likely. 

Concern has been raised that chlorinated paraffins, particularly the short-chain ones, 

may be subject to long-range atmospheric transport and subsequent bioaccumulation 

in remote regions. This issue is currently being discussed within the appropriate 

international fora, but no agreement has yet been reached. The potential for long-range 

transport (and subsequent accumulation) of the long-chain substances appears to be 

less than that for short-chain products because the LCCPs generally have lower 

vapour pressures and are likely to adsorb more strongly to soil and sediment. However, 

LCCP substances contain many components and the components exhibit a range of 

physico-chemical properties. Some components of commercial products may have 

properties that make long-range transport via the atmosphere a possibility. This issue 

should be considered further in the appropriate international fora. 

4.4 Non-compartment-specific effects relevant for 

the food chain (secondary poisoning) 

4.4.1 Avian toxicity 

The toxicity of a C22–26, 42% wt. Cl chlorinated paraffin to chicken embryos has been 

studied. In the study, the chlorinated paraffin was injected into fertilized hens' eggs 

after four days of incubation in an emulsion of peanut oil, lecithin and water at a dose of 

100 or 200 mg/kg egg. No effects were seen on the incubation time, hatching rate, 

hatching weight, weight gain after hatch (the observations were made up to day 39 

after the start of incubation) or liver weights of the chicks when compared with the 

control group (Brunström, 1993). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 209

In a further injection study, Brunström (1995) investigated the effects of a C22–26, 42% 

wt. Cl substance on liver weight, microsomal enzyme activities and cytochrome P-450 

concentration in chick embryos after 20 days of incubation. In this experiment the 

chlorinated paraffin concentration used was 300 mg/kg egg. No effects were seen on 

the viability of the chick embryos, liver weights or AHH (aryl hydrocarbon 

(benzo[a]pyrene) hydroxylase) activity due to the treatment. A statistically significant 

(p<0.01) increase in cytochrome P-450 concentration and decrease in APND 

(aminopyrine N-demethylase) and ECOD (7-ethoxycoumarin O-deethylase) activity 

was observed in the treated population when compared to the control population. 

4.4.2 Mammalian toxicity 

There are mammalian toxicity data for representative LCCP products with carbon 

chain-lengths C20–30 for: 

• acute toxicity; 

• skin and eye irritation; 

• skin sensitisation; 

• repeated dose toxicity; 

• mutagenicity (limited to bacterial gene mutation and in vivo cytogenetics 

testing); 

• carcinogenicity; 

• developmental toxicity. 

However, toxicokinetic information for the C20–30 LCCPs is limited and there are no data 

on: 

• repeated skin exposure (a hazardous property identified for medium-chain 

length chlorinated paraffins); 

• the potential to induce gene mutations in mammalian cells; 

• fertility; 

• parturition; 

• lactation. 

The hazardous properties of the C20–30 LCCPs in these data-gap areas will be predicted 

based on what is known about the toxicity of the medium-chain chlorinated paraffins 

(MCCPs, CAS no. 85535-85-9) (ECB, 2007b). The justification for this read-across is 

that the C20–30 LCCPs have a similar chemical structure to the MCCPs and certain 

physico-chemical properties are similar (log Kow, water solubility). Further, the profiles 

of both groups of chlorinated paraffins are broadly similar where studies have been 

conducted on their adverse health effects. Therefore, the toxicity of LCCPs in other 

areas is likely to be similar to MCCPs. There are also data gaps for the MCCPs, so the 

European risk assessment for the MCCPs involves a read-across from the short-chain 

chlorinated paraffins (SCCPs, CAS no. 85535-84-8) (ECB, 2000). A summarised 

comparison of the physico-chemical and toxicological properties of these three 

categories of chlorinated paraffins is provided in Appendix I. 
210 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

With the exception of a skin irritation study, no mammalian toxicity data are available 

for the LCCPs with carbon chain lengths C18–20. Additionally, information on the 

physico-chemical properties, in particular water solubility and log Kow, are limited. 

The hazardous properties of the C18–20 LCCPs have been predicted on the basis of 

what is known about the toxicity of the MCCPs and the LCCPs that have carbon chain 

lengths C20–30. The justification for this read-across is that the C18–20 LCCPs have a 

similar chemical structure to the MCCPs and C20–30 LCCPs and therefore their toxic 

properties are likely to be similar. There are uncertainties in this read-across, so the 

most conservative toxicology positions possible will be taken as the prediction for the 

C18–20 LCCPs (based on data for the MCCPs and C20–30 LCCPs). Furthermore, an 

additional assessment factor will be used in the risk assessment for C18–20 LCCPs to 

account for uncertainty in these predictions. 

4.4.2.1 Toxicokinetics 

Studies in animals 

Limited toxicokinetic information is available for a C22–26, 43% chlorination product and 

a C22–26, 70% chlorination product. 

In conjunction with a standard 13-week repeated dose toxicity study, 18 rats of each 

gender received a single dose of a radiolabelled C22–26, 43% chlorinated LCCP by the 

oral (gavage) route at 100 or 3,750 mg/kg (IRDC, 1981). The animals were dosed 

either after having received the respective dose level of unlabelled LCCP daily for 13 

weeks or having previously not been exposed to LCCP. Radioactivity in faeces and 

urine was monitored during the first seven days after radiolabelled LCCP dosing. Three 

animals per gender per group were killed at 0.5, 1, 2, 7, 28 and 90 days for collection of 

tissue and/or blood samples for radioactivity measurement. 

It was found that between 82 and 95 per cent of the administered radioactivity was 

recovered in the faeces during the seven-day collection period, most of which was 

recovered during the first two days. Between 0.1 and 0.8 per cent of the radiolabel was 

excreted in the urine. Blood concentrations of radioactivity in animals from the twodose groups were very similar. Also, the inter-group differences in the concentration of 

radioactivity for any given tissue were much less than the differences between the 

administered dose. Tissue radioactivity levels were initially greatest in the liver but by 

90 days a redistribution to adipose tissue had occurred. This study suggests that 

absorption of the LCCP product may be saturable, but the extent of systemic 

absorption and systemic elimination of LCCP could not be determined from this study. 

Toxicokinetics of the C22–26, 70% chlorination product were investigated in a study of 

identical design (IUCLID, 2008). It was found that between 61 per cent and 88 per cent 

of the administered radioactivity was recovered in the faeces during the seven-day 

collection period. Only a very small proportion of the radioactivity (<0.1–1 per cent) was 

excrete in the urine. The highest levels of radioactivity were found in the liver, gonads 

and adipose tissue seven days after dosing, with lower levels being found in the brain, 

kidney, blood and heart. As was the case with the C22–26, 43% chlorination LCCP study, 

the extent of systemic absorption and systemic elimination could not be determined. 

Studies in humans 

No data are available. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 211

Summary of toxicokinetics 

Limited toxicokinetic information is available for the LCCP products. Based on this 

information and that available for MCCPs, it is predicted that absorption via the oral 

and inhalation routes will be significant (about 50 per cent of the administered dose). 

Absorption via the dermal route is predicted to be lower (about 1 per cent of 

administered dose). It can be predicted that LCCPs could be preferentially distributed 

to fatty tissues in the body, and that excretion via breast milk could occur. It is possible 

that there will be some metabolism of LCCPs to CO2. 

4.4.2.2 Acute toxicity 

Studies in animals 

Inhalation

No data are available. 

Oral

Valid acute toxicity investigations by the oral route (gavage) have been conducted on 

five LCCP products: C20–30 41–50% chlorination, C22–26 42% chlorination, C23 43% 

chlorination, C20–30 61–70% chlorination, C24 70% chlorination (IUCLID, 2003). Most of 

the studies were conducted in rats, but the dog and mouse have also been used as 

test species. The maximum dose levels used in these studies ranged from 4,000 to 

50,000 mg/kg. 

The LCCP products were all found to have very low acute toxicity. No deaths were 

reported in any of the studies. Furthermore, non-lethal toxicity was reported in only one 

of the studies; in the exception, incontinence was observed during the two days 

following dosing. 

Dermal

No data are available. 

Studies in humans 

No data are available. 

Summary of acute toxicity 

Acute oral toxicity data in animals are available for a number of LCCP products with 

carbon chain lengths ranging from C20 to C30. These data show that the LCCP products 

are of low acute toxicity. Based on the low oral toxicity and absence of any significant 

irritant hazard (see Section 4.4.2.3), it can be predicted that the LCCP products will 

also be of low acute toxicity by the inhalation and dermal routes. As both MCCPs and 

C20–30 LCCPs are known to be of low acute toxicity, is assumed that the C18–20 LCCPs 

will also be of low acute toxicity. 

4.4.2.3 Irritation 

Studies in animals 

Skin

Valid skin irritation testing has been conducted on four LCCP products: C19 44% 

chlorination, C20–30 70% chlorination, C22–26 42% chlorination and C20–30 41–50% 

chlorination products (IUCLID, 2003). No evidence of irritation was seen in the testing 
212 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

of three products. However, for the C22–26 42% chlorination product tested, erythema 

was observed in two out of six animals, indicating a potential to cause slight irritation, 

albeit below the severity threshold for classification according to the EU system. 

No information is available on the effects on the skin of repeated application of LCCPs 

so information from MCCPs is taken into account in the summary. 

Eye

Valid eye irritation testing has been conducted on two LCCP products (IUCLID, 2003). 

A C20–30 61–70% chlorination product caused no eye irritation. Evidence of slight 

irritation was seen in a test of a C22–26 42% chlorination product, but the criteria for 

classification as an eye irritant were not met. 

Respiratory Tract

No data are available. 

Studies in humans 

No data are available. 

Summary of irritation 

Skin and eye irritation have been investigated in animal studies for a number of LCCP 

products with carbon chain lengths ranging from C19 to C30. These studies suggest that 

the LCCPs have the potential to cause slight irritation, albeit below the severity 

threshold for classification according to the EU system. Single exposure to MCCPs 

also caused slight irritation in standard tests, but somewhat more pronounced irritation 

has been reported following repeated exposure, presumably due to defatting 

properties. In the absence of studies on repeated application of LCCPs to skin, a 

conservative assumption is made that LCCPs will have a similar effect as MCCPs. 

There are no specific data on respiratory tract irritation, but on the basis of the low skin 

and eye irritation potential, it is anticipated that the LCCP products are unlikely to 

cause such an effect. 

4.4.2.4 Corrosivity 

The skin and eye irritation studies summarised above in Section 4.4.2.3 demonstrate 

that LCCPs are not corrosive. 

4.4.2.5 Sensitisation 

Studies in animals 

Guinea pig maximisation tests have been conducted on two LCCP products (IUCLID, 

2003; IUCLID, 2000a). A C22–26 42% chlorination product tested negative in a test 

considered to be valid. A C18–27 40% chlorination product elicited a positive response; 

no information is available on the quality of this study. 

A Buehler guinea pig test has been conducted on a C22–26 product (chlorination level 

not stated) (Bailey and Sheldon, 1998). Negative results were reported for the LCCP 

product in mineral oil. This study was reported as a brief abstract, so it is not possible 

to assess the quality of the study. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 213

Studies in humans 

Skin

No data are available. 

Respiratory Tract

No data are available. 

Summary of sensitisation 

Both positive and negative results have been obtained in standard guinea pig skin 

sensitisation tests. Although firm conclusions cannot be drawn from the available data, 

it is possible that the LCCPs may have the potential to cause skin sensitisation 

reactions. 

4.4.2.6 Repeated dose toxicity 

Studies in animals 

Inhalation

No data are available. 

Oral

Standard repeated dose toxicity studies in rats are available for two similar LCCP 

products with 43% chlorination, one with a carbon chain length C22–26,and one with 

C23av, and a 70% chlorination LCCP product with a carbon chain length C20–26. The 

studies were conducted in compliance with GLP. 

C22–26, 43% chlorination product 

In a preliminary 14-day study, the LCCP product was administered by gavage to 

groups of five Fischer rats of each gender at dose levels of 0 (corn oil vehicle control), 

30, 100, 300, 1,000 or 3,000 mg/kg/day (IRDC, 1981a). Bodyweights, food and water 

consumption and the presence of clinical signs of toxicity were monitored throughout 

the study. At termination, a necropsy was conducted in which macroscopic 

abnormalities and selected organ weights were recorded. Liver microsomal Lowry 

protein and cytochrome P-450 levels and aminopyridine demethylase activity were 

determined. Liver and kidneys were subject to microscopic examination. There were no 

intergroup differences that were considered to be treatment-related and therefore a 

NOAEL of 3,000 mg/kg/day for a 14-day exposure period was identified. 

In a standard 13-week repeated dose toxicity study the LCCP product was 

administered by gavage to groups of fifteen Fischer rats of each gender at dose levels 

of 0 (corn oil vehicle control), 100, 900 or 3,750 mg/kg/day (IRDC, 1984). Bodyweights, 

food consumption and the presence of clinical signs of toxicity were monitored 

throughout the study. Water consumption was measured during the first three weeks of 

the study. Standard haematology and clinical chemistry investigations were conducted 

on blood samples taken at weeks 4/5, 8 and 13. Ophthalmoscopy examinations were 

conducted at the start and end of the study and urinalysis was conducted during week 

5. At termination, a necropsy was conducted in which macroscopic abnormalities and 

selected organ weights were recorded. A standard range of tissues, including 

reproductive organs, were examined microscopically. 

There were no treatment-related deaths, clinical signs of toxicity or effects on 

bodyweight or water consumption. Food consumption was slightly increased in both 
214 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

males and females receiving 3,500 mg/kg/day. Haematological, clinical chemistry, 

urinalysis and ophthalmoscopy findings were similar for all groups. 

At necropsy, the only changes considered to be treatment-related were on liver weight, 

among females only. Absolute liver weight was significantly increased at all treatment 

levels. Bodyweight-related liver weight was also increased at all treatment levels, 

although the differences were statistically significant only at 900 and 3,750 mg/kg/day. 

The increases were of similar magnitude (~15 per cent greater than controls) at all 

treatment levels. Microscopic examination revealed treatment related inflammatory 

changes in the liver of a number of females in all LCCP-exposed groups. The 

microscopic changes were granulomatous inflammation and/or necrosis and increased 

intensity of Oil Red O staining (an indicator of intracellular lipid accumulation). The 

incidence and severity of the liver lesions did not follow an obvious dose-dependant 

pattern. The microscopic examination also revealed the presence of nephrosis (graded 

as either trace of mild) in four males at 3,750 mg/kg/day; nephrosis was not seen in the 

controls or other LCCP treated groups. 

A NOAEL could not be identified in this study. A LOAEL of 100 mg/kg/day is 

established based on the presence of liver changes in females at all treatment levels. 

C23av, 43% chlorination 

A series of rat studies commenced with a 16-day preliminary study. The LCCP product 

was administered by gavage to groups of five Fischer rats of each gender at dose 

levels of 0 (corn oil vehicle control), 235, 469, 938, 1,875 or 3,750 mg/kg/day for five 

days/week (NTP, 1986). Bodyweights and the presence of clinical signs of toxicity were 

monitored throughout the study. At termination, a necropsy was conducted in which 

any macroscopic abnormalities were recorded. No treatment related effects were 

observed in this study. 

In a 13-week study designed as a rangefinder for a carcinogenicity study, the LCCP 

product was administered by gavage to groups of 10 Fischer rats of each gender at 

dose levels of 0 (corn oil vehicle control) 235, 469, 938, 1,875 or 3,750 mg/kg/day for 

five days per week (NTP, 1986). Bodyweights and the presence of clinical signs of 

toxicity were monitored throughout the study. At termination, a necropsy was 

conducted in which any macroscopic abnormalities were recorded. A standard range of 

tissues, including reproductive organs, were examined microscopically. 

There were no treatment-related deaths, clinical signs of toxicity, effects on bodyweight 

or macroscopic abnormalities observed at necropsy. Microscopic abnormalities were 

reported in the liver in females in all LCCP exposed groups. There was a dose related 

increase in the incidence of granulomatous inflammation in the liver; the incidence 

ranged from 1/10 at 235 mg/kg/day to 9/10 at 3,750 mg/kg/day, compared with 0/10 in 

the control group. A LOAEL of 235 mg/kg/day is established for a 13-week exposure 

period, based on the presence of liver changes at all treatment levels. 

In a carcinogenicity study (cancer findings are presented in Section 4.4.2.8), the LCCP 

product was administered by gavage to Fischer rats, for five days each week, for up to 

either six months, 12 months or two years (NTP, 1986). The dose levels were 0 (corn 

oil vehicle control), 1,875 or 3,750 mg/kg/day for males and 0, 100, 300 or 

900 mg/kg/day for females. The group sizes were 20 rats for each gender for the six 

and 12 month exposure periods and 50 of each gender for the two year exposure 

period. Bodyweights and the presence of clinical signs of toxicity were monitored 

throughout the study. At termination, a necropsy was conducted in which any 

macroscopic abnormalities were recorded. A standard range of tissues, including 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 215

reproductive organs, were examined microscopically. For the six and 12 month 

exposure groups, blood was collected just prior to necropsy for standard 

haematological and clinical chemistry investigations; additionally the weights of major 

organs were measured. 

In the groups exposed for six or 12 months there were no treatment-related deaths or 

effects on bodyweight. The activities of several serum enzymes that serve as markers 

for liver injury were significantly increased in males (at 1,875 and 3,750 mg/kg/day) and 

females (at 300 and 900 mg/kg/day) at both time intervals. Bodyweight-related liver 

weights were increased in males at 3,750 mg/kg/day at 12 months and in females at 

300 mg/kg/day at 12 months and at 900 mg/kg/day at six and 12 months. 

Microscopically, there was a dose- and time-related increase in the incidence and 

severity of granulomatous and lymphohistiocytic hepatitis throughout all the LCCP 

exposed groups. 

In the two year study survival was not affected by LCCP treatment. In males there were 

no effects on bodyweights, but for females at 300 and 900 mg/kg/day bodyweights 

were about five per cent lower than controls from week 70. The only clinical signs that 

could be related to treatment were brown staining around the mouth of some males 

from week 44 and a high incidence of distended abdomen for females towards the end 

of the study. Microscopically, treatment-related non-neoplastic lesions were reported in 

all LCCP treated groups in the liver (granulomatous focal inflammation, hyperplasia, 

pigmentation), pancreatic lymph node (granulomatous inflammation, lymphoid 

hyperplasia) for both males and females, and in the eye (retinopathy, cataracts) among 

males. Generally, the incidence of microscopic lesions was similar in all LCCP groups. 

A LOAEL of 100 mg/kg/day is established for non-neoplastic changes, based on the 

presence of microscopic changes in the liver and lymph nodes at the lowest dose level. 

The series of mouse studies commenced with a 16-day preliminary study. The LCCP 

product was administered by gavage to groups of five B6C3F1 mice of each gender at 

dose levels of 0 (corn oil vehicle control), 469, 938, 1,875, 3,750 or 7,500 mg/kg/day for 

five days per week (NTP, 1986). Bodyweights and the presence of clinical signs of 

toxicity were monitored throughout the study. At termination, a necropsy was 

conducted in which macroscopic abnormalities were recorded. No treatment-related 

effects were observed in this study. 

In a 13-week study designed as a rangefinder for a carcinogenicity study, the LCCP 

product was administered by gavage to groups of 10 B6C3F1 mice of each gender at 

dose levels of 0 (corn oil vehicle control) 469, 938, 1,875, 3,750 or 7,500 mg/kg/day for 

five days per week (NTP, 1986). Bodyweights and the presence of clinical signs of 

toxicity were monitored throughout the study. At termination, a necropsy was 

conducted in which any macroscopic abnormalities were recorded. A range of tissues 

were examined microscopically. No treatment related effects were observed in this 

study. 

In a carcinogenicity study (cancer findings are presented in Section 4.4.2.8) the LCCP 

product was administered by gavage to groups of 50 B6C3F1 mice of each gender at 

dose levels of 0 (corn oil vehicle control) 2,500 or 5,000 mg/kg/day, five days per week, 

for two years (NTP, 1986). Bodyweights and the presence of clinical signs of toxicity 

were monitored throughout the study. At termination, a necropsy was conducted in 

which macroscopic abnormalities were recorded. A standard range of tissues, including 

reproductive organs, were examined microscopically. 

Survival and bodyweights were not affected by LCCP treatment. There were no 

treatment-related clinical signs. There were no non-neoplastic microscopic findings that 
216 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

could be clearly attributed to LCCP treatment. Thus, a NOAEL of 5,000 mg/kg/day is 

established in the mouse for a two-year exposure period. 

C20–26, 70% chlorination 

In a five-day study designed as a rangefinder for a cytogenetics study, the LCCP 

product was administered by gavage to groups of eight Fischer 344 rats of each 

gender at dose levels of 0 (1% carboxymethylcellulose vehicle control), 1,000, 2,500 or 

5,000 g/kg/day (IRDC, 1982). Bodyweights and food consumption were measured and 

clinical signs of toxicity were monitored. At termination a necropsy was conducted in 

which macroscopic abnormalities were recorded. There were no treatment-related 

effects and therefore a NOAEL of 5,000 mg/kg/day for a five-day exposure period was 

identified. 

In a preliminary 14-day study, the LCCP product was administered via the diet to 

groups of five Fischer rats of each gender at concentrations resulting in dose levels of 

about 0, 17, 55, 179, 565 and 1,715 mg/kg/day (IRDC, 1981b). Bodyweights, food 

consumption and the presence of clinical signs of toxicity were monitored throughout 

the study. At termination a necropsy was conducted in which macroscopic 

abnormalities and selected organ weights were recorded. Liver microsomal Lowry 

protein and cytochrome P-450 levels and aminopyridine demethylase activity were 

determined. Liver, kidneys and spleen were subject to microscopic examination. There 

were no intergroup differences that were considered to be treatment-related and 

therefore a NOAEL of 1,715 mg/kg/day for a 14-day exposure period was identified. 

In a standard 13-week repeated exposure toxicity study the LCCP product was 

administered via the diet to groups of 15 Fischer rats of each gender at concentrations 

resulting in dose levels of 0, 100, 900 or 3,750 mg/kg/day (IUCLID, 2003). 

Bodyweights, food consumption and the presence of clinical signs of toxicity were 

monitored throughout the study. Water consumption was measured during the first 

three weeks of the study. Standard haematology and clinical chemistry investigations 

were conducted on blood samples taken at weeks 4/5, 8 and 13. Ophthalmoscopy 

examinations were conducted at the start and end of the study and urinalysis was 

conducted during week 5. At termination, a necropsy was conducted in which 

macroscopic abnormalities and selected organ weights were recorded. A standard 

range of tissues, including reproductive organs, from the control and the 

3,750 mg/kg/day group were examined microscopically. 

There were no treatment-related deaths, clinical signs of toxicity or effects on water 

consumption. Bodyweight gain was significantly reduced at 3,750 mg/kg/day, with 

weights at 13 weeks being seven per cent or three per cent less than controls for males 

and females, respectively. Food consumption was significantly increased in both males 

(by ~11 per cent) and females (by ~7 per cent) at 3,750 mg/kg/day. There was a 

significant reduction in urine volume, with an associated increase in urine specific 

gravity, in males at 3,750 mg/kg/day. Haematological, clinical chemistry (except for 

aspartate (AST) and alanine (ALT) aminotransferase, see below) and ophthalmoscopy 

findings were similar for all groups. 

Effects on the liver were reported at 3,750 mg/kg/day. There was a statistically 

significant increase in bodyweight-related liver weight in males and females; absolute 

liver weight was also increased in females at this dose level. Microscopic findings in the 

liver of rats from the 3,750 mg/kg/day were increased cytoplasmic vacuolation, 

hepatocellular hypertrophy and positive Oil Red O staining. The microscopic changes 

were more prominent among females. Additionally, AST (females) and ALT (males and 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 217

females) were slightly, though statistically significant, increased at this dose level, 

confirming an effect on the liver. 

Overall, a NOAEL of 900 mg/kg/day was identified, based on the observation of effects 

on bodyweight gain, food consumption and the liver at the higher dose level of 

3,750 mg/kg/day. 

Dermal

No data are available. 

Studies in humans 

No data are available. 

Summary of repeated dose toxicity 

No information is available on the effects of repeated exposure in humans. In animals 

there are no data relating to the inhalation or dermal routes. Repeated dose toxicity 

data in animals for the oral route are available for two LCCP products with 43% 

chlorination (by gavage administration), one with carbon chain length C22–26 and one 

with C23av, and for a 70% chlorinated LCCP product (by dietary administration) with 

carbon chain length C20–26. A specific comparison of the toxicities of the low and high 

chlorination states is not possible because of differences in methods of administration. 

The liver was identified as the main target organ in the rat for both the 43% and 70% 

chlorination products. For the 43% chlorination products, inflammatory and necrotic 

histopathological changes, intracellular lipid accumulation and hyperplasia were seen 

in rats at dose levels of 100 mg/kg/day and above. As 100 mg/kg/day was the lowest 

dose level investigated, this is identified as a LOAEL for liver toxicity for 43% 

chlorination LCCP products. For the 70% chlorination product, effects in the liver (i.e. 

hyperplasia, intracellular lipid accumulation and increased cytoplasmic vacuolation) 

occurred only at a very high exposure level of 3,750 mg/kg/day; the NOAEL for liver 

toxicity was 900 mg/kg/day. 

Other target organs for the 43% chlorinated LCCP products were also identified in the 

rat. Kidney toxicity, manifested as histopathological-detected mild nephrosis was seen 

in several male rats only dosed with the 43% chlorination product at 3,750 mg/kg/day 

for 13 weeks. Additionally, changes were observed in the pancreatic lymph node (i.e. 

granulomatous inflammation, lymphoid hyperplasia) at 100 mg/kg/day and above, and 

in the eye (retinopathy, cataracts) at 1,875 mg/kg/day and above. 

Overall, a repeated dose toxicity LOAEL of 100 mg/kg/day for 43% chlorinated LCCPs 

and a NOAEL 900 mg/kg/day for 70% chlorinated LCCPs were identified. The 

uncertainties regarding the influence of the chlorination state on the toxicity of the 

LCCPs means that the more conservative LOAEL of 100 mg/kg/day is taken forward to 

the risk assessment for all C20–30 LCCPs, irrespective of their chlorination state. For the 

C18–20 LCCPs a NOAEL of 23 mg/kg/day (300 mg/kg food) for repeated dose toxicity 

will be assigned, based on the data for MCCPs. 

4.4.2.7 Mutagenicity 

Because testing of the LCCPs is limited, data for SCCPs and MCCPs are also covered 

in the summary of this section. 
218 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

In vitro studies 

Bacterial studies

Ames testing, using valid methods, has been conducted on two LCCP products: C22–26, 

43% chlorination and C23av, 43% chlorination (IUCLID, 2003). 

The C22–26, 43% chlorination product was tested using Salmonella strains TA98, 

TA100, TA1535, TA1537. The C23av, 43% chlorination product test was conducted in 

compliance with GLP, using Salmonella strains TA98, TA100, TA1535, TA1538. The 

test result for both products was negative. 

Several other bacterial tests are reported in the IUCLID (2003), but these did not use 

standard methodology and are therefore considered invalid. 

Mammalian cell studies

A C23, 43% chlorination product has been investigated in a chromosome aberration and 

sister chromatid exchange test conducted in Chinese hamster ovary cells (Anderson et 

al., 1990). The design of the studies was comparable to the OECD test guidelines 473 

and 479. A positive result was obtained in the absence of S9 in the chromosome 

aberration test. Positive results were reported both in the presence and absence of S9 

in the sister chromatid exchange test. 

In vivo studies 

In vivo chromosome aberration tests have been conducted on two LCCP products: 

C22-26, 43% chlorination and C20–26, 70% chlorination (IUCLID, 2003). Both tests were 

conducted in compliance with GLP and were considered to be valid. 

The test result for both products was negative. 

Studies in humans 

No data are available. 

Summary of mutagenicity 

Limited data are available on the mutagenicity of the LCCPs. C23av, 43% chlorinated 

and C22–26, 42% chlorinated LCCP products are not mutagenic in bacteria, but an 

LCCP product with a higher chlorination state has not been tested in bacteria. No in 

vitro or in vivo mammalian cell gene mutation tests are available for the LCCPs. A C23, 

43% chlorination product tested positive in an in vitro chromosome aberration and 

sister chromatid exchange test. However, negative results were obtained in in vivo

chromosome aberration tests on a C22–26, 43% chlorination and a C20–26, 70% 

chlorination LCCP product, suggesting that genotoxic activity would not be expressed 

in vivo. 

The mutagenicity data available for the other chlorinated paraffin categories are also 

limited. Several short-chain chlorinated paraffins (SCCPs) have tested negative in 

bacterial tests and one SCCP has been tested in an in vitro mammalian gene cell 

mutation test which was negative. In vivo, an SCCP product tested negative in a 

chromosome aberration test and in a dominant lethal test. The MCCPs that have been 

tested in bacteria are also not mutagenic, but no members of this category have been 

tested in in vitro or in vivo mammalian cell gene mutation tests, as is the case for the 

LCCPs. Two similar MCCP products have tested negative in in vivo micronucleus tests 

and another MCCP product was negative in an in vivo chromosome aberration test. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 219

Overall, the chlorinated paraffins have not been comprehensively tested for 

mutagenicity. However, given the lack of evidence of mutagenicity for the chlorinated 

paraffins generally, it can be predicted that the LCCPs will not be mutagenic. 

4.4.2.8 Carcinogenicity 

Studies in animals 

The carcinogenicity of a C23av, 43% chlorination LCCP product has been investigated in 

rats and mice in standard studies (NTP, 1986). Non-neoplastic findings reported in 

these studies are presented in Section 4.4.2.6. 

In the rat study, groups of 50 Fischer rats of each gender were administered the LCCP 

product by gavage, five day per week, for up to two years. The dose levels were 0 

(corn oil vehicle control), 1,875 or 3,750 mg/kg/day for males and 0, 100, 300 or 900 

mg/kg/day for females. The incidence of tumours in males was not affected by LCCP 

treatment. However, a dose-related increased incidence in adrenal gland medullary 

phaeochromocytoma was seen in females in all the LCCP treated groups (1/50, 4/50, 

6/50 and 7/50 in the control, 100, 300 or 900 mg/kg/day, respectively). All the tumours, 

except for one at 100 mg/kg/day, were benign. The historical incidence of this type of 

tumour in corn-oil vehicle control female Fischer rats is 5–6 per cent. The NTP report 

concludes that there was no evidence of carcinogenicity in male rats and equivocal 

evidence of carcinogenicity in female rats.

In the mouse study, groups of 50 B6C3F1 mice of each gender were administered the 

LCCP product by gavage at dose levels of 0 (corn oil vehicle), 2,500 or 5,000 

mg/kg/day, five days/week, for two years. The number of female deaths after week 65 

was unusually high, probably the result of a Klebsiella oxytoca infection. This may have 

reduced the power of the study to detect a carcinogenic effect. In males there was a 

dose-related increased incidence of malignant lymphomas (6/50 (12 per cent), 12/50 

(24 per cent) and 16/50 (32 per cent) in the control, 2,500 and 5,000 mg/kg/day groups, 

respectively). The historical incidence of this type of tumour in corn-oil vehicle control 

male B6C3F1 mice is 22 per cent, similar to that observed at the lower dose level of 

2,500 mg/kg/day, so only the increased incidence at 5,000 mg/kg/day can be 

considered to be treatment-related. 

In females there was a marginal increase in the incidence of hepatocellular carcinomas 

(1/50, 1/49 and 6/50 in the control, 2,500 and 5,000 mg/kg/day groups, respectively) 

and of adenomas and carcinomas combined (4/50, 3/49 and 10/50). The historical 

incidence of hepatocellular carcinomas in corn-oil vehicle control females was about 

half that observed in the high dose group. The NTP report concludes that there was 

clear evidence of carcinogenicity in male mice and equivocal evidence of 

carcinogenicity in female mice. 

Studies in humans 

No data are available. 

Summary of carcinogenicity 

The carcinogenicity of a C23av, 43% chlorination LCCP product has been investigated in 

rats and mice in standard studies. An increased incidence of malignant lymphoma in 

male mice was reported at the highest dose tested, 5,000 mg/kg/day, providing 

evidence that LCCPs are carcinogenic. Marginal increases in the incidence of adrenal 

medullary phaeochromocytomas observed in female rats from 100 mg/kg/day and in 
220 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

hepatocellular carcinomas in female mice at 5,000 mg/kg/day were not considered to 

represent convincing evidence of carcinogenicity. 

Overall, there is evidence that LCCPs are carcinogenic, but only at very high exposure 

levels. Because the chlorinated paraffins do not appear to have mutagenic potential it 

is likely that this carcinogenic activity is the result of a non-genotoxic mode of action 

and it can therefore be assumed that the carcinogenicity will have a threshold exposure 

level. Accordingly, a NOAEL of 2,500 mg/kg/day, at which the incidence of malignant 

lymphomas was similar to historical controls, can be identified. 

4.4.2.9 Toxicity for reproduction 

Effects on fertility 

Studies in animals

There are no studies in which effects on fertility and reproductive performance have 

been specifically investigated. No changes in the weight or macroscopic and 

microscopic appearance of the reproductive organs were reported in the repeated dose 

toxicity studies, available for C22–26, 43% chlorination, C23av, 43% chlorination and C20–

26, 70% chlorination LCCP products (see Section 4.4.2.6). 

Limited testing that has been conducted into the effects of LCCPS on fertility and 

reproductive performance, therefore data for MCCPs is taken into account in the 

summary of this section. 

 

Studies in humans

No data are available. 

Developmental toxicity 

Studies in animals

Valid studies are available in rat and rabbits for a C22–26, 43% chlorination and a C22–26, 

70% chlorination LCCP product. The studies were conducted in compliance with GLP. 

C22–26, 43% chlorination 

In a standard developmental toxicity study, the LCCP product was administered to 

groups of 25 timed mated female Sprague-Dawley rats at dose levels of 0 (corn oil 

vehicle control), 500, 2,000 or 5,000 mg/kg/day, from days 6 to 19 of gestation (IRDC 

1983a). Clinical signs and maternal bodyweights were monitored throughout the study. 

The mothers were killed on day 20 of gestation and a necropsy was performed. 

Maternal organs were examined for gross abnormalities. Numbers of corpora lutea and 

implantation sites were counted and foetal weights were recorded. All foetuses were 

examined externally. Approximately half of the foetuses from each litter were 

processed for skeletal examination and the remainder were processed for soft tissue 

examination. 

In the mothers there were no treatment-related clinical signs, effects on bodyweight 

gain or maternal necropsy findings. There was one premature maternal death, at 

5,000 mg/kg/day on day 18 of gestation, but a relationship with treatment could not be 

established. Pre- and post-implantation loss was not affected by treatment. Foetal 

weights and the incidence of external, visceral and skeletal variations and 

abnormalities in the foetuses were similar to the controls for all LCCP treated groups. A 

NOAEL of 5,000 mg/kg/day was identified for maternal and developmental toxicity. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 221

In a standard developmental toxicity study, the LCCP product was administered to 

groups of 16 timed mated female Dutch belted rabbits at dose levels of 0 (corn oil 

vehicle control), 500, 2,000 or 5,000 mg/kg/day, from days 6 to 27 of gestation 

(IUCLID, 2003). Clinical signs and maternal bodyweights were monitored throughout 

the study. The mothers were killed on day 28 of gestation and a necropsy was 

performed. Maternal organs were examined for gross abnormalities. Numbers of 

corpora lutea and implantation sites were counted and foetal weights were recorded. 

All foetuses were examined for external, visceral and skeletal variations and 

abnormalities. 

Among mothers from all LCCP-treated groups there was an increased incidence of soft 

faeces and matted hair in the anogenital region. There were no treatment-related 

effects on maternal bodyweight gain or necropsy findings. There was one premature 

maternal death, at 5,000 mg/kg/day, due to a dosing error. Three mothers aborted 

during the study, one at 2,000 mg/kg/day group and two at 5,000 mg/kg/day. However, 

abortions are relatively common in rabbit developmental toxicity studies, so these 

abortions could not be attributed to LCCP treatment. Post-implantation loss was slightly 

increased at 5,000 mg/kg/day, with a consequent slight reduction in the numbers of 

viable foetuses. Foetal weights and the incidence of foetal external, visceral and 

skeletal variations and abnormalities were similar to the controls for all the LCCP 

treated groups. The comparison of the incidence of variations and abnormalities with 

controls was of limited value owing to the reduced numbers of live foetuses at 5,000 

mg/kg/day, As there were clinical signs that were possibly related to treatment in all 

LCCP-treated groups, a NOAEL for maternal toxicity could not be identified and 

therefore a LOAEL of 500 mg/kg/day is declared. The NOAEL for developmental 

toxicity is 2,000 mg/kg/day, based on the observation of increased post-implantation 

loss at 5,000 mg/kg/day. It is considered likely that this post-implantation loss was a 

secondary non-specific consequence of maternal toxicity. 

C22–26, 70% chlorination 

In a standard developmental toxicity study, the LCCP product was administered to 

groups of 25 timed mated female Sprague-Dawley rats at dose levels of 0 (aqueous 

carboxymethyl cellulose vehicle control), 500, 2,000 or 5,000 mg/kg/day, from days 6 to 

19 of gestation (IRDC 1984b). The design of the study was identical to the rat 

developmental toxicity study for the C22–26, 43% chlorination LCCP product, described 

above (IRDC 1983a). There were no treatment-related effects in either the mothers or 

offspring, and therefore a NOAEL of 5,000 mg/kg/day was identified for maternal and 

developmental toxicity. 

In a standard developmental toxicity study, the LCCP product was administered to 

groups of 16 timed mated female Dutch belted rabbits at dose levels of 0 (aqueous 

carboxymethyl cellulose vehicle control), 500, 2,000 or 5,000 mg/kg/day, from days 6 to 

27 of gestation (IRDC 1983b). The dose levels were chosen on the basis of range 

finding studies in which evidence of maternal toxicity and a high incidence of abortions 

were reported at dose levels of 2,000 and 5,000 mg/kg/day. The design of the study 

was identical to the rabbit developmental toxicity study for the C22–26, 43% chlorination 

LCCP product, described above (IUCLID, 2003). 

There were no treatment-related maternal clinical signs of effects on bodyweight gain. 

Two mothers at 1,000 mg/kg/day died due to dosing errors and one mother at 

500 mg/kg/day died of an undetermined cause. At the maternal necropsy a slight 

increase in the incidence of congested lungs was reported in the LCCP-treated groups, 

but there was no dose-response relationship so this was considered likely to be a 

chance finding. Pre- and post-implantation loss, foetal weights and the incidence of 
222 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

foetal variations and abnormalities were not affected by treatment. Overall, a NOAEL of 

1,000 mg/kg/day for maternal and developmental toxicity was identified. 

Studies in humans 

No data are available. 

Summary of toxicity for reproduction 

There are no studies in which effects on fertility and reproductive performance have 

been specifically investigated. No changes in the weight or macroscopic and 

microscopic appearance of the reproductive organs were reported in the repeated dose 

toxicity studies, available for C22–26, 43% chlorination, C23av, 43% chlorination and C20–

26, 70% chlorination LCCP products. Taking account of this information from the 

repeated dose toxicity studies and the fact that no effects on fertility were observed in 

two MCCP reproductive toxicity studies, it is predicted that the LCCPs do not have the 

capacity to affect fertility. In one MCCP study using dietary administration, maternal 

deaths during parturition were reported at 538 mg/kg/day as a consequence of 

haemorrhaging due to low vitamin K levels. A NOAEL of 100 mg/kg/day was identified 

for this effect. In the absence of studies on the effects of LCCPs during the time of 

parturition and on vitamin K levels, a conservative assumption is made that LCCPs will 

have a similar effect. 

In relation to developmental effects, no evidence of a specific effect on development 

was observed in standard rat and rabbit studies on a C22–26, 43% chlorination and a 

C22–26, 70% chlorination LCCP product. However, maternal dietary exposure to MCCPs 

has been shown to cause haemorrhaging and death in neonates, thought to be mainly 

due to reduced vitamin K levels in the milk. A NOAEL of 47 mg/kg/day as a maternal 

dose was identified for this effect. In the absence of studies on the effects of LCCPs on 

neonates and on vitamin K levels, a conservative assumption is made that LCCPs will 

have a similar effect. 

4.4.2.10 Summary of mammalian toxicity 

No human data are available for the LCCPs. 

No toxicokinetic data are available for the LCCP products. Based on information 

available for MCCPs, it is predicted that absorption via the oral and inhalation routes 

will be significant (about 50 per cent of the administered dose). Absorption via the 

dermal route is predicted to be lower (about one per cent of administered dose). It can 

be predicted that LCCPs could be preferentially distributed to fatty tissues in the body, 

and that excretion via breast milk could occur. 

Acute oral toxicity data in animals are available for a number of LCCP products with 

carbon chain lengths ranging from C20 to C30. These data show that the LCCP products 

are of low acute toxicity. Based on the low oral toxicity and absence of significant 

irritant hazard (see Section 4.4.2.3) it can be predicted that the LCCP products will also 

be of low acute toxicity by the inhalation and dermal routes. 

Skin and eye irritation has been investigated in animal studies for a number of LCCP 

products with carbon chain lengths ranging from C20 to C30. These studies show that 

LCCPs have the potential to cause slight irritation, albeit below the severity threshold 

for classification according to the EU system. Single exposure to MCCPs also causes 

slight irritation in standard tests, but somewhat more pronounced irritation has been 

reported following repeated exposure, presumably due to defatting properties. In the 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 223

absence of studies on repeated application of LCCPs to skin, a conservative 

assumption is made that LCCPs will have a similar effect. There are no specific data on 

respiratory tract irritation, but on the basis of the low skin and eye irritation potential it is 

anticipated that LCCP products are unlikely to cause such an effect. 

Both positive and negative results have been obtained in standard guinea pig skin 

sensitisation tests. It is possible that the LCCPs may have the potential to cause skin 

sensitisation reactions, although firm conclusions cannot be drawn from the available 

data. 

On the basis of a positive result in a standard guinea pig maximisation test using an 

LCCP C18–27 40% chlorination product, it is assumed that LCCPs have the potential to 

cause skin sensitisation reactions. 

No information is available on the effects of repeated exposure in humans. In animals 

there are no data relating to the inhalation or dermal routes. Repeated dose toxicity 

data in animals for the oral route are available for two LCCP products with 43% 

chlorination (by gavage administration), one with carbon chain length C22–26 and one 

with C23av, and for a 70% chlorinated LCCP product (by dietary administration) with 

carbon chain length C20–26. A specific comparison of the toxicities of the low and high 

chlorination states is not possible because of differences in the methods of 

administration and the absence of investigation into the influence of chlorination on the 

toxicokinetic profile. 

The liver was identified as the main target organ in the rat for both the 43% and 70% 

chlorination products. For the 43% chlorination products, inflammatory and necrotic 

histopathological changes, intracellular lipid accumulation and hyperplasia were seen 

in rats at dose levels of 100 mg/kg/day and above. As 100 mg/kg/day was the lowest 

dose level investigated, this is identified as a LOAEL for liver toxicity for 43% 

chlorination LCCP products. For the 70% chlorination product, effects in the liver 

(hyperplasia, intracellular lipid accumulation and increased cytoplasmic vacuolation) 

occurred only at a very high exposure level of 3,750 mg/kg/day; the NOAEL for liver 

toxicity was 900 mg/kg/day. 

Other target organs for the 43% chlorinated LCCP products were also identified in the 

rat. Kidney toxicity, manifested as histopathological detected mild nephrosis was seen 

in several male rats only dosed with the 43% chlorination product at 3,750 mg/kg/day 

for 13 weeks. Additionally, changes were observed in the pancreatic lymph node 

(granulomatous inflammation, lymphoid hyperplasia) at 100 mg/kg/day and above, and 

in the eye (retinopathy, cataracts) at 1,875 mg/kg/day and above. 

Overall, a repeated dose toxicity LOAEL of 100 mg/kg/day for 43% chlorinated LCCPs 

and a NOAEL 900 mg/kg/day for 70% chlorinated LCCPs were identified. It is 

recommended that the more conservative LOAEL of 100 mg/kg/day is taken forward to 

the risk assessment for the C20–30 LCCPs, regardless of the chlorination state, owing to 

the uncertainties regarding the influence of the chlorination state on the toxicity of 

LCCPs. For the C18–20 LCCPs a NOAEL of 23 mg/kg/day (equivalent to 300 mg/kg 

food) for repeat dose toxicity is assigned, based on the data for MCCPs. 

Limited data are available on the mutagenicity of the LCCPs. A C23av, 43% chlorinated 

and a C22–26, 42% chlorinated LCCP product were not mutagenic in bacteria, but an 

LCCP product with a higher chlorination state has not been tested in bacteria. No in 

vitro or in vivo mammalian cell gene mutation tests are available for the LCCPs. A C23, 

43% chlorination product tested positive in an in vitro chromosome aberration and 

sister chromatid exchange test. However, negative results were obtained in in vivo
224 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

chromosome aberration tests on a C22–26, 43% chlorination and a C22–26, 70% 

chlorination LCCP product, suggesting that genotoxic activity would not be expressed 

in vivo. The mutagenicity data available for other categories of chlorinated paraffins are 

also limited. Several SCCPs have tested negative in bacterial tests and one SCCP has 

been tested in an in vitro mammalian gene cell mutation test which was negative. In 

vivo, an SCCP product tested negative in a chromosome aberration test and in a 

dominant lethal test. The MCCPs that have been tested in bacteria are also not 

mutagenic, but no members of this category of chlorinated paraffin have been tested in 

in vitro or in vivo mammalian cell gene mutation tests, as is the case for the LCCPs. 

Two similar MCCP products have tested negative in in vivo micronucleus tests and 

another MCCP product was negative in an in vivo chromosome aberration test. Overall, 

the chlorinated paraffins have not been comprehensively tested for mutagenicity. 

However, given the lack of evidence of mutagenicity for the chlorinated paraffins 

generally, it can be predicted that the LCCPs will not be mutagenic. 

The carcinogenicity of a C23av, 43% chlorination LCCP product has been investigated in 

rats and mice in standard studies. An increased incidence of malignant lymphoma in 

male mice reported at the highest dose tested (5,000 mg/kg/day) provides evidence 

that LCCPs are carcinogenic. Marginal increases in the incidence of adrenal medullary 

phaeochromocytomas observed in female rats from 100 mg/kg/day and in 

hepatocellular carcinomas in female mice at 5,000 mg/kg/day were not considered to 

be convincing evidence of carcinogenicity. Overall, there is evidence that LCCPs are 

carcinogenic, but only at very high exposure levels. The chlorinated paraffins do not 

appear to have mutagenic potential, so it is likely that this carcinogenic activity is the 

result of a non-genotoxic mode of action. It can therefore be assumed that the 

carcinogenicity will have a threshold exposure level. Accordingly, a NOAEL of 2,500 

mg/kg/day, at which the incidence of malignant lymphomas was similar to historical 

controls, can be identified. It is assumed that this NOAEL is applicable to all LCCPs. 

There are no studies in which effects on fertility and reproductive performance have 

been specifically investigated. No changes in the weight or macroscopic and 

microscopic appearance of the reproductive organs were reported in the repeated dose 

toxicity studies, available for C22–26, 43% chlorination, C23av, 43% chlorination and C20–

26, 70% chlorination LCCP products. Taking account of this information from the 

repeated dose toxicity studies and the fact that no effects on fertility were observed in 

two MCCP reproductive toxicity studies, it is predicted that the LCCPs do not have the 

capacity to affect fertility. In one MCCP study using dietary administration, maternal 

deaths during parturition were reported at 538 mg/kg/day as a consequence of 

haemorrhaging due to low vitamin K levels. A NOAEL of 100 mg/kg/day was identified 

for this effect. In the absence of studies on the effects of LCCPs during the time of 

parturition and on vitamin K levels, a conservative assumption is made that LCCPs will 

have a similar effect. 

In relation to developmental effects, no evidence of a specific effect on development 

was observed in standard rat and rabbit studies on a C22–26, 43% chlorination and a 

C22–26, 70% chlorination LCCP product. However, maternal dietary exposure to MCCPs 

has been shown to cause haemorrhaging and death in neonates, thought to be mainly 

due to reduced vitamin K levels in the milk. A NOAEL of 47 mg/kg/day as a maternal 

dose was identified for this effect. In the absence of studies of the effects of LCCPs on 

neonates and on vitamin K levels, a conservative assumption is made that all the 

LCCPs will have a similar effect. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 225

4.4.3 PNEC for secondary poisoning 

Avian toxicity data are available for LCCPs. However, the mode of administration 

(direct injection into eggs) means that these data cannot be used to estimate a PNEC. 

There is a large database of repeated dose mammalian studies available for both a 

C>20, 43% wt. Cl product and a C>20, 70% wt. Cl product that is suitable for derivation of 

a PNEC. There appear to be few mammalian toxicity data available for C18–20 liquid 

products. The available data are summarised in the preceeding sections. 

The conclusion from this analysis is that a LOAEL of 100 mg/kg/day for C20–30 LCCPs 

and a NOAEL of 23 mg/kg/day (equivalent to 300 mg/kg food) for C18–20 LCCPs (based 

on read-across from MCCPs) should be used for the assessment of secondary 

poisoning, based on the most sensitive LOAEL or NOAELs identified for repeated dose 

effects (liver or kidney toxicity, respectively). 

For the secondary poisoning assessment it is suggested that the LOAEL of 

100 mg/kg/day for C20–30 LCCPs is divided by three to provide an estimate of the 

NOAEL (i.e. assumed NOAEL = 33.3 mg/kg/day). 

Using the conversion factors given in the TGD, a dose of 33.3 mg/kg bw/day is 

equivalent to a dietary exposure of 667 mg/kg food. A tentative PNECoral of 22.2 mg/kg 

food can be estimated using an assessment factor of 30 (chronic toxicity data are 

available). This PNECoral is considered in the assessment for both the C>20 liquid and 

C>20 solid products. 

It is not possible to derive a PNEC for the C18–20 liquid chlorinated paraffins. As a 

pragmatic approach, a conservative PNECoral(screening) of 5 mg/kg food will be used. This 

value is based on the PNECoral that has been derived for MCCPs18 but includes a 

further assessment factor of two to account for uncertainty resulting from the limited 

availability of toxicity data for the C18–20 liquid chlorinated paraffins. This approach 

assumes that the C18–20 liquid chlorinated paraffins have a similar toxicity profile to the 

medium-chain (C14-17) chlorinated paraffins (C17 and, to a lesser extent, C16 chlorinated 

paraffins are present at quite high levels in the C18–20 chlorinated paraffin products). It is 

known that the frequency and severity of toxicity of chlorinated paraffins generally 

decreases with increasing chain length of the chlorinated paraffin (BUA, 1992) and so 

this approach is probably conservative. 

In summary, the following PNECs will be used in the assessment of secondary 

poisoning. 

C18–20 liquid chlorinated paraffin PNECoral(screening) = 5 mg/kg food 

 C>20 liquid chlorinated paraffin PNECoral = 22 mg/kg food 

 C>20 solid chlorinated paraffin PNECoral = 22 mg/kg food 

 

18 The PNECoral for MCCPs in the published risk assessment is currently 0.17 mg/kg 

(ECB, 2005a). However, since the assessment was published, further information has 

become available that shows that the actual NOAEL from mammalian studies for 

MCCPs is around 300 mg/kg food (23 mg/kg/day) for repeated dose exposure (90-day 

studies) and a revised PNECoral of 10 mg/kg food has been agreed using an 

assessment factor of 30 on these data (ECB, 2007a). The PNECoral of 10 mg/kg food is 

considered to be most reliable for MCCPs. 
226 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

4.5 Classification 

4.5.1 Current classification 

LCCPs are not listed in Annex 1 of the Directive 67/548/EEC. Since there is no agreed 

harmonised classification, suppliers have the responsibility to self-classify. 

4.5.2 Proposal 

4.5.2.1 Environment 

No reliable values for an L(E)C50 have been determined in acute tests with aquatic 

organisms. Effects have generally only been seen when the substances have been 

tested at concentrations well in excess of the water solubility and so may represent 

physical effects rather than direct toxicity of the substance itself. 

The one exception to this observation may be a C18–20, 52% wt. Cl substance when 

tested as a water-soluble fraction with Daphnia magna. Here a 48h-hour EC15 was 

determined as 0.4–0.5 mg/l. Effects were also seen at much lower concentrations with 

this substance in a long-term Daphnia reproduction study. It is not possible to 

determine from the study if the effects seen were due to the substance itself, to 

physical effects or to preferential solubility of a toxic impurity present in the test 

substance. 

LCCP substances are not readily biodegradable, they are poorly soluble and have log 

Kow values ≥7.5. There are several studies investigating the accumulation of these 

substances in aquatic organisms, but it is not possible to derive reliable BCF values 

from these experiments. Predicted BCF data indicate that some types of LCCPs may 

have the potential to be taken up by and accumulate in fish. Based on this information, 

a classification of R53 could be proposed for LCCPs. 

The C18–20 products are also likely to contain a significant amount of other chlorinated 

paraffin impurities (typically <1 per cent C16 and 17 per cent C17) which are also 

constituents of MCCP products. The proposal for classifying the MCCPs as dangerous 

for the environment (N; R50/53) was agreed at the Environmental Classification and 

Labelling Expert Meeting in September 2004. This decision was based on the acute 

toxicity seen with Daphnia magna (48-hour EC50 = 0.0059 mg/l), a high fish 

bioconcentration factor of 1,087 and the lack of degradation expected in standard 

ready biodegradation tests. This may also have some impact on the classification of 

the C18–20 chlorinated paraffins in particular. 

4.5.2.2 Human health 

The classification for human health has not been considered in this hazard 

assessment. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 227

5. Risk characterisation 

PECs and PNECs have been derived for three subgroups of LCCPs: 

• the C18–20 liquid products; 

• the C>20 liquid products; 

• the C>20 solid products. 

This approach allows differences in environmental fate, behaviour and effects between 

the three groups to be taken into account in the assessment. However, when it comes 

to risk characterisation, consideration must be given to whether a local site could be 

using more than one type of LCCP. PEC/PNEC ratios have been derived for each of 

the three subgroups, as well as for the total LCCPs that may be used at a site, to take 

this possibility into account. 

Similarly, at a regional level, exposure to total LCCPs will occur. The approach outlined 

above also has the advantage of making it clearer from which type of LCCP any risk 

identified arises. 

The one exception to this general approach to the risk characterisation is for the use of 

LCCPs in leather fat liquors. Here, the local PEC is calculated based on the total 

release from a site being either C18–20 liquid or C>20 liquid. In this instance it is 

unrealistic to add these two PECs (and hence obtain PEC/PNEC ratios) for a site. If 

both types of LCCP are used in the leather processing, then the amount of each type 

would be lower than assumed in the calculation (i.e. the total LCCP release would be 

the same, but it would be split between the two types); the total PECs and hence total 

PEC/PNECs would be intermediate between these two extremes. 

The PNECs used in the risk characterisation for a given type of LCCP (i.e. C18–20 liquid, 

C>20 liquid and C>20 solid chlorinated paraffins) have, wherever possible, been derived 

from toxicity data obtained on that specific type of chlorinated paraffin. Where this was 

not possible, due to a lack of suitable experimental data, worst case “screening” 

PNECs have been derived, based on the available toxicity data for other types of 

chlorinated paraffins. The manner in which these screening values have been derived 

means that they are likely to be protective for, and will overestimate the actual risk 

from, the type of chlorinated paraffin under consideration. Therefore, although this 

approach can be used to show where the PEC/PNEC ratio is likely be less than 1, it 

cannot be used reliably to indicate a risk if the PEC/PNEC ratio is greater than 1. 

However, this approach is useful for identifying if there is a need to generate more 

toxicity data for the chlorinated paraffin in question.

5.1 Aquatic compartment 

5.1.1 Risk characterisation ratios for surface water 

A PNECwater of 2.9 μg/l for C18–20 liquid chlorinated paraffin and a tentative 

PNECwater(screening) of 5.5 μg/l for C>20 liquid and C>20 solid chlorinated paraffins have 

been derived. The resulting PEC/PNEC ratios for the various scenarios considered in 
228 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

this assessment are shown in Table 5.1 and are also displayed in the bar chart in 

Figure 5.1. 

Based on this analysis, the PEC/PNEC ratios are all <1 for all scenarios considered. It 

can therefore be concluded that the risk to aquatic organisms from the production and 

use of LCCPs is low. 

5.1.2 Risk characterisation ratios for waste water treatment plant 

(WWTP) micro-organisms 

A PNEC of 60 mg/l was derived for sewage treatment microorganisms. This 

concentration is well above those predicted to occur in waste water treatment plants 

and the resulting PEC/PNEC ratios are all <<1 for all scenarios considered. Therefore it 

can be concluded that the risk to waste water treatment plants from the production and 

use of LCCPs is low. 

5.1.3 Risk characterisation ratios for sediment 

There are no toxicity studies available on sediment-dwelling organisms. A PNECsed of 

5,710 mg/kg wet weight has been derived for the C18–20 liquid chlorinated paraffins; a 

PNECsed(screening) of 33,100 mg/kg wet weight and >1.2×106

 mg/kg wet weight have been 

derived for the C>20 liquid and C>20 solid chlorinated paraffins, respectively. The 

resulting PEC/PNEC ratios are shown in Table 5.2 and Figure 5.2. The PEC/PNEC 

ratios have been increased by a factor of 10, as suggested in the TGD, in order to take 

into account possible exposure by direct ingestion of sediment-bound substance. 

A PEC/PNEC ratio >1 is obtained for one scenario only – the intermittent release 

scenario19 for C18–20 liquids used in emulsifiable metal cutting/working fluids. 

 

19 According to an analysis by Entec (2004), intermittent disposal of such emulsified 

metal cutting/working fluids to drain is not necessarily prohibited under existing 

legislation in the UK, provided the site operator obtained relevant permission from the 

sewerage undertaker. However most companies are expected to separate the oil 

phase from the emulsified fluid prior to disposal to drain (with the oil being disposed of 

by processes such as incineration). In addition, Euro Chlor (2008) indicates that, as far 

as they are aware, there is no current use of LCCPs in emulsified fluids in the EU. 

Therefore this scenario is not relevant to the vast majority of sites using emulsifiable 

metal cutting/working fluids containing LCCPs. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 229

Table 5.1 Estimated PEC/PNEC ratios for surface water 

Scenario Step PEC/PNEC ratio 

 C18–20

liquid 

C>20

liquid 

C>20

solid 

Total 

Production Generic 6.9×10-4 5.8×10-4 4.2×10-7 1.3×10-3 

Compounding (O) 3.6×10-4 b b 3.6×10-4

Conversion (O) 3.6×10-4 b b 3.6×10-4

Use in PVC – 

plastisol 

coating Compounding/conversion 

(O) 

5.8×10-4 b b 5.8×10-4

Compounding (O) 5.3×10-4 b b 5.3×10-4

Compounding (PO) 2.3×10-3 b b 2.3×10-3

Compounding (C) 3.1×10-4 b b 3.1×10-4

Conversion (O) 4.6×10-4 b b 4.6×10-4

Conversion (PO) 4.9×10-4 b b 4.9×10-4

Conversion (C) 4.3×10-4 b b 4.3×10-4

Compounding/conversion 

(O) 

8.5×10-4 b b 8.5×10-4

Compounding/conversion 

(PO) 

2.6×10-3 b b 2.6×10-3 

Use in PVC – 

extrusion/other 

Compounding/conversion 

(C) 

6.1×10-4 b b 6.1×10-4

Use in rubber Compounding/conversion b 1.5×10-4 2.2×10-5 1.7×10-4 

Use in 

sealants 

Formulation and use <1 <1 b <1 

Formulation <1 <1 2.5×10-7 2.5×10-7 

Industrial application 6.6×10-4 1.8×10-4 4.8×10-6 8.4×10-4 

Use in paints 

Domestic application <1 <1 <1 <1

Formulation 1.4×10-4 8.8×10-5 b 2.3×10-4

Use in oil-based fluids 

(large site – 5% LCCP 

content)

b 5.9×10-4 b 5.9×10-4 

Use in oil-based fluids 

(large site – 10% LCCP 

content)

b 1.1×10-3 b 1.1×10-3

Use in oil-based fluids 

(small site – 5% LCCP 

content)

2.8×10-3 5.5×10-4 b 3.4×10-3 

Use in oil-based fluids 

(small site – 10% LCCP 

content)

5.4×10-3 1.0×10-4 b 5.5×10-3 

Use in emulsifiable fluids 3.6×10-4 1.3×10-4 b 4.9×10-4

Use in metal 

cutting/working 

fluids 

Use in emulsifiable fluids 

– intermittent release 

0.22a 0.038a b 0.26a 

Table 5.1 continued overleaf 
230 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 5.1 continued 

Scenario Step PEC/PNEC ratio 

 C18–20

liquid 

C>20

liquid 

C>20

solid 

Total 

Formulation 1.0×10-3 2.4×10-4 b 1.2×10-3 Use in leather 

fat liquors Use – complete 

processing of raw hides 

8.1×10-3 1.5×10-3 b NA 

Use in textile applications 0.038 b b 0.038 

Regional sources 1.1×10-

4

– 

1.3×10-4 

8.2×10-

5

– 

8.7×10-5 

1.5×10-

7

– 

1.6×10-7 

1.9×10-

4

– 

2.2×10-4 

Notes: a For the intermittent scenario an assessment factor can be applied to the acute 

EC50 to derive the PNEC. However no effects were seen in the acute tests and 

so it is not clear if risk actually exists from this scenario. 

 b = no major use of the substance in the application. 

 NA = not applicable – see text. 

 O = open systems; PO = partially open systems; C = closed systems (as 

defined in OECD, 2004b). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 231

0.000.200.400.600.801.00

Production

PVC - plastisol coating -

conversion

PVC - other -

compounding - O

PVC - other -

compounding - C

PVC - other - conversion

- PO

PVC - other -

compounding/conversion

PVC - other -

compounding/conversion

Paints - formulation

Metal working -

formulation

Metal working - use in oilbased fluids - small site

Metal working -

emulsifiable fluids -

PEC/PNEC

Figure 5.1 Estimated PEC/PNEC ratios for surface water 
232 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 5.2 Estimated PEC/PNEC ratios for sediment 

Scenario Step PEC/PNEC ratio 

 C18–20

liquid 

C>20

liquid 

C>20 solid Total 

Production Generic 6.9×10-3 5.8×10-3 <4.2x10-6 0.013 

Compounding (O) 3.6×10-3 b b 3.6×10-3

Conversion (O) 3.6×10-3 b b 3.6×10-3

Use in PVC – 

plastisol coating 

Compounding/conversion 

(O) 

5.8×10-3 b b 5.8×10-3

Compounding (O) 5.3×10-3 b b 5.3×10-3

Compounding (PO) 0.023 b b 0.023 

Compounding (C) 3.1×10-3 b b 3.1×10-3

Conversion (O) 4.6×10-3 b b 4.6×10-3

Conversion (PO) 4.9×10-3 b b 4.9×10-3

Conversion (C) 4.3×10-3 b b 4.3×10-3

Compounding/conversion 

(O) 

8.5×10-3 b b 8.5×10-3

Compounding/conversion 

(PO) 

0.026 b b 0.026 

Use in PVC – 

extrusion/other 

Compounding/conversion (C) 6.1×10-3 b b 6.1×10-3

Use in rubber Compounding/conversion b 1.5×10-3 <2.2×10-4 1.7×10-3

Use in sealants Formulation and use <1 <1 b <1 

Formulation <1 <1 <2.5×10-6 <2.5×10-6

Industrial application 6.6×10-3 1.8×10-3 <4.8×10-5 8.4×10-3

Use in paints 

Domestic application <1 <1 <1 <1

Formulation 1.4×10-3 8.8×10-4 b 2.3×10-3

Use in oil-based fluids (large 

site – 5% LCCP content)

b 5.9×10-3 b 5.9×10-3

Use in oil-based fluids (large 

site – 10% LCCP content)

b 0.011 b 0.011 

Use in oil-based fluids (small 

site – 5% LCCP content)

0.028 5.5×10-3 b 0.034 

Use in oil-based fluids (small 

site – 10% LCCP content)

0.054 0.010 b 0.064 

Use in emulsifiable fluids 3.6×10-3 1.3×10-3 b 4.9×10-3

Use in metal 

cutting/working 

fluids 

Use in emulsifiable fluids – 

intermittent release 

2.2a

 or 

0.016–

0.040a 

0.38a or 

3.3×10-3–

7.6×10-3a 

b 2.6a or 

0.019–

0.048a 

Table 5.2 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 233

Table 5.2 continued 

Scenario Step PEC/PNEC ratio 

 C18–20

liquid 

C>20

liquid 

C>20 solid Total 

Formulation 0.010 2.4×10-3 Use in leather b 0.012 

fat liquors Use – complete processing 

of raw hides 

0.081 0.015 b NA 

Use in textile applications 0.38 b b 0.38 

Regional sources 2.3×10-3– 

2.7×10-3

1.6×10-3– 

1.8×10-3

<3.0×10-6–

<3.1×10-6 

3.9×10-3– 

4.5×10-3

Notes: a Intermittent release scenario – it is not clear how this is dealt with in the TGD for 

sediment (see text). 

 b = process makes no significant contribution to levels in sediment. 

 NA = not applicable. 

 O = open systems; PO = partially open systems; C = closed systems (as defined in 

OECD, 2004b). 
234 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

0

0.20.40.60.8

1

1.2

Production

PVC - plastisol coating - compounding

PVC - plastisol coating - conversion

PVC - plastisol coating - compounding/conversion

PVC - other - compounding - O

PVC - other - compounding - PO

PVC - other - compounding - C

PVC - other - conversion - O

PVC - other - conversion - PO

PVC - other - conversion - C

PVC - other - compounding/conversion - O

PVC - other - compounding/conversion - PO

PVC - other - compounding/conversion - C

Rubber

Paints - formulation

Paints - application

Metal working - formulation

Metal working - use in oil-based fluids - large site

Metal working - use in oil-based fluids - small site

Metal working - use in emulsifiable fluids

Metal working - emulsifiable fluids - intermittent release

PEC/PNEC

Figure 5.2 PEC/PNEC ratios for sediment 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 235

The TGD does not give any guidance for how this type of intermittent scenario should 

be treated in the risk characterisation for sediment. The PEC/PNEC ratios here have 

been derived based on the instantaneous concentration expected in sediment during 

an emission event (this assumes that equilibrium between the sediment and water is 

reached instantly), and also based on an average concentration over the year, taking 

into account the other emissions from the site. For the chlorinated paraffins considered, 

the PEC/PNEC ratio changes from >1 to <1 when the average PEC is used. The 

uncertainties in this scenario are discussed further in Section 5.1.4. 

As discussed in Section 5.1.4, when metalworking lubricants containing up to 70 per 

cent chlorinated paraffin are considered, the PEC/PNEC ratio could be up to seven 

times higher than the calculation for a fluid with 10 per cent chlorinated paraffin 

content. In the use in oil-based fluids this increase would lead to a PEC/PNEC ratio for 

of 0.38 for C18–20 liquid chlorinated paraffins and 0.070 for C>20 liquid chlorinated 

paraffins. Therefore no risk would be expected even if the chlorinated paraffin content 

was as high as 70 per cent. 

High concentrations of LCCPs are predicted to occur in the sediment compartment and 

so it is important to consider the risk characterisation for this compartment carefully. 

Recent tests on sediment organisms with medium-chain chlorinated paraffins showed 

that these were toxic to sediment organisms (the NOEC was 50 mg/kg wet weight), so 

the possibility exists that LCCPs may also be toxic to sediment organisms at 

concentrations similar to those predicted. Since the current PNECs for LCCPs are 

derived based on the equilibrium partitioning method, and the aquatic data on which 

they are based are rather uncertain, the whole assessment for the sediment 

compartment is uncertain. The most logical way forward for the assessment of 

sediment as a whole would be to investigate toxicity of LCCPs to sediment-organisms 

directly. However, given the generally low risk characterisation ratios found in the 

current assessment, such further testing is not considered to be a high priority. 

5.1.4 Uncertainties and possible refinements 

As with any "generic" risk assessment, there are uncertainties inherent in the approach 

taken. For LCCPs these uncertainties are compounded by the fact that the 

commercially produced substances contain many components; they are either difficult 

to test or fall outside the scope of simple standard testing methods. The derivation of 

the physico-chemical properties and other data necessary for the PEC calculations is 

therefore difficult. 

In this assessment, a set of data has been chosen that is considered to be 

representative for three subgroups of LCCPs. These data necessarily rely on estimates 

and extrapolations from other data, and so in themselves are uncertain. Furthermore, 

given the nature of LCCP substances (low solubility, high log Kow, low vapour 

pressure), it is unlikely that actual further measurement of some of these properties is 

practical. The effect of variation in some of these physico-chemical properties on the 

environmental modelling has been investigated in Appendix E. However, there are still 

some areas where reliable information is lacking. 

There is considerable uncertainty over the aquatic effects data for these substances; a 

conservative approach has therefore been taken to determine the PNECs used for 

surface water.As it is not possible to derive a reliable PNEC for the C>20 liquid and C>20

solid chlorinated paraffins for surface water, this assessment takes a worst case 

screening approach. Even so, the resulting risk characterisation indicates that the 

PEC/PNEC is <1 for all scenarios considered. 
236 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Therefore, for the vast majority of uses, even though there are large uncertainties over 

the aquatic toxicity data, further testing on aquatic organisms does not appear to be 

warranted based on the results of this assessment. The sediment compartment 

appears to be much more relevant for these substances. 

For this assessment, the PNECs for sediment have been estimated based on the 

equilibrium partitioning method. Recent tests on sediment organisms with mediumchain chlorinated paraffins showed that these were toxic to sediment organisms (a 

NOEC of 50 mg/kg wet weight was determined) and so the possibility exists that 

LCCPs may also be toxic to sediment organisms at similar concentrations. 

However, the current PNECs for LCCPs are derived using the equilibrium partitioning 

method, but the aquatic data on which the calculations are based are rather uncertain, 

making uncertain the entire assessment for the sediment compartment. In addition, 

even if it is assumed that the C>20 liquid and C>20 solid chlorinated paraffins are not toxic 

to aquatic organisms at concentrations up to their water solubility, it does not 

necessarily follow that no toxicity would be expected to sediment-dwelling organisms 

because direct ingestion of sediment-bound substance could occur. 

Investigation of the toxicity of LCCPs to sediment-organisms directly should therefore 

be considered in order to reduce some of this uncertainty. However, given the 

generally low risk characterisation ratios found in the current assessment, such further 

testing is not thought be a high priority. 

The actual emission estimates used in this assessment are also uncertain. For most 

scenarios considered, the best information available for specific industries has been 

used in preference to the default estimates. However, in many cases industry 

information was not available for LCCPs, but has been extrapolated from data for other 

substances. This approach necessarily introduces uncertainties into the estimates. 

In addition, it is possible that LCCPs are imported into the EU. Figures on the actual 

imports are unknown, although an allowance for imports has been made in the way the 

emission estimates have been derived. Nevertheless, this lack of information 

introduces further uncertainties into the exposure assessment, particularly if the 

imported substance is used in applications not covered by the assessment. 

For use in metal cutting/working fluids, the actual extent of use of LCCPs in waterbased emulsions is unknown. Recent information from Euro Chlor has indicated that, 

as far as they are aware, there is no use in water-based emulsions, but the coverage of 

the survey is unclear. The available information indicates that LCCPs are used mainly 

in oil-based lubricants for deep drawing operations. Some of these oil types of lubricant 

may have LCCP contents higher than assumed in the PEC calculations, for example 

up to 70 per cent. Assuming the release of these high LCCP content fluids is the same 

as for the oil-based fluids in general, then the resulting PEC/PNEC ratio would be 

approximately seven times that obtained for a fluid with 10 per cent chlorinated paraffin 

content. Nevertheless, this higher PEC/PNEC ratio would still be <1. 

For the intermittent release scenario for surface water, the PNEC is even more 

uncertain because the TGD recommends that the PNEC should be derived from acute 

data (the environmental exposure from this scenario will be very short-term), usually 

using an assessment factor of 100. However, it was not possible to determine the 

PNEC in this way as the substance involved showed little or no toxicity in acute tests, 

even when tested at concentrations well in excess of its water solubility; the PNEC for 

water for long-term exposure has been used instead. Despite this, the resulting risk 

characterisation ratio is <1, indicating a low risk. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 237

For the intermittent release scenario for sediment, the TGD does not give any guidance 

for how this scenario should be treated in the risk characterisation. The PEC/PNEC 

ratios here have been derived: 

• based on the instantaneous concentration expected in sediment during an 

emission event (this assumes that equilibrium between the sediment and water 

is reached instantly); 

• based on an average concentration over the year, taking into account the other 

emissions from the site. 

For the chlorinated paraffins considered, the PEC/PNEC ratio changes from >1 to <1 

when the average PEC is used. 

For the use of LCCPs in textiles, little information is currently available on the 

processes used, and the potential for emission to the environment. The current 

assessment is based on worst case default assumptions and so may grossly 

overestimate the actual emissions to the environment, and hence PECs. Further 

information on the emissions to the environment from this process would be useful to 

reduce the uncertainty with this scenario. However, no risks to the aquatic environment 

(water and sediment) were identified with the worst case approach taken. 

Information is also lacking in the assessment of "waste remaining in the environment". 

Here there are no agreed methodologies available in the TGD for estimating PECs for 

this type of release. There are also uncertainties associated with the actual 

(bio)availability and environmental behaviour of the substance when released in this 

form (essentially as polymer particulates containing the substance). 

5.1.5 Conclusions for the aquatic compartment 

For surface water, the PEC/PNEC ratios are <1 for all scenarios; it is concluded that 

LCCPs present a low risk to this compartment. 

For sediment, the PEC/PNEC ratios are <1 for all scenarios except for the intermittent 

release scenario of C18–20 liquid chlorinated paraffins from emulsion-based metal 

cutting/working fluids. The relevance of this scenario to the current use of LCCPs, and 

the current fluid disposal practices within the industry, is not clear. The assessment 

could be refined with: 

• clarification of whether LCCPs are used in emulsion metal cutting/working 

fluids; 

• clarification of the current disposal practices of emulsion metal cutting/working 

fluids containing LCCPs. 

It should be noted, however, that the applicability of the equilibrium partitioning 

approach for these substances is uncertain, and toxic effects have been seen with 

other chlorinated paraffins at concentrations much lower than the PNECs assumed in 

this assessment. To reduce the uncertainty in the risk assessment for the sediment 

compartment, information on the actual toxicity to sediment-organisms should be 

considered. Ideally, these data should be obtained on a C18–20 liquid or C>20 liquid 

chlorinated paraffin product in the first instance. The results from toxicity tests with 

medium-chain chlorinated paraffins indicate that Lumbriculus variegatus or Hyalella 

azteca would be suitable test organisms. However, the results of the current 

assessment indicate that the need for such toxicity data should be a low priority at 

present. 
238 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

5.2 Terrestrial compartment 

5.2.1 Risk characterisation ratios 

There are no toxicity studies available on plants, earthworms or other soil-dwelling 

organisms. The equilibrium partitioning method has been used to derive a value for 

PNECsoil of 4,640 mg/kg wet weight for C18–20 liquid chlorinated paraffins and screening 

values, PNECsoil(screening), of 26,900 mg/kg wet weight for C>20 liquid chlorinated paraffins 

and >971,000 mg/kg wet weight for C>20 solid chlorinated paraffins. The TGD suggests 

that the PEC/PNEC ratio is increased by a factor of 10 for substances with log Kow >5 

to take into account direct ingestion of soil-bound substance. The resulting PEC/PNEC 

ratios obtained are shown in Table 5.3 and Figure 5.3. 

The PEC/PNEC ratios are <1 for all scenarios considered. Therefore the risk to the soil 

compartment from production and use of LCCPs is low. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 239

Table 5.3 PEC/PNEC ratios for soil 

Scenario Step PEC/PNEC ratio 

 C18–20

liquid 

C>20

liquid 

C>20

solid 

Total 

Production Generic <1 <1 <1 <1 

Compounding (O) 2.3×10-3 b b 2.3×10-3

Conversion (O) 2.3×10-3 b b 2.3×10-3

Use in PVC – 

plastisol 

coating Compounding/conversion 

(O) 

3.2×10-3 b b 3.2×10-3

Compounding (O) 3.0×10-3 b b 3.0×10-3

Compounding (PO) 0.010 b b 0.010 

Compounding (C) 2.1×10-3 b b 2.1×10-3

Conversion (O) 2.7×10-3 b b 2.7×10-3

Conversion (PO) 2.8×10-3 b b 2.8×10-3

Conversion (C) 2.6×10-3 b b 2.6×10-3

Compounding/conversion 

(O) 

4.4×10-3 b b 4.4×10-3

Compounding/conversion 

(PO) 

0.012 b b 0.012 

Use in PVC – 

extrusion/other 

Compounding/conversion 

(C) 

3.4×10-3 b b 3.4×10-3

Use in rubber Compounding/conversion b 3.4×10-4 <9.1×10-5 4.3×10-4 

Use in sealants Formulation and use <1 <1 b <1 

Formulation <1 <1 <4.2×10-7 <4.2×10-7

Industrial application 3.6×10-3 4.7×10-4 <2.0×10-5 4.1×10-3 

Use in paints 

Domestic application <1 <1 <1 <1

Formulation 1.4×10-3 8.1×10-5 b 1.5×10-3

Use in oil-based fluids (large 

site – 5% LCCP content)

b 2.2×10-3 b 2.2×10-3 

Use in oil-based fluids (large 

site – 10% LCCP content)

b 4.3×10-3 b 4.3×10-3 

Use in oil-based fluids (small 

site – 5% LCCP content)

0.013 2.0×10-3 b 0.015 

Use in oil-based fluids (small 

site – 10% LCCP content)

0.024 3.9×10-3 b 0.028 

Use in emulsifiable fluids 2.3×10-3 2.4×10-4 b 2.5×10-3

Use in metal 

cutting/working 

fluids 

Use in emulsifiable fluids – 

intermittent release 

0.10a 0.018a b 0.12a 

Table 5.3 continued overleaf 
240 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 5.3 continued 

Scenario Step PEC/PNEC ratio 

 C18–20

liquid 

C>20

liquid 

C>20 solid Total 

Formulation 6.9×10-3 5.6×10-4 b 7.5×10-3 Use in leather 

fat liquors Use – complete 

processing of raw hides 

0.035 5.9×10-3 b NA 

Use in textile 

applications 

 0.16 b b 0.16 

Agricultural soil 9.1×10-4– 

1.2×10-3

1.0×10-3 <1.6×10-7–

<1.7×10-7 

1.9×10-3– 

2.2×10-3 

Regional 

sources 

Industrial/urban soil 0.024– 

0.026 

0.023– 

0.025 

<5.5×10-5– 

<5.6×10-5 

0.047– 

0.051 

Notes: a Assumes dilution of sewage sludge at waste water treatment plant before 

application to soil. 

 b = process makes no significant contribution to levels in water. 

 NA = not applicable. 

O = open systems; PO = partially open systems; C = closed systems (as 

defined in OECD, 2004b). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 241

0

0.20.40.60.8

1

Production

PVC- plastisol coating - compounding

PVC - plastisol coating - conversion

PVC - plastisol coating - compounding/conversion

PVC - other - compounding - O

PVC - other - compounding - PO

PVC - other - compounding - C

PVC - other - conversion - O

PVC - other - conversion - PO

PVC - other - compounding - C

PVC - other - compounding/conversion - O

PVC - other - compounding/conversion - PO

PVC - other - compounding/conversion - C

Rubber

Paints - formulation

Paints - application

Metal working - formulation

Metal working - use in oil-based fluids - large site

Metal working - use in oil-based fluids - small site

Metal working - use in emulsifiable fluids

Metal working - emulsifiable fluids - intermittent release

PEC/PNEC

Figure 5.3 PEC/PNEC ratios for soil 
242 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

5.2.2 Uncertainties and possible refinements 

There are uncertainties over the emission estimates used for many of the scenarios 

considered in this assessment. These uncertainties are discussed in Section 5.1.4 in 

relation to the surface water and sediment compartments. The application to land of 

sludge generated during the treatment of waste water could be a major route to soil for 

LCCPs, so the uncertainties in the emissions to waste water are equally relevant here. 

There are also uncertainties over the behaviour of LCCPs during waste water treatment 

(the fraction going to sludge) and the subsequent rate of biodegradation of LCCPs in soil 

to which the sludge is applied. Within the methodology used, the predicted behaviour 

during waste water treatment is governed mainly by the log Kow value and the Henry’s 

Law constant. The effect on the environmental modelling made by variations to some of 

the key physico-chemical properties of LCCPs is explored in Appendix E. This work shows 

that the predicted concentrations in soil were relatively insensitive to the value of the 

physico-chemical properties used. 

Appendix E also considers how the uncertainties in the biodegradation rate of LCCPs 

affect the PECs. The degradation rate was shown to be a key input parameter for the 

calculation of regional and (to a lesser extent) local concentrations. The degradation rate 

also has a major impact on the predicted concentrations in soil and any further 

concentrations derived from them (e.g. earthworms, root crops etc.). The current 

PEC/PNEC ratios essentially assume that no biodegradation occurs. If significant 

biodegradation of LCCPs does occur in the environment this activity would reduce the 

PEC/PNEC ratios (particularly at the regional level), even if the biodegradation rate is 

slow. 

The industrial/urban soil scenarios result from long-term emissions of particulate matter 

containing LCCPs. There are some uncertainties in these estimates, particularly over the 

actual availability and persistence of the chlorinated paraffin over extended time periods. 

As discussed in Section 3.3.2.1, the length of time taken to reach steady state in the 

industrial/urban soil compartment is of the order of 1,000 years or more, which makes the 

predicted concentrations very uncertain. The predicted concentration can be calculated 

over a shorter timeframe. The concentration reached 100 years from now would be 

approximately 2 mg/kg wet weight for the C18–20 liquid chlorinated paraffins, 14 mg/kg wet 

weight for the C>20 liquid chlorinated paraffins and 0.5 mg/kg wet weight for the C>20 solid 

chlorinated paraffins. The resulting PEC/PNEC ratios for industrial/urban soil would be 

4.3×10-3, 5.2×10-3 and 5.2×10-6 for the three chlorinated paraffin types respectively, giving 

a total PEC/PNEC ratio of 9.5×10-3. 

It may be also possible to refine the PECs for industrial/urban soil scenarios by obtaining 

further exposure information or a more realistic biodegradation rate in soil for these 

substances. However, the effort required to obtain these values would be large and it is 

unlikely that the information would have a significant impact on the conclusions of the risk 

assessment. 

Similar to the case with sediment, the PNEC for the soil compartment is uncertain, due to 

uncertainties in the underlying aquatic toxicity data and uncertainties in the applicability of 

the equilibrium partitioning method to LCCPs. Some of these uncertainties are already 

taken into account by the use of a conservative approach with regard to the assessment 

factors used etc. Recent tests on medium-chain chlorinated paraffins indicated that they 

were toxic to earthworms (Eisenia fetida), with a NOEC of 106 mg/kg wet weight. Thus, 

based on these data for other chlorinated paraffins, although it cannot be ruled out that 

LCCPs will be toxic to soil organisms, it is very unlikely that they will be toxic at 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 243

concentrations similar to those predicted in most local scenarios (<50 mg/kg wet weight, 

and generally between 1 and 10 mg/kg wet weight). 

5.2.3 Conclusions for soil 

The PEC/PNEC ratios are <1 for all scenarios considered. Therefore the risk to the soil 

compartment from production and use of LCCPs is low. 

5.3 Atmosphere 

5.3.1 Conclusions for the atmosphere 

Neither biotic nor abiotic effects on the atmosphere are likely because of the limited 

atmospheric release and low volatility of LCCPs. 

Long-range atmospheric transport and subsequent bioaccumulation in remote regions 

have been raised as a possible concern for chlorinated paraffins, particularly the shortchain ones. This issue is currently being discussed within the appropriate international 

fora, but no agreement has yet been reached. 

The potential for long-range transport (and subsequent accumulation) of the LCCPs 

appears to be less than that for short-chain chlorinated paraffins. LCCPs generally have 

lower vapour pressures, are likely to adsorb more strongly to soil and sediment, and 

appear to be less bioaccumulative. However, the substances supplied in the market 

contain many components spanning a range of physico-chemical properties. Some 

components of the commercial products may have properties that may mean that longrange transport via the atmosphere is a possibility. This issue should be considered 

further in the appropriate international fora. 

5.4 Non-compartment specific effects relevant for the 

food chain (secondary poisoning) 

5.4.1 Risk characterisation ratios 

PNECs for secondary poisoning by oral intake have been tentatively determined as 

5 mg/kg food for the C18–20 liquid chlorinated paraffins (screening value), 22 mg/kg food for 

the C>20 liquid chlorinated paraffins and 22 mg/kg food for the C>20 solid chlorinated 

paraffins. The estimated PEC/PNEC ratios for secondary poisoning are shown in Table 

5.4 (via the fish food chain) and Table 5.5 (via the earthworm food chain) and in Figure 5.4 

and Figure 5.5. 

For the fish food chain, the PEC/PNEC ratios are all very low. Therefore it can be 

concluded that a risk of secondary poisoning via the fish food chain is low for LCCPs.

For the earthworm food chain, risk characterisation ratios >1 are obtained for the C18–20

liquid chlorinated paraffins for two scenarios only (the use of LCCPs in emulsifiable metal 

cutting/working fluids where intermittent disposal to waste water is assumed, and the use 

in textiles). All other scenarios lead to risk characterisation ratios <1. 
244 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 5.4 PEC/PNEC ratios for secondary poisoning via the fish food ch

Scenario Step PEC/PNEC ratio – TGD method PEC/PNE

C18–20

liquid 

C>20

liquid 

C>20 solid Total C18–20

liquid 

C

liq

Production Generic 2.4×10-4 1.4×10-5 6.8×10-11 2.5×10-4 4.8×10-4 2.

Compounding (O) 9.2×10-5 b b 9.2×10-5 1.8×10-4 b Conversion (O) 9.2×10-5 b b 9.2×10-5 1.8×10-4 b 

Use in PVC – plastisol coating Compounding/conversion 

(O) 

9.8×10-5 b b 9.8×10-5 2.0×10-4 b 

Compounding (O) 9.6×10-5 b b 9.6×10-5 1.9×10-4 b Compounding (PO) 1.5×10-4 b b 1.5×10-4 3.0×10-4 b Compounding (C) 9.0×10-5 b b 9.0×10-5 1.8×10-4 b Conversion (O) 9.4×10-5 b b 9.0×10-5 1.9×10-4 b Conversion (PO) 9.6×10-5 b b 9.6×10-5 1.9×10-4 b Conversion (C) 9.4×10-5 b b 9.4×10-5 1.9×10-4 b Compounding/conversion (O) 

1.1×10-4 b b 1.1×10-4 2.2×10-4 b 

Compounding/conversion (PO) 

1.6×10-4 b b 1.6×10-4 3.2×10-4 b 

Use in PVC – extrusion/other

Compounding/conversion (C) 

1.0×10-4 b b 1.0×10-4 2.0×10-4 b 

Use in rubber Compounding/conversion b 5.0×10-6 2.0×10-10 5.0×10-6 b 1.Use in sealants 

Formulation and use <1 <1 b <1 <1 <Formulation <1 <1 5.0×10-11 5.0×10-11 <1 <

Industrial application 2.2×10-3 5.9×10-6 5.0×10-10 2.2×10-3 4.4×10-4 1.

Use in paints 

Domestic application <1b <1b <1b <1b <1b <

Table 5.4 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 245

Table 5.4 continued Scenario Step PEC/PNEC ratio – TGD method PEC/PNE

C18–20

liquid 

C>20

liquid 

C>20 solid Total C18–20

liquid 

C

liq

Use in metal cutting/working fluids 

Formulation 8.6×10-5 4.2×10-6 b 9.0×10-5 1.7×10-4 8.Use in oil-based fluids (large site – 5% LCCP content) 

b 1.4×10-5 b 1.4×10-5 b 2.

Use in oil-based fluids (large site - 10% LCCP content) 

b 2.4×10-5 b 2.4×10-5 b 5.

Use in oil-based fluids (small site – 5% LCCP content) 

7.8×10-4 1.3×10-5 b 7.9×10-4 1.6×10-3 2.

Use in oil-based fluids (small site – 10% LCCP content) 

1.5×10-3 2.2×10-5 b 1.5×10-3 3.0×10-3 4.

Use in emulsifiable fluids 1.4×10-4 5.0×10-6 b 1.5×10-4 2.8×10-4 1.Use in emulsifiable fluids – intermittent release 

4.8×10-4 a 9.1×10-6 a b 4.9×10-4 a 9.6×10-4 a 1.

Use in leather fat liquors 

Formulation 1.6×10-4 4.5×10-6 b 1.6×10-4 3.2×10-4 9.

Use – complete processing of raw hides 

7.8×10-4 8.2×10-6 b NA 1.6×10-3 1.

Use in textile Compounding 0.010 b b 0.010 0.020 b 

Notes: a Intermittent release scenario. 

 b = process makes no significant contribution to levels in water.  O = open systems; PO = partially open systems; C = closed systems (as defined in OECD, 2004b). 

NA = not applicable. 
246 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 5.5 PEC/PNEC ratios for secondary poisoning via the earthworm food 

Scenario Step PEC/PNEC ratio – corrected TGD m

C18–20 liquid C>20 liquid C>20 solid 

Production Generic <1 <1 <1 

Compounding (O) 0.048 b b Conversion (O) 0.048 b b 

Use in PVC – plastisol coating Compounding/conversion 

(O) 

0.059 b b 

Compounding (O) 0.057 b b Compounding (PO) 0.16 b b Compounding (C) 0.044 b b Conversion (O) 0.054 b b Conversion (PO) 0.054 b b Conversion (C) 0.051 b b Compounding/conversion (O) 

0.074 b b 

Compounding/conversion (PO) 

0.18 b b 

Use in PVC – extrusion/other

Compounding/conversion (C) 

0.062 b b 

Use in rubber Compounding/conversion b 0.019 2.0×10-3 

Use in sealants 

Formulation and use <1 <1 b 

Formulation <1 <1 1.3×10-5 

Industrial application 0.065 0.021 4.4×10-4 

Use in paints 

Domestic application <1 <1 <1 

Table 5.5 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 247

Table 5.5 continued Scenario Step PEC/PNEC ratio – corrected TGD m

C18–20 liquid C>20 liquid C>20 solid 

Use in metal cutting/working fluids 

Formulation 0.034 0.015 b Use in oil-based fluids (large site – 5% LCCP content) 

b 0.044 b 

Use in oil-based fluids (large site – 10% LCCP content) 

b 0.074 b 

Use in oil-based fluids (small site – 5% LCCP content) 

0.18 0.041 b 

Use in oil-based fluids (small site – 10% LCCP content) 

0.33 0.069 b 

Use in emulsifiable fluids 0.048 0.017 b 

Use in emulsifiable fluids – intermittent release 

1.4a 0.25a b 

Use in leather fat liquors 

Formulation 0.11 0.022 b 

 Use – complete processing 

of raw hides 

0.48 0.094 b 

Use in textile 2.2 b b 

Notes: a Intermittent release scenario. 

 b = process makes no significant contribution to levels in water.  O = open systems; PO = partially open systems; C = closed systems (as defined in OECD, 2004b).  NA = not applicable. 
248 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Figure 5.4 PEC/PNEC ratios for secondary poisoning by the fish food chain (altern

0.000.200.40

Production

PVC- plastisol coating - compounding

PVC -plastisol coating - conversion

PVC - plastisol coating - compounding/conversion

PVC - other - compounding - O

PVC - other - compounding - PO

PVC - other - compouding - C

PVC - other - conversion - O

PVC - other - conversion - PO

PVC - other - conversion - C

PVC - other - compounding/conversion - O

PVC - other - compounding/conversion - PO

PVC - other - compounding/conversion - C

Rubber

Paints - formulation

Paints - application

Metal working - formulation

Metal working - use in oil-based fluids - large site

Metal working - use in oil-based fluids - small site

Metal working - use in emulsifiable fluids

Metal working - emulsifiable fluids - intermittent release

PEC/PNE

C
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 249

Figure 5.5 PEC/PNEC ratios for secondary poisoning by the earthworm food chain (corre

0

0.20.40.60.8

1

1.2

Production

PVC- plastisol coating - compounding

PVC - plastsol coating - conversion

PVC - plastisol coating - compounding/conversion

PVC - other - compounding - O

PVC - other - compounding - PO

PVC - other - compounding - C

PVC - other - conversion - O

PVC - other - conversion - PO

PVC - other - conversion - C

PVC - other - compounding/conversion - O

PVC - other - compounding/conversion - PO

PVC - other - compounding/conversion - C

Rubber

Paints - formulation

Paints - application

Metal working - formulation

Metal working - use in oil-based fluids - large site

Metal working - use in oil-based fluids - small site

Metal working - use in emulsifiable fluids

PEC/PNEC 
250 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

5.4.2 Uncertainties and possible refinements 

The PECs for secondary poisoning depend on the predicted concentrations in surface 

water and soil. The uncertainties for these compartments – outlined in Section 5.1.4 

and Section 5.2.2 – are also relevant here. In particular, the two scenarios that lead to 

a PEC/PNEC ratio >1 for earthworms (the intermittent release of LCCPs in metal 

cutting/working fluids and their use in textiles) also lead to a PEC/PNEC >1 for the 

sediment compartment. The application to land of sludge generated during the 

treatment of waste water could be a major route to soil for LCCPs, so the uncertainties 

in the emissions to waste water are equally relevant here as they are for sediment. 

Therefore, further exposure information would be useful to reduce the uncertainty in 

these two scenarios. 

There are considerable uncertainties over the bioconcentration factors for LCCPs in 

fish and in earthworms. The current assessment is based on what are considered to be 

the best available estimates for the bioconcentration factor for fish and the 

bioaccumulation factor for earthworms from soil. The risk characterisation ratios for the 

fish food chain are very low so the uncertainties over the bioconcentration factor are 

probably not too significant in terms of the overall conclusions of the assessment. 

However, for the earthworm food chain, which has risk characterisation ratios above 1 

in some scenarios, the uncertainty over the extent of uptake into earthworms is 

important to the overall conclusions as to whether a risk actually exists. The 

determination of an actual earthworm bioconcentration factor for LCCPs would 

therefore be worth considering. 

There are also uncertainties over the PNECs used for secondary poisoning. In 

particular the PNEC for the C18–20 liquid chlorinated paraffins is based on a 

conservative read-across approach from data on medium-chain chlorinated paraffins. 

5.4.3 Conclusions for predators 

The risk of secondary poisoning through the fish food chain appears to be low for all 

scenarios considered. 

For the earthworm food chain, risk characterisation ratios >1 were obtained for the use 

of LCCPs in emulsion-based metal cutting/working fluids (intermittent release scenario) 

and textile applications. To make a decision on whether a risk actually exists the 

assessment could be refined with: 

• clarification of whether LCCPs are used in emulsion metal cutting/working 

fluids; 

• clarification of the current disposal practices of emulsion metal cutting/working 

fluids containing LCCPs; 

• information on the emissions to the environment from textile processes using 

LCCPs. 

Consideration could also be given to carrying out an earthworm bioaccumulation test 

with a C18–20 liquid LCCP. However, the need for such testing is considered a low 

priority at present. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 251

5.5 Marine compartment 

5.5.1 Risk characterisation ratios 

The PEC/PNEC ratios obtained for the marine compartment are summarised in Table 

5.6 (marine water), Table 5.7 (marine sediment), Table 5.8 (marine predators) and 

Table 5.9 (marine top predators). The PEC/PNEC ratios for sediment have been 

increased by a factor of 10 to take account of the possibility of direct ingestion of 

sediment-bound substance. 

The PEC/PNEC ratios are <1 for the majority of scenarios, indicating a low risk to the 

marine compartment. However PEC/PNEC ratios >1 are obtained for marine water and 

marine sediment for use in metal cutting/working fluids (intermittent release scenario) 

and for marine sediment for use in textiles. 

Table 5.6 PEC/PNEC ratios for marine water 

Scenario Step PEC/PNEC 

C18–20 

liquid 

C>20 liquid C>20 solid Totalc 

Production Generic 4.2×10-3 3.6×10-3 2.1×10-6 7.8×10-3 

Compounding (O) 1.8×10-3 NAa NAa 1.8×10-3 

Conversion (O) 1.8×10-3 NAa NAa 1.8×10-3 

Use in PVC 

– plastisol 

applications Compounding/ 

conversion (O) 

3.3×10-3 NAa NAa 3.3×10-3 

Compounding (O) 3.0×10-3 NAa NAa 3.0×10-3 

Compounding 

(PO) 

0.015 NAa NAa 0.015

Compounding (C) 1.5×10-3 NAa NAa 1.5×10-3 

Conversion (O) 2.5×10-3 NAa NAa 2.5×10-3 

Conversion (PO) 2.7×10-3 NAa NAa 2.7×10-3 

Conversion (C) 2.3×10-3 NAa NAa 2.3×10-3 

Compounding/ 

conversion (O) 

5.3×10-3 NAa NAa 5.3×10-3 

Compounding/ 

conversion (PO) 

0.018 NAa NAa 0.018

Use in PVC 

– extrusion/ 

other 

Compounding/ 

conversion (C) 

3.6×10-3 NAa NAa 3.6×10-3 

Use in 

rubber 

Compounding/ 

conversion 

NAa 5.5×10-4 1.6×10-4 7.1×10-4 

Use in 

sealants 

Formulation and 

use 

negligibleb negligibleb NAa negligibleb

Formulation negligibleb negligibleb 8.9×10-7 8.9×10-7

Industrial 

application 

4.0×10-3 7.6×10-4 3.4×10-5 4.8×10-3 

Use in 

paints 

Domestic 

application 

negligibleb

 negligibleb negligibleb negligibleb
252 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 5.6 continued 

Scenario Step PEC/PNEC 

 C18–20 

liquid 

C>20 liquid C>20 solid Totalc

Formulation 2.1×10-4 1.1×10-4 NAa 3.2×10-4 

Use in oil-based 

fluids (large) 

NAa 3.7×10-3–

7.3×10-3 

NAa 3.7×10-3–

7.3×10-3

Use in oil-based 

fluids (small) 

0.019–

0.038

3.4×10-3–

6.7×10-3 

NAa 0.022–

0.045 

Use in 

emulsifiable fluids 

1.8×10-3 3.8×10-3 NAa 5.6×10-3 

Use in metal 

cutting/ 

working 

fluids 

Use in 

emulsifiable fluids 

– intermittent 

release 

1.6 0.27 NAa

 1.9 

Formulation 6.5×10-3 1.2×10-3 NAa 7.7×10-3 Use in 

leather fat 

liquors Use – complete 

processing of raw 

hidesd 

0.057 9.9×10-3 NAa NA 

Use in textile applications 0.27 NAa NAa 0.27 

Regional sources 1.8×10-4 1.1×10-4 1.9×10-7 2.9×10-4 

Notes: a NA = not applicable; no significant use of the substance in this application. 

b

 The process makes no significant contribution to the levels in water. 

c

 Total = total concentration assuming all types of chlorinated paraffin are 

released from a site. 

d

 The calculation for complete processing of raw hides is considered to be the 

most realistic scenario. 

O = open systems; PO = partially open systems; C = closed systems (as 

defined in OECD, 2004b). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 253

Table 5.7 PEC/PNEC ratios for marine sediment 

Scenario Step PEC/PNEC 

C18–20 

liquid 

C>20

liquid 

C>20 solid Totalc 

Production Generic 0.042 

(<<1)e

 

0.036 

(<<1)e 2.1×10-5

(<<1)e 

0.078

(<<1)e 

Compounding (O) 0.018 NAa NAa 0.018

Conversion (O) 0.018 NAa NAa 0.018

Use in PVC 

– plastisol 

applications Compounding/ 

conversion (O) 

0.033 NAa NAa 0.033

Compounding (O) 0.030 NAa NAa 0.030

Compounding 

(PO) 

0.15 NAa NAa 0.15

Compounding (C) 0.015 NAa NAa 0.015

Conversion (O) 0.025 NAa NAa 0.025

Conversion (PO) 0.027 NAa NAa 0.027

Conversion (C) 0.023 NAa NAa 0.023

Compounding/ 

conversion (O) 

0.053 NAa NAa 0.053

Compounding/ 

conversion (PO) 

0.18 NAa NAa 0.18

Use in PVC 

– extrusion/ 

other 

Compounding/ 

conversion (C) 

0.036 NAa NAa 0.036

Use in 

rubber 

Compounding/ 

conversion 

NAa 5.5×10-3 1.6×10-3 7.1×10-3 

Use in 

sealants 

Formulation and 

use 

negligibleb negligibleb NAa negligibleb

Formulation negligibleb negligibleb 8.9×10-6 8.9×10-6

Industrial 

application 

0.040 7.6×10-3 3.4×10-4 0.048

Use in 

paints 

Domestic 

application 

negligibleb

 negligibleb negligibleb negligibleb

Table 5.7 continued overleaf 
254 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 5.7 continued 

Scenario Step PEC/PNEC 

 C18–20 

liquid 

C>20

liquid 

C>20 solid Totalc

Formulation 2.1×10-3 1.1×10-3 NAa 3.2×10-3 

Use in oil-based 

fluids (large) 

NAa 0.037–

0.073

NAa 0.037–

0.073 

Use in oil-based 

fluids (small) 

0.19–0.38 0.034–

0.067

NAa 0.22–

0.45 

Use in 

emulsifiable fluids 

0.018 3.8×10-3 NAa

 0.022

Use in metal 

cutting/ 

working 

fluids 

Use in 

emulsifiable fluids 

– intermittent 

release 

16 or 

0.11–0.28

2.7 or 

0.019–

0.047 

NAa 19 or 

0.13–

0.33 

Formulation 0.065 0.012 NAa Use in 0.077

leather fat 

liquors Use – complete 

processing of raw 

hidesd 

0.57 0.099 NAa NA 

Use in textile applications 2.7 NAa NAa 2.7 

Regional sources 3.7×10-3 2.2×10-3 3.9×10-6 5.9×10-3 

Notes: a NA = not applicable; no significant use of the substance in this application. 

b

 The process makes no significant contribution to the levels in sediment. 

c

 Total = total concentration assuming all types of chlorinated paraffin are 

released from a site. 

d

 The calculation for complete processing of raw hides is considered to be the 

most realistic scenario. 

e

 Calculation for a generic site. It is known that there is only one chlorinated 

paraffin production site that discharges into the sea after on-site treatment of 

the effluent. A confidential calculation for this site indicates that the PEC/PNEC 

ratios would be <<1. 

O = open systems; PO = partially open systems; C = closed systems (as 

defined in OECD, 2004b). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 255

Table 5.8 PEC/PNEC ratios for marine predators 

Scenario Step PEC/PNEC 

C18–20 

liquide 

C>20

liquide 

C>20 solid Totalc 

Production Generic 2.4×10-4 1.5×10-5 5.0×10-11 2.6×10-4 

Compounding (O) 3.2×10-5 NAa NAa 3.2×10-5 

Conversion (O) 3.2×10-5 NAa NAa 3.2×10-5 

Use in PVC 

– plastisol 

applications Compounding/ 

conversion (O) 

4.2×10-5 NAa NAa 4.2×10-5 

Compounding (O) 4.0×10-5 NAa NAa 4.0×10-5 

Compounding 

(PO) 

1.1×10-4 NAa NAa 1.1×10-4 

Compounding (C) 3.0×10-5 NAa NAa 3.0×10-5 

Conversion (O) 3.6×10-5 NAa NAa 3.6×10-5 

Conversion (PO) 3.8×10-5 NAa NAa 3.8×10-5 

Conversion (C) 3.6×10-5 NAa NAa 3.6×10-5 

Compounding/ 

conversion (O) 

5.2×10-5 NAa NAa 5.2×10-5 

Compounding/ 

conversion (PO) 

1.2×10-4 NAa NAa 1.2×10-4 

Use in PVC 

– extrusion/ 

other 

Compounding/ 

conversion (C) 

4.2×10-5 NAa NAa 4.2×10-5 

Use in 

rubber 

Compounding/ 

conversion 

NAa 2.5×10-6 2.3×10-10 2.5×10-6 

Use in 

sealants 

Formulation and 

use 

negligibleb negligibleb NAa negligibleb

Formulation negligibleb negligibleb 2.4×10-11 2.4×10-11

Industrial 

application 

2.2×10-4 3.6×10-6 6.8×10-10 2.2×10-4 

Use in 

paints 

Domestic 

application 

negligibleb

 negligibleb negligibleb negligibleb

Table 5.8 continued overleaf 
256 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 5.8 continued 

Scenario Step PEC/PNEC 

 C18–20 

liquide

C>20

liquide

C>20 solid Totalc

Formulation 2.4×10-5 1.0×10-6 NAa 2.4×10-5 

Use in oil-based 

fluids (large) 

NAa 1.5×10-5–

3.0×10-5 

NAa 1.5×10-5–

3.0×10-5

Use in oil-based 

fluids (small) 

1.0×10-3–

2.0×10-3 

1.4×10-5–

2.7×10-5 

NAa 1.0×10-3–

2.0×10-3 

Use in 

emulsifiable fluids 

1.1×10-4 2.1×10-6 NAa 1.1×10-4 

Use in metal 

cutting/ 

working 

fluids 

Use in 

emulsifiable fluids 

– intermittent 

release 

5.8×10-4 8.2×10-6 NAa 5.9×10-4 

Formulation 1.3×10-4 1.7×10-6 NAa 1.3×10-4 Use in 

leather fat 

liquors Use – complete 

processing of raw 

hidesd 

1.0×10-3 6.8×10-6 NAa NA

Use in 

textile 

applications 

 0.014 NAa NAa 0.014

Notes: a NA = not applicable; no significant use of the substance in this application. 

b

 The process makes no significant contribution to the levels in fish. 

c

 Total = total concentration assuming all types of chlorinated paraffin are 

released from a site. 

d

 The calculation for complete processing of raw hides is considered to be the 

most realistic scenario. 

e

 The PEC/PNECs for C18–20 liquid and C>20 liquid chlorinated paraffins would be 

around two times higher using the alternate method of calculation. 

O = open systems; PO = partially open systems; C = closed systems (as 

defined in OECD, 2004b). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 257

Table 5.9 Predicted concentrations for marine top predators 

Scenario Step PEClocal(marine top predators) (mg/kg wet wt.) 

C18–20 

liquide 

C>20

liquide 

C>20 solid Totalc 

Production Generic 6.4×10-5 3.8×10-6 1.8×10-11 6.8×10-5 

Compounding (O) 2.6×10-5 NAa NAa 2.6×10-5 

Conversion (O) 2.6×10-5 NAa NAa 2.6×10-5 

Use in PVC 

– plastisol 

applications Compounding/ 

conversion (O) 

2.6×10-5 NAa NAa 2.6×10-5 

Compounding (O) 2.6×10-5 NAa NAa 2.6×10-5 

Compounding 

(PO) 

4.0×10-5 NAa NAa 4.0×10-5 

Compounding (C) 2.4×10-5 NAa NAa 2.4×10-5 

Conversion (O) 2.6×10-5 NAa NAa 2.6×10-5 

Conversion (PO) 2.6×10-5 NAa NAa 2.6×10-5 

Conversion (C) 2.6×10-5 NAa NAa 2.6×10-5 

Compounding/ 

conversion (O) 

3.0×10-5 NAa NAa 3.0×10-5 

Compounding/ 

conversion (PO) 

4.4×10-5 NAa NAa 4.4×10-5 

Use in PVC 

– extrusion/ 

other 

Compounding/ 

conversion (C) 

2.8×10-5 NAa NAa 2.8×10-5 

Use in 

rubber 

Compounding/ 

conversion 

NAa 1.3×10-6 5.5×10-11 1.3×10-6 

Use in 

sealants 

Formulation and 

use 

negligibleb negligibleb NAa negligibleb

Formulation negligibleb negligibleb 1.3×10-11 1.3×10-11

Industrial 

application 

6.2×10-5 1.5×10-6 1.5×10-10 6.4×10-5 

Use in 

paints 

Domestic 

application 

negligibleb

 negligibleb negligibleb negligibleb

Table 5.9 continued overleaf 
258 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table 5.9 continued 

Scenario Step PEClocal(marine top predators) (mg/kg wet wt.) 

 C18–20 

liquide

C>20

liquide

C>20 solid Totalc

Formulation 2.4×10-5 1.0×10-6 NAa 2.5×10-5 

Use in oil-based 

fluids (large) 

NAa 3.9×10-6–

6.8×10-6 

NAa 3.9×10-6–

6.8×10-6

Use in oil-based 

fluids (small) 

2.2×10-4–

4.2×10-4 

3.6×10-6–

6.4×10-6 

NAa 2.2×10-4–

4.2×10-4 

Use in 

emulsifiable fluids 

4.0×10-5 1.3×10-6 NAa 4.1×10-5 

Use in metal 

cutting/ 

working 

fluids 

Use in 

emulsifiable fluids 

– intermittent 

release 

1.3×10-4 2.5×10-6 NAa 1.3×10-4 

Formulation 4.6×10-5 1.2×10-6 NAa 4.7×10-5 Use in 

leather fat 

liquors Use – complete 

processing of raw 

hidesd 

2.2×10-4 2.2×10-6 NAa NA

Use in textile applications 2.8×10-3 NAa NAa 2.8×10-3 

Notes: a NA = not applicable; no significant use of the substance in this application. 

b

 The process makes no significant contribution to the levels in fish. 

c

 Total = total concentration assuming all types of chlorinated paraffin are 

released from a site. 

d

 The calculation for complete processing of raw hides is considered to be the 

most realistic scenario. e

 The PECs for C18–20 liquid and C>20 liquid chlorinated paraffins would be 

around two times higher using the alternate method of calculation. 

O = open systems; PO = partially open systems; C = closed systems (as 

defined in OECD, 2004b). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 259

5.5.2 Assessment against PBT criteria 

The final part of the marine risk assessment procedure requires a screening of the 

properties of a substance to see if it is considered as a persistent (P), bioaccumulative 

(B) and toxic (T) substance. 

5.5.2.1 Persistence 

The persistence criteria laid down in the marine risk assessment guidance require a 

half-life >60 days in marine water or >180 days in marine sediment. For LCCPs, there 

are no tests available from which to estimate a reliable half-life for marine water or 

sediment. The available screening studies, although indicating that biodegradation 

does occur under some situations, indicate that LCCPs are unlikely to be readily 

biodegradable or inherently biodegradable. Therefore it can be assumed that LCCPs 

are potentially persistent or potentially very persistent under the criteria used. 

5.5.2.2 Bioaccumulation 

The criterion used in the marine risk assessment for bioaccumulation is a 

bioconcentration factor (BCF) >2,000 l/kg. There are no reliable experimental 

bioaccumulation factors available for LCCPs. In the main risk assessment report, BCFs 

of 1,092 l/kg for C18–20 liquid chlorinated paraffins, 192 l/kg for C>20 liquid chlorinated 

paraffins and <1 for C>20 solid chlorinated paraffins were estimated from the log Kow 

values of 9.7, 10.3 and 17 respectively. These indicate that the bioaccumulation 

criterion is unlikely to be met for LCCPs. 

The marine risk assessment guidance recommends that, when BCFs are estimated 

from log Kow, a linear structure-activity relationship should be used. This approach 

implies that all substances with a log Kow of >4.5 would meet the bioaccumulation 

criterion. Hence, the LCCPs would be considered as bioaccumulative under this 

definition. 

The BCF values estimated above for LCCPs do not use the linear relationship, but use 

the equation from the TGD recommended for substances with log Kow >6. The values 

obtained using this relationship are broadly consistent with the trend found in the 

measured fish BCFs for other chlorinated paraffins. This finding shows that the actual 

BCF value decreases with increasing carbon chain length (measured fish BCF for 

short-chain chlorinated paraffins was 7,816 l/kg and the measured BCF for mediumchain chlorinated paraffins was 1,087 l/kg). Therefore based on the available data, the 

actual BCF for LCCPs would be expected to be lower than that measured for mediumchain chlorinated paraffins; it is therefore unlikely that the LCCPs would meet the 

bioaccumulation criterion based on the fish BCF. 

The marine risk assessment methodology also allows other bioaccumulation data to be 

taken into account, but does not give specific criteria against which to judge whether 

the substance should be considered bioaccumulative or not. There are several dietary 

accumulation studies available for LCCPs. These show that LCCPs can be taken up by 

organisms (fish, mussels and mammals). In all cases the concentrations reached in the 

animals were less than those in the diet. This indicates that although uptake of the 

substance can occur via food, the levels should not increase through the food chain. 

Therefore, based on this interpretation of the data, LCCPs are not considered to be 

bioaccumulative under the definitions used in the draft marine risk assessment 

guidance. 
260 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

5.5.2.3 Toxicity 

The toxicity criterion used in the marine risk assessment guidance is a chronic NOEC 

<0.01 mg/l. The available data indicate that the chronic NOEC for LCCPs is 0.029 mg/l. 

This value was obtained from tests with Daphnia magna with a C18–20 liquid chlorinated 

paraffin. Other date suggest that the C>20 liquid and C>20 solid chlorinated paraffins are 

not toxic to aquatic organisms at concentrations up to their water solubility limit. 

Therefore, based on these data, LCCPs do not meet the toxicity criterion from the 

marine risk assessment guidance. 

5.5.3 Uncertainties and possible refinements 

In the PEC/PNEC assessment there are considerable uncertainties over both the PECs 

and PNECs. These uncertainties are similar to those discussed in Sections 5.1.4 and 

5.2.2. 

For the PBT assessment there are few reliable experimental data available that can be 

used to compare directly the P and B criteria. Based on the best estimates available, 

LCCPs are considered to potentially meet the P or vP criteria only. 

It should be noted that there are currently some data gaps in the available long-term 

toxicity dataset for LCCPs. However, since the B criterion is not met, according to the 

draft risk assessment guidance, there is no need to carry out further testing to see if the 

T criterion is met. 

5.5.4 Conclusions for the marine compartments 

A marine risk assessment has been carried out for LCCPs using the draft methodology 

under development for inclusion in the TGD. 

The provisional risk assessment carried out indicates a low risk to predators and top 

predators from the production and use of LCCPs but a risk to the marine environment 

from the intermittent release of LCCPs in emulsifiable metal cutting/working fluids 

(based on the current PEC/PNEC ratios for water and sediment). The use of LCCPs in 

textile applications may also pose a risk to the marine environment, based on the 

current PEC/PNEC ratios for sediment. It is possible to refine the PECs for these 

endpoints by obtaining further exposure information, in particular: 

• clarification of whether LCCPs are used in emulsion metal cutting/working 

fluids; 

• clarification of the current disposal practices of emulsion metal cutting/working 

fluids containing LCCPs; 

• information on the emissions to the environment from textile processes using 

LCCPs. 

It would also be possible to revise the PNEC for some of these endpoints by carrying 

out further long-term testing with aquatic organisms and/or sediment organisms, 

preferably marine species. However this type of testing would be very difficult to carry 

out for LCCPs and this should be considered a low priority. 

For the persistent, bioaccumulative and toxic (PBT) criteria, LCCPs can be considered 

to be potentially persistent (P) or potentially very persistent (vP) based on the available 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 261

data. There are some uncertainties over the actual BCF value for LCCPs, but the 

available information indicates that this is likely to be <2,000 l/kg. It should also be 

noted that there are currently some data gaps in the available long-term toxicity dataset 

for LCCPs. However, since the B criterion is not met, according to the draft risk 

assessment guidance, there is no need to carry out further testing to see if the T 

criterion is met. 

5.6 Man exposed via the environment 

5.6.1 Risk characterisation ratios 

For humans exposed via the environment, NOAELs and LOAELs have been 

determined or extrapolated for LCCPs. These are a NOAEL of 23 mg/kg/day for C18–20

liquid chlorinated paraffins and a LOAEL of 100 mg/kg/day for both C>20 liquid and C>20

solid chlorinated paraffins (see Section 4.4.2). These are based on the most sensitive 

effects identified in repeated dose studies (liver or kidney toxicity). 

Similar to the case with the derivation of the PNEC for secondary poisoning, it is 

suggested that the LOAEL values are divided by a factor of 3 to provide an estimate of 

the NOAEL for both C>20 liquid and C>20 solid chlorinated paraffins, and that the NOAEL 

for the C18–20 liquid is divided by a factor of 2 to account for uncertainty resulting from 

the limited availability of toxicity data. Thus the NOAELs considered in this risk 

characterisation would be as follows: 

 C18–20 liquid NOAEL 12 mg/kg/day 

 C>20 liquid NOAEL 33 mg/kg/day 

 C>20 solid NOAEL 33 mg/kg/day 

The predicted human exposure from environmental sources is summarised in Section 

3.3.4. As discussed earlier, the applicability of the methods used to estimate the 

concentrations in the food chain for LCCPs is uncertain. 

The estimated daily human intake from local sources is in the general range: 

• 3.1×10-6 mg/kg/day to 0.026 mg/kg/day for the C18–20 liquid chlorinated paraffins; 

• 8.5×10-7 mg/kg/day to 6.5×10-3 mg/kg/day for the C>20 liquid chlorinated 

paraffins; 

• 3.4×10-12 mg/kg/day to 8.9×10-4 mg/kg/day for the C>20 solid chlorinated 

paraffins. 

The margin of safety (MOS) between the above NOAELs and these exposure levels is: 

• 461–3.9×106

 for the C18–20 liquid chlorinated paraffins; 

• 5.1×103

–3.9×107 for the C>20 liquid chlorinated paraffins; 

• 3.7×104

–9.7×1012 for the C>20 solid chlorinated paraffins. 

These MOS are very large for the C>20 liquid chlorinated paraffins and the C>20 solid 

chlorinated paraffins; it can be concluded therefore that there is no concern for local 

exposure in relation to repeated dose toxicity of these substances. 
262 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

For the C18–20 liquid chlorinated paraffins, the lowest MOS for local exposure is 461 

(from use in textile applications); the MOS is ≥1.8×103

 for all other scenarios. These 

MOS are all high, indicating that there is little or no concern for local exposure in 

relation to repeated dose toxicity from these uses. 

The value for human exposure for regional environmental sources predicted by EUSES 

is: 

• 1.5×10-4 mg/kg/day for the C18–20 liquid products; 

• 7.1×10-4 mg/kg/day for the C>20 liquid products; 

• 4.2×10-6 mg/kg/day for the C>20 solid products. 

The MOS between the above NOAELs and these exposure levels is: 

• 8.0×104 for the C18–20 liquid products; 

• 4.7×104 for the C>20 liquid products; 

• 7.9×106 for the C>20 solid products. 

These MOS values are very high and therefore there is no concern for regional 

exposures in relation to repeated dose toxicity of LCCPs. 

It should be taken into account here that there are considerable uncertainties in both 

the PECs and NOAELs considered in the assessment for exposure of man via the 

environment. It would be theoretically possible to obtain more reliable estimates of the 

likely exposure via the food chain for these substances by carrying out further testing to 

investigate the actual uptake into root crops, milk, meat and leaf crops. However, such 

testing would be difficult to carry out for these substance and, based on the approach 

above, such further testing is not currently warranted. 

5.6.2 Uncertainties and possible refinements 

There is considerable uncertainty in the PECs calculated for man via the environment. 

It may be possible to refine the PEC estimates by carrying out further investigations to 

measure the actual uptake from soil into root crops, from air into leaf crops and the 

subsequent transfer into meat and milk. However, such investigations would be 

extremely difficult to carry out and such refinement is not considered to be a priority at 

present. 

It may also be possible to refine the PECs by obtaining further information on the 

release to the environment from the uses of LCCPs. 

5.6.3 Conclusions for man exposed via the environment 

The provisional risk assessment carried out indicates that the production and uses of 

the C18–20 liquid, C>20 liquid and C>20 solid chlorinated paraffins are expected to present 

a low risk to man exposed via environmental routes. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 263

5.7 Other issues 

5.7.1 Presence of other chlorinated paraffin impurities in LCCPs 

In Section 1.2.1, information was reported to indicate that the C18–20 liquid chlorinated 

paraffins may contain a substantial proportion of C17 chlorinated paraffins, and very 

small amounts of chlorinated paraffins of shorter chain lengths. The typical levels 

reported were 17 per cent C17 and <1 per cent C16, although the range of the C17

impurity was given as 10–20 per cent. The amounts of chlorinated paraffins with 

carbon chain lengths of C15 or lower present in the C18–20 liquid products would be 

negligibly small. 

Since the C>20 liquid and C>20 chlorinated paraffins use a carbon feedstock that centres 

around C24 or C25, these would not be expected to contain significant quantities of 

chlorinated paraffins with carbon chain lengths shorter than C20. 

Based on the estimated regional and continental releases of C18–20 liquid chlorinated 

paraffin, the amounts of C16–17 chlorinated paraffin released are shown in Table 5.10. 

Table 5.10 Estimated amounts of C16–17 chlorinated paraffin released to the 

environment 

Compartment Regional release Continental release 

Air 1,160–1,616 kg/year 10,439–14,542 kg/year 

Waste water 226–254 kg/year 2,033–2,288 kg/year 

Surface water 213–378 kg/year 1,922–3,398 kg/year 

Urban/industrial soil 351–808 kg/year 3,160–7,275 kg/year 

These releases could add to the environmental burden of C16–17 chlorinated paraffin 

that arises from medium-chain chlorinated paraffins, and are being considered further 

in the assessment of that substance. 

In terms of the risk assessment of the LCCPs, the risk from the C16–17 chlorinated 

paraffin impurities in the products should already be accounted for in the risk 

characterisation, since the assessment is based, in the main, on data obtained using 

the commercial product (which will contain the impurity). This will certainly be the case 

for secondary poisoning, where the PNEC is currently based on data on the mediumchain chlorinated paraffins in any case. 

For surface water, the PNEC derived in the medium-chain chlorinated paraffins risk 

assessment is currently 1 μg/l (ECB, 2005a). This is slightly lower than the PNEC used 

here for the C18–20 liquid products (PNEC 2.9 μg/l). 

In the case of sediment and soil, the PNECs for C18–20 liquid chlorinated paraffins used 

in this assessment (5,710 mg/kg wet weight and 4,640 mg/kg wet weight for sediment 

and soil, respectively) are considerably higher than those currently derived for mediumchain chlorinated paraffins (5 mg/kg wet weight and 10.6 mg/kg wet weight, 

respectively) based on actual toxicity tests on sediment and soil organisms. 

In order to investigate the possible effects of the C16–17 impurities further, PEC/PNEC 

ratios have been derived for this impurity assuming that it behaves in an identical 
264 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

fashion in terms of environmental fate, behaviour and toxicity as the medium-chain 

chlorinated paraffins. The results of this analysis are given in Appendix G. 

It should be noted that this approach assumes, in particular, that all the toxicity seen 

with the medium-chain chlorinated paraffins is due mainly to the C17 component. This is 

not likely to be the case as there is a general trend that the chlorinated paraffins 

become less toxic and bioavailable with increasing carbon chain length. Thus, although 

this “worst case” approach can be used to identify situations where no risk exists, a 

PEC/PNEC >1 does not necessarily mean that an actual risk exists, rather that more 

information may be necessary to specifically address the effects of the impurities 

further.

This analysis indicated that possible risks to surface water, sediment and soil could 

occur from LCCPs in some applications of the substance. No risks from secondary 

poisoning from the fish food chain were identified, but a possible risk from all uses was 

found for the earthworm food chain. This indicates that the applicability of the PNEC 

derived for medium-chain chlorinated paraffins to the C16–17 impurities present in the 

C18–20 liquid chlorinated paraffins should be considered further. 

5.7.2 Waste disposal 

Similar to chlorinated compounds in general, chlorinated paraffins can act as a source 

of chlorine during incineration processes. This chlorine can then lead to the formation 

of polychlorinated dioxins and furans – a well known problem associated with 

incineration. 

In most cases, controls are already in place on incinerators to minimise the formation of 

these dioxins and furans, and so the presence of the chlorinated paraffins should not 

lead to increased emissions. However, other processes involving chlorinated paraffins 

may not be so well controlled. One specific example is when metal swarf from metal 

cutting is re-melted. In this case the swarf may contain metalworking/cutting fluids 

containing chlorinated paraffins which could theoretically contribute to the formation of 

chlorinated dioxins and furans in the process. There is insufficient information available 

on this issue to make an assessment of the significance this processes in terms of a 

risk for the environment. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 265

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Glossary Of Terms 

Term Description 

Biochemical oxygen 

demand (BOD) 

A measure of degradation potential.. 

Bioconcentration factor 

(BCF) 

A measure of chemical uptake, being the ratio between 

the concentration in an organism and the concentration in 

an environmental compartment (usually water). 

CAS number (no.) An identifying code number assigned to chemicals by the 

Chemical Abstract Services. The CAS number is a 

generally recognised identification reference for a 

chemical; it is possible that a substance can have more 

than one such number. 

Lowest observed adverse 

effect level (LOAEL) 

The lowest concentration in a mammalian toxicity test that 

does gives rise to adverse effects (relative to a control). 

Lowest observed effect 

concentration (LOEC) 

The lowest concentration in a toxicity test that gives rise to 

adverse effects (relative to a control). 

Median effective 

concentration (EC50) 

The concentration in a toxicity test at which a particular 

effect is observed in half of the organisms exposed for a 

specified time. 

Median lethal 

concentration/dose 

(LC/D50) 

The concentration in a toxicity test that can be expected to 

cause death in half of the organisms exposed for a 

specified time. 

No observed adverse 

effect level (NOAEL) 

The highest concentration in a mammalian toxicity test 

that does not give rise to adverse effects (relative to a 

control). 

No observed effect 

concentration (NOEC) 

The highest concentration in a toxicity test that does not 

give rise to adverse effects (relative to a control). 

Octanol-water partition 

coefficient (Kow) 

This parameter gives an indication of the partitioning 

behaviour of a substance between water and lipidcontaining materials such as cell membranes or organic 

matter in soils and sediments. 

Readily biodegradable Rapid environmental degradation to carbon dioxide and 

water, etc., as measured by laboratory screening tests 

involving micro-organisms 

 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 275

Abbreviations 

Acronym Description 

ABS Acrylonitrile butadiene styrene copolymer 

AChE Acetylcholinesterase 

AF Assessment factor 

ASTM American Society for Testing and Materials 

BACS British Association for Chemical Specialities 

BAF Bioaccumulation factor 

BCF Bioconcentration factor 

BMF Biomagnification factor 

BOD Biochemical oxygen demand 

bw Body weight (also Bw, b.w.) 

CAS Chemical Abstract Services 

CEFIC European Chemical Industry Council 

CEPAD Conseil Européen des Phénols Alkylés et Derivés (the European Council 

for Alkylphenols and Derivatives): a trade association representing the 

major European producers of alkylphenols, and some of the users 

(http://www.cefic.be/cepad/) 

CMR Carcinogenic, mutagenic and toxic to reproduction 

CNS Central nervous system 

COD Chemical oxygen demand 

CSTEE Scientific Committee for Toxicity, Ecotoxicity and the Environment (DG 

SANCO) 

Defra Department of the Environment, Food and Rural Affairs 

DETR Department of the Environment, Transport and the Regions 

DIN Deutsche Industrie Norm (German norm) 

dw Dry weight 

EAA European Adjuvants Association 
276 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Acronym Description 

EC European Communities 

EC10 Effect concentration measured as 10% effect 

EC50 Median effect concentration 

ECB European Chemicals Bureau 

ECx As EC50, but for x% effect; x usually being 0, 10, or 100 

EDMAR Endocrine disruption in the marine environment 

EDTA Endocrine disruption testing and assessment 

EEC European Economic Communities 

EINECS European Inventory of Existing Commercial Chemical Substances – this 

lists all chemical substances that were supplied to the market prior to 18th 

September 1981 

EN European Norm 

EOSCA European Oilfield Speciality Chemicals Association 

EPA Environmental Protection Agency (USA) 

EQS Environmental quality standard 

ESD Emission Scenario Document 

ESIS European Chemical Substances Information System 

ESR The Existing Substances Regulation – Council Regulation (EEC) 793/93 

on the evaluation and control of the risks of ‘existing’ substances 

EU European Union 

EU-15 The 15 European Union Member States prior to May 2004 

EUSES European Union System for the Evaluation of Substances (software tool 

in support of the TGD on risk assessment) 

FAF Food accumulation factor 

GLP Good laboratory practice 

GSI Gonadosomatic index 

HLC Henry’s Law constant 

HPLC High pressure liquid chromatography 

HPV High production volume (supply > 1000 tonnes/year) 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 277

Acronym Description 

HPVC High production volume chemical (supply > 1000 tonnes/year) 

HSDB Hazardous Substances Data Bank 

HSI Hepatosomatic index 

IC Industrial category 

IC50 Median immobilisation concentration or median inhibitory concentration 

IPC Integrated pollution control 

IPCS International Programme on Chemical Safety 

IPPC Integrated Pollution Prevention and Control (EC Directive 96/61/EEC) 

ISO International Organisation for Standardisation 

IUCLID International Uniform Chemical Information Database: contains data 

collected under the Existing Substances Regulation (ESR) 

IUPAC International Union for Pure and Applied Chemistry 

Koc Organic carbon normalised distribution coefficient 

Kow Octanol-water partition coefficient 

Kp Solids-water partition coefficient 

Kplant-water Partition coefficient between plant tissues and water 

Ksusp-water Partition coefficient between suspended sediment and water 

Ksoil-water Partition coefficient between soil and water 

L(E)C50 Median lethal (effect) concentration 

LD50 Median lethal dose 

LDPE Low density polyethylene 

LOAEL Lowest observed adverse effect level 

LOEC Lowest observed effect concentration 

LOEL Lowest observed effect level 

log Kow Log of the octanol-water partition coefficient (Kow) 

LPV Low production volume (supply 10-1,000 tonnes/year) 

LPVC Low production volume chemical (supply 10-1,000 tonnes/year) 
278 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Acronym Description 

LQ Quantification limit 

MBS Methyl methacrylate butadiene styrene terpolymer 

MITI Ministry of International Trade and Industry, Japan 

MOS Margin of safety 

N Dangerous for the environment (Symbols and indications of danger for 

dangerous substances and preparations according to Annex III of 

Directive 67/548/EEC 

n.t.p. Normal temperature and pressure 

NO(A)EL No observed (adverse) effect level 

NOEC No observed effect concentration 

OECD Organisation for Economic Cooperation and Development 

OSI Ovarian somatic index 

OSPAR Oslo and Paris Convention for the protection of the marine environment of 

the Northeast Atlantic, http://www.ospar.org 

P Persistent 

PBT Persistent, bioaccumulative and toxic 

PEC Predicted environmental concentration 

pH Logarithm (to the base 10) of the hydrogen ion concentration [H+] 

pKa Logarithm (to the base 10) of the acid dissociation constant 

PNEC Predicted no effect concentration 

PP Polypropylene 

ppb Parts per billion 

ppm Parts per million 

PVC Polyvinyl chloride 

(Q)SAR (Quantitative) structure-activity relationship 

RBA Relative binding affinity 

RCR Risk characterisation ratio 

SEPA Scottish Environmental Protection Agency 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 279

Acronym Description 

SETAC Society of Environmental Toxicology And Chemistry 

SIAR SIDS Initial Assessment Report, OECD 

SIDS Screening Information Dataset, OECD 

SMILES Simplified Molecular Input Line Entry System – the SMILES code is a 

chemical notation system used to represent a molecular structure by a 

linear string of symbols; it is a simple way of entering chemical structural 

information into a computer programme 

SRC Syracuse Research Corporation 

STP Sewage treatment plant 

STW Sewage treatment works 

TG Test guideline 

TGD Technical Guidance Document 

UBA Umweltbundesamt (Federal Environment Protection Agency in Austria 

and Germany) 

UGPLI Urogenital pupilla length index 

US EPA Environmental Protection Agency, USA 

UV Ultraviolet region of the electromagnetic spectrum 

vB Very bioaccumulative 

vP Very persistent 

vPvB Very persistent and very bioaccumulative 

WAF Water accommodated fraction 

w/v Weight per volume ratio 

w/w Weight per weight ratio 

wt Weight 

wwt Wet weight 

WWTP Wastewater treatment plant 
280 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Appendix A EUSES modelling 

This appendix contains reference to copies of the EUSES printout files for long-chain 

chlorinated paraffins (LCCPs). The EUSES modelling has been carried out separately 

for the three main types of LCCP considered in the assessment. The EUSES printout 

for C18–20 liquid chlorinated paraffins , C>20 liquid chlorinated, C>20 solid chlorinated 

paraffins are available from the Environment Agency. Please contact - e-mail: 

ukesrenv@environment-agency.gov.uk

A1 C18–20 liquid chlorinated paraffins 

The results from the following scenarios from the main report are included in the 

printout. 

EUSES Printout Scenario

USE PATTERN 1 Production 

production generic production site 

USE PATTERN 2 Use in PVC – plastisol coating 

formulation compounding site – open system 

industrial use conversion site – open system 

private use combined compounding/conversion site – open system 

USE PATTERN 3 Use in PVC – extrusion/other – open system 

formulation compounding site – open system 

industrial use conversion site – open system 

private use combined compounding/conversion site – open system 

USE PATTERN 4 Use in PVC – extrusion/other – partially open system 

formulation compounding site – partially open system 

industrial use conversion site – partially open system 

private use combined compounding/conversion site – partially open 

system 

USE PATTERN 5 Use in PVC – extrusion other – closed system 

formulation compounding site – closed system 

industrial use conversion site – closed system 

private use combined compounding/conversion site – closed system 

USE PATTERN 6 Use in paints and varnishes 

formulation formulation site 

industrial use industrial application of paints 

USE PATTERN 7 Use in metal cutting/working fluids 

formulation formulation site 

industrial use use in oil-based fluids (small site; 5% LCCP content) 

private use use in oil-based fluids (small site; 10% LCCP content) 

service life use in emulsifiable fluids 

waste treatment use in emulsifiable fluids – intermittent release 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 281

USE PATTERN 8 Use in leather fat liquors 

formulation formulation site (default calculation) 

industrial use use – complete processing of raw hides 

private use use – processing of “wet blue” 

waste treatment formulation site (industry-specific calculation) 

USE PATTERN 9 Use in textiles 

industrial use textile treatment site 

The EUSES file for C18–20 liquid chlorinated paraffins is available from the Environment 

Agency. Please contact - e-mail: ukesrenv@environment-agency.gov.uk

A2 C>20 liquid chlorinated paraffins 

The results for the following scenarios from the main report are included in the printout: 

EUSES Printout Scenario

USE PATTERN 1 Production 

production generic production site 

USE PATTERN 2 Use in rubber 

Industrial use combined compounding/conversion site 

USE PATTERN 3 Use in paints and varnishes 

formulation formulation site 

industrial use industrial application of paints 

USE PATTERN 4 Use in metal cutting/working fluids – oil based 

formulation formulation site 

industrial use use in oil-based fluids (large site; 5% LCCP content) 

private use use in oil-based fluids (large site; 10% LCCP content) 

service life use in oil-based fluids (small site; 5% LCCP content) 

waste treatment use in oil-based fluids (small site; 10% LCCP content) 

USE PATTERN 5 Use in metal cutting/working fluids – water based 

industrial use use in emulsifiable fluids 

waste treatment use in emulsifiable fluids – intermittent release 

USE PATTERN 6 Use in leather fat liquors 

formulation formulation site (default calculation) 

industrial use use – complete processing of raw hides 

private use use – processing of “wet blue” 

waste treatment formulation site (industry-specific calculation) 

The EUSES file for C>20 liquid chlorinated paraffins is is available from the Environment 

Agency. Please contact - e-mail: ukesrenv@environment-agency.gov.uk. 

A3 C>20 solid chlorinated paraffins 

The results from the following scenarios from the main report are included in the 

printout. 
282 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

EUSES Printout Scenario

USE PATTERN 1 Production 

production generic production site 

USE PATTERN 2 Use in rubber 

industrial use combined compounding/conversion site 

USE PATTERN 3 Use in paints and varnishes 

formulation formulation site 

industrial use industrial application of paints 

The EUSES file for C>20 solid chlorinated paraffins is available from the Environment 

Agency. Please contact - e-mail: ukesrenv@environment-agency.gov.uk 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 283

Appendix B Estimated vapour 

pressure of LCCPs 

The vapour pressure has been estimated for LCCPs using the following equation 

derived for short-chain chlorinated paraffins: 

log (vapour pressure) = -(0.353 x no. of C atoms) - (0.645x no. of Cl atoms) + 4.462 

where vapour pressure is in Pa at 25°C. 

Taken from: Drouillard K G, Tomy G T, Muir D C G and Friesen K J Volatility of 

chlorinated n-alkanes (C10-C12): Vapour pressures and Henry's Law constants. 

Environmental Toxicology and Chemistry, 17, 1998, 1252-1260. 

Table B1 Estimated vapour pressure for LCCPs (C18–C30) 

No of 

carbons 

No of 

chlorines 

No of 

hydrogens 

Molecular 

weight 

(g/mole) 

Chorine 

content 

(by weight) 

Estimated 

vapour 

pressure (Pa) 

18 1 37 288.5 12.3% 2.90E-03 

18 2 36 323 22.0% 6.58E-04 

18 3 35 357.5 29.8% 1.49E-04 

18 4 34 392 36.2% 3.37E-05 

18 5 33 426.5 41.6% 7.64E-06 

18 6 32 461 46.2% 1.73E-06 

18 7 31 495.5 50.2% 3.92E-07 

18 8 30 530 53.6% 8.87E-08 

18 9 29 564.5 56.6% 2.01E-08 

18 10 28 599 59.3% 4.55E-09 

18 11 27 633.5 61.6% 1.03E-09 

18 12 26 668 63.8% 2.33E-10 

18 13 25 702.5 65.7% 5.28E-11 

18 14 24 737 67.4% 1.20E-11 

18 15 23 771.5 69.0% 2.71E-12 

18 16 22 806 70.5% 6.14E-13 

18 17 21 840.5 71.8% 1.39E-13 

19 1 39 302.5 11.7% 1.29E-03 

19 2 38 337 21.1% 2.92E-04 

19 3 37 371.5 28.7% 6.61E-05 

19 4 36 406 35.0% 1.50E-05 

19 5 35 440.5 40.3% 3.39E-06 

19 6 34 475 44.8% 7.67E-07 

19 7 33 509.5 48.8% 1.74E-07 

19 8 32 544 52.2% 3.94E-08 

19 9 31 578.5 55.2% 8.91E-09 

19 10 30 613 57.9% 2.02E-09 

19 11 29 647.5 60.3% 4.57E-10 

19 12 28 682 62.5% 1.04E-10 

19 13 27 716.5 64.4% 2.34E-11 

19 14 26 751 66.2% 5.31E-12 
284 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

No of 

carbons 

No of 

chlorines 

No of 

hydrogens 

Molecular 

weight 

(g/mole) 

Chorine 

content 

(by weight) 

Estimated 

vapour 

pressure (Pa) 

19 15 25 785.5 67.8% 1.20E-12 

19 16 24 820 69.3% 2.72E-13 

19 17 23 854.5 70.6% 6.17E-14 

19 18 22 889 71.9% 1.40E-14 

20 1 41 316.5 11.2% 5.71E-04 

20 2 40 351 20.2% 1.29E-04 

20 3 39 385.5 27.6% 2.93E-05 

20 4 38 420 33.8% 6.64E-06 

20 5 37 454.5 39.1% 1.50E-06 

20 6 36 489 43.6% 3.40E-07 

20 7 35 523.5 47.5% 7.71E-08 

20 8 34 558 50.9% 1.75E-08 

20 9 33 592.5 53.9% 3.95E-09 

20 10 32 627 56.6% 8.95E-10 

20 11 31 661.5 59.0% 2.03E-10 

20 12 30 696 61.2% 4.59E-11 

20 13 29 730.5 63.2% 1.04E-11 

20 14 28 765 65.0% 2.36E-12 

20 15 27 799.5 66.6% 5.33E-13 

20 16 26 834 68.1% 1.21E-13 

20 17 25 868.5 69.5% 2.74E-14 

20 18 24 903 70.8% 6.19E-15 

20 19 23 937.5 71.9% 1.40E-15 

20 20 22 972 73.0% 3.18E-16 

21 1 43 330.5 10.7% 2.54E-04 

21 2 42 365 19.5% 5.74E-05 

21 3 41 399.5 26.7% 1.30E-05 

21 4 40 434 32.7% 2.94E-06 

21 5 39 468.5 37.9% 6.67E-07 

21 6 38 503 42.3% 1.51E-07 

21 7 37 537.5 46.2% 3.42E-08 

21 8 36 572 49.7% 7.74E-09 

21 9 35 606.5 52.7% 1.75E-09 

21 10 34 641 55.4% 3.97E-10 

21 11 33 675.5 57.8% 8.99E-11 

21 12 32 710 60.0% 2.04E-11 

21 13 31 744.5 62.0% 4.61E-12 

21 14 30 779 63.8% 1.04E-12 

21 15 29 813.5 65.5% 2.37E-13 

21 16 28 848 67.0% 5.36E-14 

21 17 27 882.5 68.4% 1.21E-14 

21 18 26 917 69.7% 2.75E-15 

21 19 25 951.5 70.9% 6.22E-16 

21 20 24 986 72.0% 1.41E-16 

21 21 23 1020.5 73.1% 3.19E-17 

22 1 45 344.5 10.3% 1.12E-04 

22 2 44 379 18.7% 2.55E-05 

22 3 43 413.5 25.8% 5.77E-06 

22 4 42 448 31.7% 1.31E-06 

22 5 41 482.5 36.8% 2.96E-07 

22 6 40 517 41.2% 6.70E-08 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 285

No of 

carbons 

No of 

chlorines 

No of 

hydrogens 

Molecular 

weight 

(g/mole) 

Chorine 

content 

(by weight) 

Estimated 

vapour 

pressure (Pa) 

22 7 39 551.5 45.1% 1.52E-08 

22 8 38 586 48.5% 3.44E-09 

22 9 37 620.5 51.5% 7.78E-10 

22 10 36 655 54.2% 1.76E-10 

22 11 35 689.5 56.6% 3.99E-11 

22 12 34 724 58.8% 9.04E-12 

22 13 33 758.5 60.8% 2.05E-12 

22 14 32 793 62.7% 4.63E-13 

22 15 31 827.5 64.4% 1.05E-13 

22 16 30 862 65.9% 2.38E-14 

22 17 29 896.5 67.3% 5.38E-15 

22 18 28 931 68.6% 1.22E-15 

22 19 27 965.5 69.9% 2.76E-16 

22 20 26 1000 71.0% 6.25E-17 

22 21 25 1034.5 72.1% 1.42E-17 

22 22 24 1069 73.1% 3.21E-18 

23 1 47 358.5 9.9% 4.99E-05 

23 2 46 393 18.1% 1.13E-05 

23 3 45 427.5 24.9% 2.56E-06 

23 4 44 462 30.7% 5.79E-07 

23 5 43 496.5 35.8% 1.31E-07 

23 6 42 531 40.1% 2.97E-08 

23 7 41 565.5 43.9% 6.73E-09 

23 8 40 600 47.3% 1.52E-09 

23 9 39 634.5 50.4% 3.45E-10 

23 10 38 669 53.1% 7.82E-11 

23 11 37 703.5 55.5% 1.77E-11 

23 12 36 738 57.7% 4.01E-12 

23 13 35 772.5 59.7% 9.08E-13 

23 14 34 807 61.6% 2.06E-13 

23 15 33 841.5 63.3% 4.66E-14 

23 16 32 876 64.8% 1.05E-14 

23 17 31 910.5 66.3% 2.39E-15 

23 18 30 945 67.6% 5.41E-16 

23 19 29 979.5 68.9% 1.22E-16 

23 20 28 1014 70.0% 2.77E-17 

23 21 27 1048.5 71.1% 6.28E-18 

23 22 26 1083 72.1% 1.42E-18 

23 23 25 1117.5 73.1% 3.22E-19 

24 1 49 372.5 9.5% 2.21E-05 

24 2 48 407 17.4% 5.01E-06 

24 3 47 441.5 24.1% 1.14E-06 

24 4 46 476 29.8% 2.57E-07 

24 5 45 510.5 34.8% 5.82E-08 

24 6 44 545 39.1% 1.32E-08 

24 7 43 579.5 42.9% 2.99E-09 

24 8 42 614 46.3% 6.76E-10 

24 9 41 648.5 49.3% 1.53E-10 

24 10 40 683 52.0% 3.47E-11 

24 11 39 717.5 54.4% 7.85E-12 

24 12 38 752 56.6% 1.78E-12 
286 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

No of 

carbons 

No of 

chlorines 

No of 

hydrogens 

Molecular 

weight 

(g/mole) 

Chorine 

content 

(by weight) 

Estimated 

vapour 

pressure (Pa) 

24 13 37 786.5 58.7% 4.03E-13 

24 14 36 821 60.5% 9.12E-14 

24 15 35 855.5 62.2% 2.07E-14 

24 16 34 890 63.8% 4.68E-15 

24 17 33 924.5 65.3% 1.06E-15 

24 18 32 959 66.6% 2.40E-16 

24 19 31 993.5 67.9% 5.43E-17 

24 20 30 1028 69.1% 1.23E-17 

24 21 29 1062.5 70.2% 2.79E-18 

24 22 28 1097 71.2% 6.31E-19 

24 23 27 1131.5 72.2% 1.43E-19 

24 24 26 1166 73.1% 3.24E-20 

25 1 51 386.5 9.2% 9.82E-06 

25 2 50 421 16.9% 2.22E-06 

25 3 49 455.5 23.4% 5.04E-07 

25 4 48 490 29.0% 1.14E-07 

25 5 47 524.5 33.8% 2.58E-08 

25 6 46 559 38.1% 5.85E-09 

25 7 45 593.5 41.9% 1.32E-09 

25 8 44 628 45.2% 3.00E-10 

25 9 43 662.5 48.2% 6.79E-11 

25 10 42 697 50.9% 1.54E-11 

25 11 41 731.5 53.4% 3.48E-12 

25 12 40 766 55.6% 7.89E-13 

25 13 39 800.5 57.7% 1.79E-13 

25 14 38 835 59.5% 4.05E-14 

25 15 37 869.5 61.2% 9.16E-15 

25 16 36 904 62.8% 2.07E-15 

25 17 35 938.5 64.3% 4.70E-16 

25 18 34 973 65.7% 1.06E-16 

25 19 33 1007.5 66.9% 2.41E-17 

25 20 32 1042 68.1% 5.46E-18 

25 21 31 1076.5 69.3% 1.24E-18 

25 22 30 1111 70.3% 2.80E-19 

25 23 29 1145.5 71.3% 6.34E-20 

25 24 28 1180 72.2% 1.44E-20 

25 25 27 1214.5 73.1% 3.25E-21 

26 1 53 400.5 8.9% 4.36E-06 

26 2 52 435 16.3% 9.86E-07 

26 3 51 469.5 22.7% 2.23E-07 

26 4 50 504 28.2% 5.06E-08 

26 5 49 538.5 33.0% 1.15E-08 

26 6 48 573 37.2% 2.59E-09 

26 7 47 607.5 40.9% 5.87E-10 

26 8 46 642 44.2% 1.33E-10 

26 9 45 676.5 47.2% 3.01E-11 

26 10 44 711 49.9% 6.82E-12 

26 11 43 745.5 52.4% 1.55E-12 

26 12 42 780 54.6% 3.50E-13 

26 13 41 814.5 56.7% 7.93E-14 

26 14 40 849 58.5% 1.79E-14 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 287

No of 

carbons 

No of 

chlorines 

No of 

hydrogens 

Molecular 

weight 

(g/mole) 

Chorine 

content 

(by weight) 

Estimated 

vapour 

pressure (Pa) 

26 15 39 883.5 60.3% 4.06E-15 

26 16 38 918 61.9% 9.20E-16 

26 17 37 952.5 63.4% 2.08E-16 

26 18 36 987 64.7% 4.72E-17 

26 19 35 1021.5 66.0% 1.07E-17 

26 20 34 1056 67.2% 2.42E-18 

26 21 33 1090.5 68.4% 5.48E-19 

26 22 32 1125 69.4% 1.24E-19 

26 23 31 1159.5 70.4% 2.81E-20 

26 24 30 1194 71.4% 6.37E-21 

26 25 29 1228.5 72.2% 1.44E-21 

26 26 28 1263 73.1% 3.27E-22 

27 1 55 414.5 8.6% 1.93E-06 

27 2 54 449 15.8% 4.38E-07 

27 3 53 483.5 22.0% 9.91E-08 

27 4 52 518 27.4% 2.24E-08 

27 5 51 552.5 32.1% 5.08E-09 

27 6 50 587 36.3% 1.15E-09 

27 7 49 621.5 40.0% 2.61E-10 

27 8 48 656 43.3% 5.90E-11 

27 9 47 690.5 46.3% 1.34E-11 

27 10 46 725 49.0% 3.03E-12 

27 11 45 759.5 51.4% 6.85E-13 

27 12 44 794 53.7% 1.55E-13 

27 13 43 828.5 55.7% 3.52E-14 

27 14 42 863 57.6% 7.96E-15 

27 15 41 897.5 59.3% 1.80E-15 

27 16 40 932 60.9% 4.08E-16 

27 17 39 966.5 62.4% 9.25E-17 

27 18 38 1001 63.8% 2.09E-17 

27 19 37 1035.5 65.1% 4.74E-18 

27 20 36 1070 66.4% 1.07E-18 

27 21 35 1104.5 67.5% 2.43E-19 

27 22 34 1139 68.6% 5.51E-20 

27 23 33 1173.5 69.6% 1.25E-20 

27 24 32 1208 70.5% 2.82E-21 

27 25 31 1242.5 71.4% 6.40E-22 

27 26 30 1277 72.3% 1.45E-22 

27 27 29 1311.5 73.1% 3.28E-23 

28 1 57 428.5 8.3% 8.57E-07 

28 2 56 463 15.3% 1.94E-07 

28 3 55 497.5 21.4% 4.40E-08 

28 4 54 532 26.7% 9.95E-09 

28 5 53 566.5 31.3% 2.25E-09 

28 6 52 601 35.4% 5.11E-10 

28 7 51 635.5 39.1% 1.16E-10 

28 8 50 670 42.4% 2.62E-11 

28 9 49 704.5 45.4% 5.93E-12 

28 10 48 739 48.0% 1.34E-12 

28 11 47 773.5 50.5% 3.04E-13 

28 12 46 808 52.7% 6.89E-14 
288 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

No of 

carbons 

No of 

chlorines 

No of 

hydrogens 

Molecular 

weight 

(g/mole) 

Chorine 

content 

(by weight) 

Estimated 

vapour 

pressure (Pa) 

28 13 45 842.5 54.8% 1.56E-14 

28 14 44 877 56.7% 3.53E-15 

28 15 43 911.5 58.4% 8.00E-16 

28 16 42 946 60.0% 1.81E-16 

28 17 41 980.5 61.6% 4.10E-17 

28 18 40 1015 63.0% 9.29E-18 

28 19 39 1049.5 64.3% 2.10E-18 

28 20 38 1084 65.5% 4.76E-19 

28 21 37 1118.5 66.7% 1.08E-19 

28 22 36 1153 67.7% 2.44E-20 

28 23 35 1187.5 68.8% 5.53E-21 

28 24 34 1222 69.7% 1.25E-21 

28 25 33 1256.5 70.6% 2.84E-22 

28 26 32 1291 71.5% 6.43E-23 

28 27 31 1325.5 72.3% 1.46E-23 

28 28 30 1360 73.1% 3.30E-24 

29 1 59 442.5 8.0% 3.80E-07 

29 2 58 477 14.9% 8.61E-08 

29 3 57 511.5 20.8% 1.95E-08 

29 4 56 546 26.0% 4.42E-09 

29 5 55 580.5 30.6% 1.00E-09 

29 6 54 615 34.6% 2.26E-10 

29 7 53 649.5 38.3% 5.13E-11 

29 8 52 684 41.5% 1.16E-11 

29 9 51 718.5 44.5% 2.63E-12 

29 10 50 753 47.1% 5.96E-13 

29 11 49 787.5 49.6% 1.35E-13 

29 12 48 822 51.8% 3.05E-14 

29 13 47 856.5 53.9% 6.92E-15 

29 14 46 891 55.8% 1.57E-15 

29 15 45 925.5 57.5% 3.55E-16 

29 16 44 960 59.2% 8.04E-17 

29 17 43 994.5 60.7% 1.82E-17 

29 18 42 1029 62.1% 4.12E-18 

29 19 41 1063.5 63.4% 9.33E-19 

29 20 40 1098 64.7% 2.11E-19 

29 21 39 1132.5 65.8% 4.79E-20 

29 22 38 1167 66.9% 1.08E-20 

29 23 37 1201.5 68.0% 2.45E-21 

29 24 36 1236 68.9% 5.56E-22 

29 25 35 1270.5 69.9% 1.26E-22 

29 26 34 1305 70.7% 2.85E-23 

29 27 33 1339.5 71.6% 6.46E-24 

29 28 32 1374 72.3% 1.46E-24 

29 29 31 1408.5 73.1% 3.31E-25 

30 1 61 456.5 7.8% 1.69E-07 

30 2 60 491 14.5% 3.82E-08 

30 3 59 525.5 20.3% 8.65E-09 

30 4 58 560 25.4% 1.96E-09 

30 5 57 594.5 29.9% 4.44E-10 

30 6 56 629 33.9% 1.00E-10 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 289

No of 

carbons 

No of 

chlorines 

No of 

hydrogens 

Molecular 

weight 

(g/mole) 

Chorine 

content 

(by weight) 

Estimated 

vapour 

pressure (Pa) 

30 7 55 663.5 37.5% 2.28E-11 

30 8 54 698 40.7% 5.15E-12 

30 9 53 732.5 43.6% 1.17E-12 

30 10 52 767 46.3% 2.64E-13 

30 11 51 801.5 48.7% 5.98E-14 

30 12 50 836 51.0% 1.36E-14 

30 13 49 870.5 53.0% 3.07E-15 

30 14 48 905 54.9% 6.95E-16 

30 15 47 939.5 56.7% 1.57E-16 

30 16 46 974 58.3% 3.56E-17 

30 17 45 1008.5 59.8% 8.07E-18 

30 18 44 1043 61.3% 1.83E-18 

30 19 43 1077.5 62.6% 4.14E-19 

30 20 42 1112 63.8% 9.38E-20 

30 21 41 1146.5 65.0% 2.12E-20 

30 22 40 1181 66.1% 4.81E-21 

30 23 39 1215.5 67.2% 1.09E-21 

30 24 38 1250 68.2% 2.47E-22 

30 25 37 1284.5 69.1% 5.58E-23 

30 26 36 1319 70.0% 1.26E-23 

30 27 35 1353.5 70.8% 2.86E-24 

30 28 34 1388 71.6% 6.49E-25 

30 29 33 1422.5 72.4% 1.47E-25 

30 30 32 1457 73.1% 3.33E-26 
290 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Appendix C Generic level III 

fugacity modelling 

The potential environmental distribution of LCCPs has been studied using a generic 

level III fugacity model. The level III model used was a four compartment model (EQC 

Model version 1.01, May 1997) similar to that recommended for use within the OECD 

HPV program. The model was run using the default settings in the model and the 

chemical specific input data shown in Table C1. 

Table C1 Properties of LCCPs used in fugacity modelling 

Property Value 

 C18–20 liquid 

chlorinated 

paraffin 

C>20 liquid 

chlorinated 

paraffin 

C>20 solid chlorinated 

paraffin 

Molecular weight 456 g/mole 

(corresponding to 

C19, 50% wt. Cl) 

600 g/mole 

(corresponding to 

C24, 52% wt. Cl) 

960 g/mole 

(corresponding to C24, 

70% wt. Cl) 

Water solubility 5 μg/l 5 μg/l 5 μg/l 

Vapour pressure 2.5×10-4 Pa 2.5×10-5 Pa 1.5×10-14 Pa 

Log Kow 9.7 10.3 17 

Degradation halflife in air 30 hours 25 hours 110 hours 

Degradation halflife in other media

 

very large (e.g. 

1×1011 hours) 

very large (e.g. 

1×1011 hours) 

very large (e.g. 1×1011

hours) 

The level III model was run four times for each group of LCCPs, with a nominal release 

rate of 1,000 kg/hour initially entering the air, soil or water compartments in different 

proportions. The following diagrams show the predicted environmental distributions. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 291
292 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 293
294 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 295
296 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 297

Appendix D Analytical methods 

used to determine LCCP in 

environmental media 

Several studies have been undertaken to measure the levels of chlorinated paraffins in 

water and sediment. However, the analyses are complicated by the fact that there are 

a wide range of possible chlorinated paraffins (of different carbon chain length, degrees 

of chlorination and position of the chlorine atoms along the carbon chain) present in 

any given commercial product. Thus, care has to be taken when comparing the results 

of one survey with those of another, since different reference compounds may have 

been used and hence different chemical species may have been measured. The main 

analytical methods used for determining the concentrations of LCCPs in environmental 

samples are discussed in the following paragraphs. The methods have been referred to 

by the author names that appear in the sections on environmental levels in the main 

part of the report. The results from all the methods used are dependent to some extent 

on the substance(s) used as reference. 

Campbell and McConnell, 1980 

This method combines solvent extraction/partition, column chromatography and finally 

TLC with argentation. Quantitation is by visual comparison of the intensity of the TLC 

‘spot’ with those from standards. The intensity of the spot is chlorine dependent and so, 

in order to err on the high side of the possible concentration, low chlorine content 

paraffin e.g. 42–45% wt Cl, is used as reference for calibration. The method is 

relatively insensitive to chemical structure and can reportedly distinguish between C10-

20 chlorinated paraffins and C20–30 chlorinated paraffins. This method, therefore, is likely 

to quantify all LCCPs present in a sample, but may overestimate the concentration, 

particularly of the C18–20 chlorinated paraffins, due to interferences with other types of 

chlorinated paraffin. 

Murray et al., 1987a and 1987b

This method is based on a gas chromatography/mass spectrometry (GC-MS) method 

using negative chemical ionisation (NCI). The analysis is carried out by monitoring 

selected mass ranges of the mass spectrum for ions indicative of chlorinated paraffins. 

The mass ranges scanned for LCCPs are 496–506 and 512–517 amu. The commercial 

product, Paroil 142 (C20–30, 40–50% Cl), was used as reference material. This method 

is reasonably specific for LCCPs with carbon chain lengths >C20, but will only identify 

the components which give rise to ions in the mass spectrometer in the ranges 

scanned. 

Jansson et al., 1993 

This method is based on GC-MS with NCI. The method does not appear to distinguish 

between chlorinated paraffins of different chain length and uses Dechlorane as an 

internal standard and several unspecified commercial chlorinated paraffin products as 

reference compounds. The method can probably be considered to give an 

approximation of the concentration of total (i.e. short-, medium and long-chain length) 

chlorinated paraffins present in a sample. 
298 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Environment Agency Japan, 1991 

Very few experimental details are given. The technique is probably based on a GC-MS 

method, but no indication is given as to what types of chlorinated paraffin were 

measured. Again, the method can probably be considered to give an approximation of 

the concentration of total chlorinated paraffins present in a sample. 

Greenpeace, 1995 

This method uses on-column reduction of the chlorinated paraffin to the parent 

hydrocarbon, followed by GC-MS quantification of the parent hydrocarbon. A range of 

alkanes between C10 and C24 were used as external standards and an average chlorine 

content of 50 per cent was assumed for the chlorinated paraffins to allow quantification. 

This approach may slightly underestimate the chlorinated paraffin concentration if high 

chlorine content material is present. The method could apparently distinguish between 

individual chlorinated paraffins with different carbon chain lengths and should 

unambiguously identify the presence of LCCPs (C18 to C24), provided any interfering nparaffins are removed from the sample prior to analysis. 

Rieger and Ballschmiter, 1995 

Sample clean-up using a silica-gel column was employed. The commercial product 

Hordaflex LC 60 (C10-13, 62% Cl) was used as a calibration standard (as only peaks 

corresponding to C10-13 chlorinated paraffins were detected). Analysis was carried out 

using GC-ECD (electron capture detector) and GC-MS with negative chemical 

ionisation. The following masses were monitored in the analysis for LCCPs: m/z = 494, 

496 and 498 (C18H31Cl7); 508, 510 and 512 (C19H33Cl7). The method is similar to that 

used by Murray et al. (1987a and b). 

van Zeijl, 1997 

The chlorinated paraffin-containing extracts were fractionated using high performance 

liquid chromatography (HPLC) with gel permeation columns. The analysis was then 

carried out on the chlorinated paraffin fractions using GC-MS with electron capture 

negative ionisation. The following negative ion clusters were monitored in the analyses: 

m/z -35 and -37 (corresponding to Cl-

); m/z -70 and -72 (corresponding to Cl2

-

) and 

m/z -71 and -73 (corresponding to HCl2). There are few details of the compounds used 

for analytical standards. A range of technical products appears to have been studied 

and the product whose mass spectra resembled that of the sample most closely 

appears to have been used for quantification. This substance appears to have been a 

C22–26, 42% wt. Cl product as the majority of the chlorinated paraffins found were 

thought to be LCCPs. The report indicates that the choice of the reference compound 

was important as the detector responses were found to vary by about one order of 

magnitude between the various products studies. 

Rotard, 1998 and Kemmlein, 2002 

The analysis was carried out by dechlorination of the chlorinated paraffins in the 

injector of the gas chromatograph (the injector contained a palladium catalyst and a 

mixture of hydrogen and helium was used as carrier gas), followed by analysis of the nparaffins formed by mass-spectrometry detector. Quantification was achieved using nalkane standards from C10 to C29. A 50 per cent chlorine content was assumed to 

convert the n-alkane concentrations measured to a concentration of chlorinated 

paraffin. 

The samples were extracted using n-hexane. After removal of lipids (where 

appropriate), the extracts were concentrated and chromatographed over superactive 

basic aluminium oxide with cyclopentane and then cyclopentane/ethylformate (3:7 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 299

mixture). The second fraction was collected, concentrated and subject to analysis. It is 

not clear if the sample clean-up method used removed potential interferences from nalkanes prior to the analysis. 

Froescheis, 1997 

Few details of the method used are currently available. 

Summary 

As can be seen from the above discussion, there are potential problems with all the 

methods used. Most of the methods are likely to provide a rough estimate of the 

concentration of LCCP, although some methods may not detect all the LCCPs present 

in a sample. The choice of the standard/reference compound used for quantification is 

important in these analysis, because if the composition of the reference compound is 

significantly different from that of the substance in the environment, then substantial 

errors could be introduced into the analysis and mis-identification of the type of 

chlorinated paraffin present could occur. Thus the analytical methods should all be 

treated as giving only approximate concentrations in environmental samples. 

References 

Campbell I. and McConnell G, 1980 Chlorinated paraffins and the environment. 1. 

Environmental Occurrence. Environmental Science and Technology, 9, 1209-1214. 

Environment Agency Japan, 1991 Chemicals in the Environment. Report on 

Environmental Survey and Wildlife Monitoring of Chemicals in F. Y. 1988 and 1989. 

Office of Health Studies, Department of Environmental Health, Environment Agency 

Japan. 

Froescheis O, 1997 Analytik und Vorkommen anthropogener schwerflüchtiger 

Organochlorverbindungen in marinen Organismen aus Oberflächen- und 

Tiefengewässern des Atlantischen und des Pazifischen Ozeans. Dissertation, 

University of Ulm, Department of Analytical Chemistry and Environmental Chemistry. 

As reported in OSPAR, 2000. 

Greenpeace, 1995 Greenpeace Zur Sache: Chlorparaffine. Greenpeace, May 1995. 

Jansson B, Andersson R, Asplund L, Litzén K, Sellström U, Uvemo U-B, Wahlberg C, 

Wideqvist U, Odsjö T and Olsson M, 1993 Chlorinated and brominated persistent 

organic compounds in biological samples from the environment. Environmental 

Toxicology and Chemistry, 12, 1163-1174. 

Kemmlein S, Hermeneit A and Rotard W, 2002 Carbon skeleton analysis of 

chloroparaffins in sediment, mussels and crabs. Organohalogen Compounds, 59, 279-

282. 

Murray T, Frankenberry M, Steele D H and Heath R G, 1987a Chlorinated paraffins: A 

report on the findings from two field studies, Sugar Creek, Ohio, Tinkers Creek, Ohio. 

Volume 1, Technical Report. United States Environmental Protection Agency Report 

EPA 560/5-87-012. 

Murray T, Frankenberry M, Steele D H and Heath R G, 1987b Chlorinated paraffins: A 

report on the findings from two field studies, Sugar Creek, Ohio, Tinkers Creek, Ohio. 

Volume 2. Appendix D. The Quality Assurance Project Plan. United States 

Environmental Protection Agency Report EPA 560/5-87-12. 
300 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

OSPAR, 2000 Draft OSPAR Background Document on Medium and Long-chained 

Chlorinated Paraffins. Oslo and Paris Commissions, 2000. 

Rieger R and Ballschmiter K, 1995 Semivolatile organic compounds - polychlorinated 

dibenzo-p-dioxins (PCDD), dibenzofurans (PCDF), biphenyls (PCB), 

hexachlorobenzene (HCB), 4,4’-DDE and chlorinated paraffins (CP) - as markers in 

sewer films. Fresenius Journal of Analytical Chemistry, 352, 715-724. 

Rotard W, Mailahn W, Kuhn S, Hermeneit A, Hildebrecht S, Kemmlein S and Mentzel 

S, 1998 Analyse von Chloroparaffinen in Sediment, Muscheln und Krabben aus der 

Umgebung einer Produktionsanlage. Umed-Info 7, 19-22, Landesgesundheitsamt 

Baden-Württemberg. As reported in OSPAR, 2000. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 301

Appendix E Effects of uncertainty 

in the physico-chemical 

properties, degradation rate and 

emissions on the modelling of 

LCCPs 

E1 Physico-chemical properties 

LCCPs are complex mixtures. This presents some problems over the values of 

physico-chemical properties to be chosen for the environmental modelling of these 

substances. In order to simplify the environmental modelling in the main risk 

assessment report, a set of physical and chemical properties were chosen as being 

representative of each of the three main groups of LCCPs. 

However, for the majority of the physico-chemical properties relevant for the 

environmental modelling, a range of values has been determined, representing the 

complex nature of the products. This appendix considers the effect that varying some 

of the key physico-chemical properties (within the range measured) has on the 

predicted environmental concentration. In order to do this simply, the EUSES model 

was run several times using the release estimates for one hypothetical local scenario 

(Paints – formulation – default calculation); this scenario was chosen as an example 

because it had releases to both air and waste water, and is a relevant scenario for 

each of the three main groups of LCCPs considered. The model was also run for the 

total regional and continental releases. 

Note: this analysis has been carried out using EUSES 1.0 and an earlier estimate for 

the local, the regional and continental release (based on usage information from 1999). 

The results are not, therefore, comparable with the regional and continental releases 

currently used in the main risk assessment). 

The physico-chemical properties for LCCPs are discussed in Chapter 1 of the main risk 

assessment report. The values used in the main report as input data for the various 

example calculations are shown in Table E1. The values chosen reflect the range of 

values measured or estimated for LCCPs. 

For this exercise most of the necessary partition coefficients – the organic carbonwater partition coefficient (Koc), the bioconcentration factors for fish, and the 

accumulation factor earthworms – were estimated from the log Kow using the default 

methods in EUSES 1.0. All calculations assumed that 93 per cent of LCCPs were 

removed from the waste water treatment plant due to adsorption onto sewage sludge. 

Table E2 gives the resulting PECs from this approach. 

Table E3 outlines the PEC/PNEC ratios obtained for surface water, sediment, soil and 

secondary poisoning, using the various physico-chemical properties. For the soil and 

sediment endpoints, both the PEC and PNEC depend on the value used for the 

organic carbon-water partition coefficient, and hence log Kow. It should be noted that 

for this analysis the PNEC in water was set to 0.29 μg/l for all three types of LCCPs 

and the PNEC for secondary was set to 0.5 mg/kg food, 100 mg/kg food and 600 
302 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

mg/kg food for C18-20, C>20 liquid and C>20 solid LCCPs, respectively (this reflects the 

PNECs in an earlier draft of the assessment). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 303

Table E1 Input data for EUSES model for the various scenarios co

Model Value used in EUSES calculation 

Input Main assessment A B C 

C18–20

liquid 

C>20

liquid 

C>20

solid 

C18–20

liquid 

C>20

liquid 

C>20

solid 

C18–20

liquid 

C>20

liquid 

C>20

solid 

C18–20

liquid 

C>20

liqui

Molecular weight (g/mole) 

500 600 960 500 600 960 500 600 960 500 600 

Water solubility (μg/l) 

5 5 5 5 5 5 0.5 0.5 0.5 0.05 0.05 

Vapour pressure (Pa) 

2.5 ×10-4 

2.5 ×10-5 

1.5 ×10-14 

5×10-4 5×10-5 5 

×10-14 

5×10-5 5×10-7 5 

×10-16 

5×10-6 5×10

Henrys Law constant (Pa.m3.mole-1) 

16 15 1×10-6 200 200 1x10-5 1 1 1×10-7 0.1 0.1 

Log Kow 9.7 10.3 17 7.5 7.5 14 8.5 8.5 15 10.5 9.5 Koca (l/kg) 9.06 

×107 

2.77 ×108 

>1 ×1010 

1.5 ×106 

1.5 ×106 

2.8 ×1011 

9.7 ×106 

9.7 ×106 

1.8 ×1012

4.0 ×108 

6.2 ×107 

Fish BCFa (l/kg) 1,096 192 <1 3.80 

×104 

3.80 ×104 

<1 1.32 

×104 

1.32 ×104 

<1 100 1,82

PNECwater (μg/l) 0.29 0.29 0.29 0.29 0.29 0.29 0.29 0.29 0.29 0.29 0.29 

PNECsediment

(mg/kg wet wt.)b 

572 1,748 63,043 9.5 9.5 1.7 

×106 

61.2 61.2 1.1 

×107 

2,523 392 

PNECsoil (mg/kg 

wet wt.)b 

464 1,418 51,176 7.5 7.5 1.4 

×106 

49.7 49.7 9.3 

×106 

2,046 318 

PNECsecondary

poisoning

(mg/kg food) 

0.5 100 600 0.5 100 600 0.5 100 600 0.5 100 

Note a Koc and BCF estimated from log Kow. 

b PNECs for sediment and soil calculated by the equilibrium partitioning method – dependent on Koc 
304 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table E2 Resulting concentrations for the various scenarios con

Endpoint Value estimated in EUSES calculation 

Main assessment A B C 

C18–20

liquid 

C>20

liquid 

C>20

solid 

C18–20

liquid

C>20

liquid

C>20

solid 

C18–20

liquid

C>20

liquid 

C>20

solid 

C18–20

liquid

C>20

liqu

Local concentrations (Paint – formulation site) Surface water (μg/l) 

3.1 ×10-3 

1.7 ×10-3 

5.0 ×10-5 

0.12 0.15 1.8 

×10-6 

0.028 0.046 2.8 

×10-7 

7.2 ×10-4 

7.5 ×10

Sediment (mg/kg wet wt.) 

6.2 10.2 10.8 4.0 4.8 10.8 5.9 9.8 10.8 6.3 10.2 

Agricultural soil (mg/kg wet wt.) 

2.1 2.1 3.6 1.9 2.2 3.6 2.4 2.2 3.6 2.6 2.1 

Air (during emission episode) (mg/m3) 

1.0 ×10-5 

1.0 ×10-5 

2.1 ×10-5 

1.0 ×10-5 

1.0 ×10-5 

2.1 ×10-5 

1.0 ×10-5 

1.0 ×10--5 

2.1 ×10-5 

1.0 ×10-5 

1.0 ×10

Fish (for secondary poisoning) (mg/kg wet wt.) 

1.6 ×10-3 

2.2 ×10-4 

2.0 ×10-8 

2.0 3.0 7.5 

×10-10 

0.18 0.42 1.2 

×10-10 

1.6 ×10-4 

9.3××10

Earthworms (for secondary poisoning) (mg/kg wet wt.) 

0.13 0.19 0.0013 5.0 11.8 4.9 

×10-5 

1.3 5.3 7.6 

×10-6 

0.034 0.77 

Predicted regional concentrations Surface water (μg/l) 

3.1 ×10-4 

7.7 ×10-4 

6.3 ×10-7 

0.0035 0.030 2.3 

×10-8 

0.0031 0.022 3.5 

×10-9 

8.1 ×10-5 

0.00

Sediment (mg/kg wet wt.) 

1.1 8.2 0.24 0.20 1.7 0.24 1.2 8.0 0.24 1.3 8.2 

Agricultural soil (mg/kg wet wt.) 

1.1 12.2 0.15 0.21 2.7 0.15 1.2 12.1 0.15 1.3 12.2 

Air (mg/m3) 3.6 

×10-7 

1.2 ×10-7 

6.2 ×10-10 

6.8 ×10-7 

2.2 ×10-6 

6.2 ×10-10 

3.3 ×10-7 

1.3 ×10-7 

6.2 ×10-10 

3.0 ×10-7 

1.1 ×10
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 305

Table E3 Resulting PEC/PNEC ratios for the various scenarios co

Endpoint PEC/PNEC ratio 

Main assessment A B C 

C18–20

liquid 

C>20

liquid

C>20

solid

C18–20

liquid

C>20

liquid

C>20

solid

C18–20

liquid

C>20

liquid 

C>20

solid

C18–20

liquid

C>

liq

Local concentrations (Paints– formulation site) Surface water (μg/l) 0.010 5.9× 

10-3 

1.7 ×10-4 

0.41 0.51 6.2× 

10-6 

0.096 0.16 9.7× 

10-7 

2.5× 10-3 

0.0

Sediment (mg/kg wet wt.) 

0.10 0.058 1.7× 

10-3 

4.1 5.1 6.2× 

10-5 

0.96 1.6 9.8× 

10-6 

0.025 0.2

Agricultural soil (30 days average) (mg/kg wet wt.) 

0.045 0.015 7.0× 

10-4 

2.5 2.5 2.6× 

10-5 

0.48 0.44 3.9× 

10-6 

0.013 0.0

Fish (for secondary poisoning) (mg/kg wet wt.) 

3.2× 10-3 

2.2× 10-6 

3.3× 10-11 

4.0 0.030 1.3× 

10-12 

0.36 4.2× 

10-3 

2.0× 10-13 

3.2× 10-4 

9.310

Earthworms (for secondary poisoning) (mg/kg wet wt.) 

0.26 1.9×

10-3 

2.2×10-6 

10.0 0.12 8.2×

10-8 

2.6 0.0530 1.3×

10-8 

0.068 7.7

10

Predicted regional concentrations Surface water (μg/l) 1.1×

10-3 

2.7×10-3 

2.1×10-6 

0.012 0.10 7.9×

10-8 

0.011 0.076 1.2×

10-8 

2.8×10-4 

0.0

Sediment (mg/kg wet wt.) 

0.019 0.047 3.8×

10-5 

0.21 1.8 1.4×

10-6 

0.20 1.3 2.2×

10-7 

5.1×



10-3

0.2

Agricultural soil (mg/kg wet wt.) 

0.024 0.086 2.9×

10-5 

0.28 3.6 1.1×

10-6 

0.24 2.4 1.6×

10-7 

6.4×10-3 

0.3
306 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

The shaded areas in Table E3 indicate where a change in the conclusions of the main 

report would occur (i.e. a change of PEC/PNEC ratio from <1 to >1) as a result of 

choosing different values for the physico-chemical properties. 

For surface water, the local PECs vary markedly with the log Kow value, and hence 

Koc value. The PEC reduces as the Koc value increases due to the increased 

adsorption of the substance onto suspended sediment. However, the PEC/PNEC 

ratios are all <1 in the examples seen; the same conclusion would be reached 

whichever log Kow value was used. 

For sediment and soil, the actual PECs are relatively insensitive to the value of the 

physico-chemical properties used (Table E2), varying only by a factor of two in the 

local calculations. However, the results of the analysis show that the PNEC, and 

hence PEC/PNEC ratio is highly dependant on the log Kow value (and hence Koc 

value). 

The PNEC for soil and sediment assumes that the toxicity through the soil or sediment 

pore water can be described adequately by the available aquatic toxicity data. The 

resulting PEC/PNEC ratio is increased by a factor of 10 to take into account the 

possibility of direct ingestion of the sediment. The uncertainty for sediment and soil 

appears to lie on the PNEC side of the risk characterisation, rather than the estimation 

of physico-chemical properties. Actual sediment toxicity data for C18–20 liquid and C>20

liquid chlorinated paraffins may be needed before this uncertainty can be removed. 

For air, the local concentrations predicted are very insensitive to the values of the 

physico-chemical properties chosen. The regional air concentrations show some 

variation, but have a similar magnitude in all of the example calculations. 

For secondary poisoning, the PECs and hence PEC/PNEC ratios vary markedly with 

the log Kow value. This is because the fish and earthworm bioconcentration factors 

that are used in the secondary poisoning calculations are estimated from log Kow. No 

reliable bioconcentration factors are currently available for LCCPs. 

E2 Degradation rate 

Since LCCPs are not readily biodegradable, the appropriate default rate constants for 

degradation in surface water (6.93×10-7 day-1), soil (6.93×10-7 day-1) and sediment 

(6.93×10-8 day-1) were used in the EUSES modelling in the main report. These 

correspond to degradation half-lives of the order of 2,740 years in soil and surface 

water, and 27,400 years in bulk sediment. 

There is some experimental evidence that LCCPs may undergo biodegradation in the 

environment but it is not possible to derive appropriate degradation rate constants 

from this data. However it is likely that LCCPs are less persistent in the environment 

than is indicated by these default degradation half-lives. Therefore the sensitivity of 

the calculations to these degradation rates was investigated. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 307

In this analysis the physico-chemical properties used were those outlined in the main 

report and the regional releases were taken to be the following values (from an earlier 

draft of the risk assessment report): 

 

C18–20, liquid C>20 liquid C>20 solid 

Air 8,945 kg/year 3,491 kg/year 14.6 kg/year 

Surface water 

(via wwtp) 1,405 kg/year 18,165 kg/year 221kg/year 

Surface water (direct) 2,074 kg/year 17,550 kg/year 46 kg/year 

Industrial/urban soil 4,343 kg/year 29,412 kg/year 1,10kg/year 

The EUSES model was run several times with different values for the degradation rate 

constants. The results are shown in Table E4. 

As can be seen from the data presented in Table E4, the regional soil concentration is 

particularly sensitive to the value of the chosen degradation rate. 
308 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table E4 Effects of varying the biodegradation half-life on predicted regional 

Biodegradation 

rate constant 

Half-life PECregional

Surface water 

(μg/l) 

Sediment 

(mg/kg wet wt.) 

Agricultura

(mg/kg wet 

Surface water, soil 

Bulk sediment

Surface water, soil 

Bulk sediment

C18–20

liquid

C>20

liquid

C>20

solid 

C18–20

liquid

C>20

liquid 

C>20

solid 

C18–20

liquid

C>20

liquid

6.93 ×10-7 

6.93×10-8 2,740 

years 

27,400 years 

2.95 ×10-4 

7.24 ×10-4 

5.8 ×10-7 

1.03 7.72 0.223 1.00 11.5 

6.93 ×10-6 

6.93×10-7 274 

years 

2,740 years 

1.54 ×10-4 

4.00 ×10-4 

3.1 ×10-7 

0.54 4.26 0.117 0.15 1.73 

6.93 x10-5 

6.93×10-6 27.4 

years 

274 years 1.09 

×10-4 

3.03 ×10-4 

2.2 ×10-7 

0.38 3.22 0.083 0.016 0.183 

6.93 x10-4 

6.93×10-5 2.74 

years 

27.4 years 

8.97 ×10-5 

2.52 ×10-4 

1.8 ×10-7 

0.304 2.61 0.066 0.001

6 

0.018 

1.90 ×10-3 

1.90×10-4 1 year 10 years 7.18 

×10-5 

2.02 ×10-4 

1.4 ×10-7 

0.23 2.00 0.051 5.87 

×10-4 

6.7 ×10-3 

6.93 ×10-3 

6.93×10-3 100 

days 

2.74 years 

4.32 ×10-5 

1.21 ×10-4 

8.5 ×10-8 

0.118 1.01 0.026 1.61 

×10-4 

1.8 ×10-3 

0.0139 1.93×10-3 50 days 1.37 

years 

3.11 ×10-5 

8.73 ×10-5 

6.1 ×10-8 

0.070 0.597 0.015 8.02 

×10-5 

9.15 ×10-4 

0.0231 2.31×10-3 30 days 300 days 2.48 

×10-5 

6.96 ×10-5 

4.9 ×10-8 

0.045 0.386 0.0098 4.83 

×10-5 

5.51 ×10-4 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 309

Appendix F Estimation of waste 

remaining in the environment and 

futher consideration of diffusive 

emissions from articles 

F1 Introduction 

This appendix considers an alternative approach to that given in the main risk 

assessment report to estimate the possible diffusive emissions of LCCPs from products 

over their lifetimes. The basis of the approach taken here is outlined in the November 

1999 and May 2000 draft EU Risk Assessment Reports for di-(2-ethylhexyl) phthalate 

(DEHP), for which Sweden is the rapporteur country. The method was used in the 2005 

final EU Risk Assessment Report for medium-chain chlorinated paraffins for which the 

United Kingdom is the rapporteur country. The approach considers both losses of the 

substance itself over the lifetime of products containing the substance and also the 

production of any waste containing the substance that may be released to the 

environment over the lifecycle. The approach is relatively crude but may provide "order 

of magnitude" estimates for the releases of LCCPs. No specific guidance is currently 

given in the Technical Guidance Document (TGD) for estimating these types of 

releases, but it is understood that an approach similar to that taken here will be 

incorporated into a future revision of the TGD. 

DEHP is the major plasticiser used in PVC, and accounts for around 51 per cent of the 

total phthalate plasticiser in use. In some calculations in this appendix it is assumed 

that the use pattern of PVC containing LCCPs is similar to that of PVC containing 

DEHP. This assumption is reasonable as LCCPs in PVC are mainly used as secondary 

plasticisers alongside the primary plasticisers (phthalates such as DEHP). 

The relative market share of PVC containing LCCPs is needed before the data given in 

the DEHP report can be used. This value can be estimated roughly from key data (the 

information on DEHP is taken from the May 2000 draft of the risk assessment for that 

substance), especially: 

• quantity of DEHP used in PVC (and other polymers) in the EU is 

462,000 tonnes/year; 

• typical DEHP content of PVC = 30 per cent; 

• estimated quantity of PVC containing DEHP produced in the EU is given as 

1.54×106

 tonnes/year. 

As DEHP accounts for around 51 per cent of the phthalate plasticiser usage in PVC, 

the total amount of phthalate-plasticised PVC produced in the EU can be estimated at 

approximately 3×106

 tonnes/year. 

Based on an estimate of the amount of PVC containing LCCPs produced in the EU, 

LCCPs could be present in around 0.11–0.17 per cent (C18–20 liquid) of the total 

plasticised PVC produced in the EU. A figure of 0.17 per cent for C18–20 liquid 

chlorinated paraffins will be considered in the following sections as a worst case. 
310 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

As indicated in the main report, C18–20 liquid chlorinated paraffins are the main type of 

LCCP currently used in PVC. However, it is known that relatively small amounts of C>20

liquid chlorinated paraffins have been used in PVC applications in the recent past and 

so PVC containing this type of LCCP is still likely to be in service in the EU. Therefore it 

is appropriate to also consider the emissions of this type of chlorinated paraffin from 

PVC in use. 

The estimated emissions for the C>20 liquid chlorinated paraffins given in the following 

sections are based on an assumption that they were present in a maximum of around 

0.008 per cent of the total PVC manufactured in the EU in the late 1990s. 

In the draft DEHP risk assessment, the uses of flexible PVC were split between indoor 

and outdoor uses, with 78 per cent of the flexible PVC used in indoor applications and 

22 per cent used in outdoor applications. This split will also be assumed to be 

applicable for PVC containing LCCPs here. 

It should be noted that the actual amounts of LCCPs used in the various PVC 

applications considered are much less well defined than is the case for DEHP. The 

assumptions made about the amounts and use of LCCPs in these applications 

introduce further uncertainty into the emissions estimated. 

F2 Estimated emissions from volatilisation from PVC 

In the EU Risk Assessment Report for medium-chain chlorinated paraffins, an emission 

figure to air for medium-chain chlorinated paraffins of 5×10-4 μg/m2

/s was determined 

for volatilisation from PVC over 21 days. Assuming this emission rate remains constant 

with time, this emission figure is equivalent to 15.8 mg/m2

/year. The equivalent 

emission figure derived for DEHP in the draft Risk Assessment of that substance was 

9.5 mg/m2

/year. No equivalent data are available for LCCPs. 

However, in the main risk assessment report it was indicated that the C18–20 liquid 

chlorinated paraffins were around 2.5 times less volatile than DEHP (which is itself 

slightly less volatile than some medium-chain chlorinated paraffins); an estimated 

emission figure of 3.8 mg/m2

/year will be used for the C18–20 liquid chlorinated paraffins. 

Tthe equivalent assumption made for the C>20 liquid chlorinated paraffins is that they 

are five times less volatile than DEHP, giving an emission factor of 1.9 mg/m2

/year. 

This factor is used here to estimate releases to the environment taking into account the 

surface area of products in a similar way to that carried out for DEHP, from which much 

of the available emission data was originally derived. 

F2.1 Indoor applications 

F2.1.1 PVC flooring 

In the draft DEHP risk assessment, the total annual production of PVC flooring in the 

EU was taken as 2.3×108

 m2/year, with a lifetime of 20 years. If it is assumed that C18–

20 liquid chlorinated paraffins are present in 0.17 per cent of the flooring, the amount of 

flooring containing C18–20 liquid chlorinated paraffins produced in the EU is 

3.9×105

 m2/year and the total amount present in the EU is 7.8×106 m2 assuming a 

20 year life-span. 

Using the emission factor estimated above for on the total area of flooring estimated to 

contain C18–20 liquid chlorinated paraffins present in the EU gives an estimated air 

emission of 30 kg/year of C18–20 liquid chlorinated paraffins from this source (the 

equivalent emission for C>20 liquid chlorinated paraffins is 0.70 kg/year). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 311

It is thought that around 50–60 per cent of cushion vinyl flooring is coated with 

polyurethane in order to improve the wear resistance and stain resistance of the 

product. This coating will obviously affect the potential for volatilisation of LCCPs from 

the product but no information is available on this. Assuming such a coating reduces 

the emissions by a factor of 10 and is applied to 50 per cent of flooring, then the 

estimated emissions would be reduced to 17 kg/year for C18–20 liquid chlorinated 

paraffins (the equivalent emission for C>20 liquid chlorinated paraffins is 0.39 kg/year). 

F2.1.2 Vinyl wall covering 

In the draft DEHP risk assessment the total annual production of vinyl wall covering in 

the EU was taken as 4×108

 m2/year, with a lifetime of seven years. The total amount of 

vinyl wall covering present in the EU at any one time is therefore 2.8×109

 m2. Assuming 

that C18–20 liquid paraffins are present in 0.17 per cent of the wall covering, the total 

amount of wall covering containing LCCPs present in the EU is 4.8×106

 m2. 

Using the emission factor above, gives an estimated air emission of 18 kg/year for the 

C18–20 liquid chlorinated paraffins from this source (the equivalent emission for C>20

liquid chlorinated paraffins is 0.43 kg/year). 

F2.1.3 Coated products, film and sheet 

In the draft DEHP risk assessment the relevant statistics for the production of coated 

products, film and sheet (e.g. upholstery, packaging, stationary products, luggage, 

clothing etc.) containing phthalate plasticisers could not be obtained. Instead the worst 

case assumption of 40 tonnes/year for total phthalate emissions from these products, 

as determined by the European Council for Plasticisers and Intermediates (ECPI, 

1996), was used as the basis of the release estimate. This estimate was based on a 

product lifetime of seven years. 

If it is assumed that C18–20 liquid chlorinated paraffins are present in 0.17 per cent of 

these products and that the emission rate is 2.5 times lower than that of the phthalates 

present, then an air emission of 27 kg/year for C18–20 liquid chlorinated paraffins can be 

estimated from this source (the equivalent emission for C>20 liquid chlorinated paraffins 

is 0.64 kg/year). 

F2.1.4 Cable 

In the draft DEHP risk assessment report the relevant statistics for the production of 

cable containing phthalate plasticisers could not be obtained. Instead the worst case 

assumption of 50 tonnes/year for total phthalate emissions from these products, as 

determined by the European Council for Plasticisers and Intermediates (ECPI, 1996), 

was used as the basis of the release estimate. 

As was the case with coated products, film and sheet, if is assumed that C18–20 liquid 

chlorinated paraffins are present in 0.17 per cent of these products and that the 

emission rate is 2.5 times lower than that of the phthalates present, then an air 

emission of 34 kg/year for C18–20 liquid chlorinated paraffins can be estimated from this 

source (the equivalent emission for C>20 liquid chlorinated paraffins is 0.80 kg/year). 

F2.1.5 Hose and profile 

In the draft DEHP risk assessment report the relevant statistics for the production of 

hose and profile containing phthalate plasticisers could not be obtained. Instead it was 

assumed that, as the surface to volume ratio and lifetime were similar to PVC flooring, 

the overall releases of DEHP would be similar to flooring. The ratio of DEHP used in 

flooring:profile/hose (74,708 tonnes/year:55,911 tonnes/year or 1.34:1) was used to 

scale the estimated emissions from PVC flooring to give an estimate from this use. 
312 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

If it is assumed that LCCPs are present in PVC flooring and hoses/profile in a similar 

ratio to that found for DEHP (i.e. 1.34:1) the releases to air from this application can be 

estimated using the above scaling factor on the estimated releases of LCCPs from 

PVC flooring. Thus the estimated release to air of LCCPs from this source is 22 kg/year 

of C18–20 liquid chlorinated paraffins (the equivalent emission for C>20 liquid chlorinated 

paraffins is 0.52 kg/year). 

F2.2 Outdoor applications 

The draft risk assessment report on DEHP provided estimated figures for the surface 

areas for various outdoor PVC products produced each year containing DEHP and that 

may emit DEHP. These estimates are shown in Table F1, along with the estimated 

lifetimes of the products. These figures were estimated from the known DEHP yearly 

consumption in these applications and applying a “surface correction factor” to convert 

the consumption figures to an “annual surface area produced” figure. Since DEHP 

accounts of around 51 per cent of the total phthalate plasticiser use in PVC, the surface 

area of all flexible (phthalate plasticised) PVC produced each year in these applications 

will be around twice the values given. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 313

Table F1 Estimated DEHP emitting surface area and lifetime of 

outdoor PVC products containing DEHP 

PVC product Annual emitting surface 

area 

(based on DEHP annual 

production) 

Lifetime 

Car undercoating 3,703,700 m2/year 12 years 

Roofing material 529,100 m2/year 20 years 

Coil coating 26,455,000 m2

/year 10 years 

Fabric coating 22,222,200 m2

/year 10 years 

Cable and wires (above 

ground) 

2,116,400 m2

/year 30 years 

Cable and wires (buried) 8,465,600 m2

/year 30 years 

Hoses and profiles 1,587,300 m2

/year 10 years 

Shoe soles 3,174,600 m2

/year 5 years 

Assuming C18–20 liquid chlorinated paraffins occur in around 0.17 per cent of all 

plasticised PVC used in the above applications, and using an emission rate of 3.8 

mg/m2

/year, emission to air estimates can be obtained for LCCPs over the lifetime of 

the PVC products (Table F2). The equivalent emissions for C>20 liquid chlorinated 

paraffins are also shown. 

Table F2 Estimated LCCP emission for outdoor PVC products 

PVC product LCCP emission 

 C18–20 liquid C>20 liquid 

Car undercoating {0.57 kg/year}a {0.014 kg/year}a 

Roofing material 0.14 kg/year 0.003 kg/year 

Coil coating 3.4 kg/year 0.080 kg/year 

Fabric coating 2.9 kg/year 0.068 kg/year 

Cable and wires (above ground) 0.81 kg/year 0.019 kg/year 

Cable and wires (buried – 

emissions will be to soil 

compartment) 

3.3 kg/year 0.077 kg/year 

Hoses and profiles 0.21 kg/year 0.005 kg/year 

Shoe soles 0.21 kg/year 0.005 kg/year 

Notes: a Chlorinated paraffins are not thought to be used in car undercoating – 

calculation given only as an example. 

 Emission = 2 × annual surface area produced based on: 

DEHP × lifetime × fraction of PVC containing LCCP × emission rate 

(mg/year). 

F3 Estimated emissions from LCCPs leaching from PVC 

In these estimates it is assumed that LCCPs have a similar potential for leaching from 

PVC as DEHP as a worst case (see main risk assessment report). 

F3.1 Indoor applications 

F3.1.1 Washing clothing with PVC printing 
314 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

It is not known if LCCPs are used in this application. In the draft risk assessment report 

for DEHP a total EU release of DEHP from this application was estimated at 99 

tonnes/year (range 18–180 tonnes/year), based on measurements of phthalate loss 

carried out in Denmark. If it is assumed that LCCPs are used in this application, then a 

release of 327 kg/year of C18–20 liquid chlorinated paraffins can be estimated based on 

the relative amounts of PVC containing DEHP and LCCPs estimated earlier (i.e. C18–20

chlorinated paraffins may be present in up to 0.17 per cent of the total plasticised PVC 

or up to 0.33 per cent of the PVC containing DEHP); the equivalent emission for C>20

liquid chlorinated paraffins is 15 kg/year). There is a large uncertainty in this figure due 

to uncertainties in the release rate and the relative amounts of LCCPs used in this 

application (if they are used at all). 

F3.1.2 Washing PVC flooring 

An emission figure for DEHP of 5 μg/dm2 (=500 μg/m2) per cleaning event (10 day 

interval) was reported in the draft DEHP risk assessment, based on experimental data 

from Sweden. The study was designed only to determine the leaching loss and did not 

include any loss due to abraded particulates. 

In the draft DEHP risk assessment report the total annual production of PVC flooring in 

the EU was taken as 2.3×108

 m2/year, with a lifetime of 20 years. If it is assumed that 

C18–20 liquid chlorinated paraffins are present in 0.17 per cent of the flooring, the total 

amount of flooring containing C18–20 liquid chlorinated paraffins present in the EU is 

7.8×106

 m2. Using the above emission figure and assuming cleaning of the flooring 

once per week, the estimated emission of LCCP is 203 kg/year for C18–20 liquid 

chlorinated paraffins (the equivalent emission for C>20 liquid chlorinated paraffins is 

9.6 kg/year). 

It is thought that around 50–60 per cent of cushion vinyl flooring is coated with 

polyurethane in order to improve the wear resistance and stain resistance of the 

product. This coating will obviously affect the potential for leaching of LCCPs from the 

product, but no information is available at this time. If it is assumed that this coating 

reduces the leaching loss by a factor of 10 and is applied to 50 per cent of the flooring, 

then the estimated emissions would be 102 kg/year for C18–20 for liquid chlorinated 

paraffins (the equivalent emission for C>20 liquid chlorinated paraffins is 5.3 kg/year). 

The draft DEHP risk assessment report also considered abrasion loss from PVC 

flooring. The assessment used data from standard tests for abrasion loss that indicated 

about 0.1–0.15 mm (average 0.125 mm) of the surface will be worn away over the 

lifetime of the flooring. Assuming the flooring is typically 2 mm thick, this abrasion loss 

corresponds to a loss rate of around 6.25 per cent over the lifetime of the PVC flooring 

or 0.31 per cent/year. This loss was assumed to occur on all PVC flooring where 

walking occurred frequently and this was estimated to be around 50 per cent of the 

total PVC area. 

Earlier, it was estimated that around 7.8×106

 m2 of PVC-flooring could contain C18–20

liquid chlorinated paraffins. Assuming an initial thickness of 0.002 m (2 mm) and a 

representative density of around 1,200–1,300 kg/m3

 for plasticised PVC (from the draft 

risk assessment of DEHP), the amount of PVC containing C18–20 liquid chlorinated 

paraffins in flooring can be roughly estimated as 20,280 tonnes (C18–20 liquid) at any 

one time (assuming a 20 year lifetime). If the abrasion rate is 0.31 per cent/year, and 

50 per cent of the available flooring is subject to abrasion, then the amount of PVC 

abraded as particulates is 31.4 tonnes/year. The LCCP could be present at 10 per cent 

in these particulates, i.e. 3,140 kg/year of C18–20 liquid chlorinated paraffins (the 

equivalent emission for C>20 liquid chlorinated paraffins is 148 kg/year). 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 315

Again, it also needs to be taken into account that around 50–60 per cent of cushion 

vinyl flooring is coated with polyurethane which will reduce the wear rate of the product, 

and hence emission of LCCP. No information is available on this, but if it is assumed 

that such a coating reduces the emission rate of LCCPs by a factor of 10 and is applied 

to 50 per cent of flooring, then the estimated particulate emissions would be reduced to 

1,730 kg/year for C18–20 liquid chlorinated paraffins (the equivalent emission for C>20

liquid chlorinated paraffins is 81 kg/year). 

These particulates are likely to end up in waste water (by washing) or landfill (by 

cleaning methods not involving water). In the May 2000 draft of the DEHP risk 

assessment, it was assumed that 50 per cent of these emissions would end up in 

waste water. This would amount to around 865–1,570 kg/year of C18–20 liquid 

chlorinated paraffins (the equivalent emission for C>20 liquid chlorinated paraffins is 41–

74 kg/year). 

F3.2 Outdoor applications 

The annual releases of plasticiser from roofing materials have been estimated from 

studies carried out by Pastruska et al. (1988) and Pastruska and Just (1990). These 

gave overall loss figures (includes volatilisation, leaching and degradation) of 

phthalates from the roofing material of 0.15 per cent/year for open air exposures and 

0.35 per cent/year for a surface covered with gravel. 

In the draft risk assessment report for DEHP these figures were converted into surface 

area emission figures for DEHP of 1.98 g/m2

/year for uncovered surfaces and 4.62 

g/m2

/year for gravel-covered surfaces. These figures were assumed to represent the 

leaching loss from the PVC, and were expected to be distributed 50 per cent to surface 

water and 50 per cent to soil. 

Using a similar methodology as used for DEHP, the following surface area emission 

figures can be estimated for LCCPs using the above data. 

 1 m2

 of roofing material (1.5 mm thickness) = 1.5×106 mm3 volume 

 Density of PVC (unplasticised) = 1.406 mg/mm3

 Density of DEHP = 0.985 mg/mm3

 Density of LCCP = 1.3 mg/mm3

 Overall density of plasticised PVC 

(10 per cent LCCP and 35 per cent DEHP) = 1.248 mg/mm3

 1 m2

 of roofing material (1.5 mm thickness) = 1,872 g 

 Amount of LCCP present in 1 m2

 roofing material = 10 per cent = 187.2 g/m2 

 Annual emission rate = 0.15 per cent/year or 

or = 0.35 per cent year 

 Surface area emission factor for LCCP = 0.28 g/m2

/year 

or = 0.65 g/m2/year 

These calculations assume that the LCCPs are as equally susceptible to removal 

(leaching) as DEHP. Processes other than leaching (e.g. biodegradation) could have 

occurred in these experiments with phthalates, which may not be applicable to LCCPs, 

resulting in an overestimate of the leaching loss. 

Assuming the C18–20 liquid chlorinated paraffins occur in around 0.17 per cent 

respectively of all plasticised PVC used in the outdoor applications outlined in Section 

F2.2, and using an emission rate of 0.65 g/m2

/year for gravel-covered surfaces and 

0.28 g/m2

/year for open surfaces, estimated leaching losses can be obtained over the 

lifetime of the PVC products (Table F3). The equivalent emissions for C>20 liquid 

chlorinated paraffins are also shown. 
316 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table F3 Estimated LCCP leaching losses from outdoor PVC 

products 

PVC product Emission factor Estimated leaching loss 

 C18–20 liquid C>20 liquid 

Car undercoating {0.28 g/m2/year}a {42 kg/year}a {2.0 kg/year}a 

Roofing material 0.65 g/m2/year 23 kg/year 1.1 kg/year 

Coil coating 0.28 g/m2

/year 251 kg/year 12 kg/year 

Fabric coating 0.28 g/m2

/year 212 kg/year 10 kg/year 

Cable and wires (above 

ground) 

0.28 g/m2

/year 60 kg/year 2.8kg/year 

Cable and wires (buried) 

emissions will be to soil 

compartment) 

0.65 g/m2

/year (560 kg/year 26 kg/year 

Hoses and profiles 0.28 g/m2

/year 15 kg/year 0.71 kg/year 

Shoe soles 0.65 g/m2

/year 35 kg/year 1.7 kg/year 

Note: a Chlorinated paraffins are not thought to be used in car undercoating – 

calculation given only as an example. 

Emission = 2 × annual surface area produced based on: 

DEHP × lifetime × fraction of PVC containing LCCP × emission factor (g/year). 

In addition, a figure of 47 tonnes/year of DEHP was estimated to be released to waste 

water during the washing of car underbodies in the draft risk assessment for DEHP. 

The “scaled” emission for LCCPs (taking into account the relative amounts used in 

PVC applications) would be around 160 kg/year of C18–20 liquid chlorinated paraffins 

(the equivalent emission for C>20 liquid chlorinated paraffins is 7.1 kg/year). However, it 

is thought that chlorinated paraffins do not have a significant use in car undercoating. 

F4 Emissions during waste disposal 

F4.1 Car shredding 

As well as PVC-coated underbodies (which are unlikely to contain chlorinated 

paraffins), cars may contain other PVC articles (e.g. cable or wiring) that may contain 

LCCPs. The draft risk assessment report on DEHP includes an emission scenario for 

this endpoint and this information has been used here to estimate the worst case 

emissions of chlorinated paraffins during the process as follows: 

Amount of PVC per car = 16 kg 

Percentage of PVC that is plasticised = 35 per cent 

Amount of plasticised PVC/car = 5.4 kg 

Maximum amount of chlorinated paraffin/car 

(assuming 10 per cent content in PVC) = 0.54 kg 

Total number of cars processed in EU = 10,600,000/year 

Total amount of chlorinated paraffins present = 5,724 tonnes/year 

Number of shredder sites in EU = 252 

Average amount of chlorinated paraffin processed = 22.7 tonnes/year/site 

Number of days of operation = 300 

Emission factor to air = 0.05 per cent 

Local release of chlorinated paraffins to air = 11.4 kg/year 

= 0.038 kg/day 

Total EU release of chlorinated paraffins to air = 2.86 tonnes/year 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 317

The main type of chlorinated paraffin used in PVC is medium-chain chlorinated 

paraffin. LCCPs account for only a small fraction of the total chlorinated paraffin usage 

in PVC (estimated at around 0.5 per cent for C18–20 liquid chlorinated paraffins in the 

late 1990s). Therefore, the estimated air emissions of C18–20 liquid chlorinated paraffins 

from this source would be expected to be 1.9×10-4 kg/day at a local site and 14 kg/year 

in the EU as a whole (the equivalent emission for the C>20 liquid chlorinated paraffins 

would be 1.5×10-5 kg/day at a local site and 1.1 kg/year in the EU as a whole). 

F4.2 Incineration of municipal waste 

No information is available on levels of LCCPs in the exhaust gases from municipal 

waste incinerators and so it is not possible to estimate a release from this source. The 

conditions present during municipal waste incineration would be expected to effectively 

destroy any LCCPs present. 

F4.3 Municipal landfill 

No information is available on the amounts of LCCPs subject to leaching from 

municipal landfills. In the draft risk assessment of DEHP it was estimated that around 

15 tonnes/year of DEHP could leach from landfills to waste water in the EU. If it is 

assumed that LCCPs have a similar potential to leach as DEHP then the amount of 

LCCPs leached could be estimated to be around 51 kg/year of C18–20 liquid chlorinated 

paraffins, based on scaling the DEHP figure to the relative total volumes of DEHP and 

LCCPs used in PVC applications in the EU (the equivalent emission for C>20 liquid 

chlorinated paraffins is 2.3 kg/year). 

F4.4 Waste remaining in the environment 

Waste remaining in the environment can be considered to be particles of polymer 

product (e.g. PVC, paint, sealant etc.) which contain the LCCP. These particles are 

primarily released to the urban/industrial soil compartment, but they may also end up in 

sediment or air. End-products with outdoor uses are most likely to be sources of this 

waste. The release can occur both over the lifetime of the product (due to weathering, 

wear etc.) and at disposal (particularly where articles are dismantled or subjected to 

other mechanical processes). 

In the draft DEHP risk assessment, waste remaining in the environment was identified 

to be produced from a number of outdoor applications of PVC, i.e.: 

• car undercoating; 

• roofing material; 

• coil coating; 

• fabric coating; 

• cables and wires; 

• hoses and profiles; 

• shoe soles. 

Furthermore, it was stated that 22 per cent of the DEHP in PVC was used in these 

outdoor applications. The actual breakdown of the use of LCCPs between these 

different sources is not known and so it will be assumed that around 22 per cent of the 

LCCP is also used in PVC for outdoor applications. 
318 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

In addition, LCCPs are also used in rubber products, textile products, outdoor paints 

and building sealants which also need to be considered as possible sources of waste 

remaining in the environment. The use in leather fat liquors and metalworking/cutting 

fluids are not considered to contribute significantly to these types of release. Table F4 

outlines the relevant tonnages for the applications considered. 

The emission factors used for these types of losses in the draft DEHP risk assessment 

were around 2–10 per cent over the lifetime of the product, with the higher factor being 

applied to articles subject to high wear rates (such as car underbodies and shoe soles), 

and two per cent during disposal operations. The assumptions behind the derivation of 

these factors were not given in the report. These releases were thought to occur mainly 

to urban/industrial soil. A similar approach is taken here as a worst case, using similar 

factors as used for DEHP. Only outdoor applications are considered to contribute 

significantly to the waste over the lifetime of the articles. However, for some of the 

applications (e.g. sealants, textiles, paints) the actual fraction used in outdoor 

applications is uncertain and so it has been assumed that all of the LCCPs are used in 

outdoor applications as a worst case. 

This approach assumes that: 

• the quantity of articles/products containing LCCPs disposed of each year is 

equal to the quantity of new articles/products containing LCCPs produced each 

year; 

• the emissions factors estimate the total release over the entire service life of the 

product/article (i.e. for high wear articles, 10 per cent of the product is worn 

away as particles/dust over the lifetime of the product). 

For use in rubber products, sealants/adhesives and paints, a particulate emission 

factor of two per cent over the technical lifetime of the product and two per cent at 

disposal is used (in the May 2000 draft of the DEHP assessment a figure of five per 

cent over the technical lifetime and five per cent at disposal was used for paints and 

sealants, so these values are also considered). However, for PVC applications, there 

may be some high wear products produced (e.g. shoe soles) and so a higher 

particulate emission factor may be appropriate to some of these applications. 

Since the actual breakdown of the use of LCCPs between these various PVC end-uses 

is currently unknown, an emission factor of six per cent over the lifetime of the technical 

product was used (average of the low and high wear factors), with two per cent 

emission at disposal. The calculations also take into account the LCCPs estimated to 

be lost via volatilisation and leaching over the lifetime in order to avoid double counting 

of these emissions. 

The emissions are likely to be mainly to soil. In the draft DEHP assessment it was 

assumed that 75 per cent of the emission would be to industrial/urban soil and 0.1 per 

cent to air, with the remainder occurring to surface water (sediment). The same split of 

the emissions will be used here in the absence of any further information. The 

emissions are summarised in Table F4. 

There are many uncertainties inherent in these emission estimates. Further, since this 

“waste” is essentially polymeric particles (e.g. rubber, polymer, sealant, paint) 

containing the LCCP, it is not known if this is “available” in the environment and 

therefore whether organisms are at any risk to exposure. 

In addition to these particulate releases, an estimated 865–1,570 kg/year of C18–20

liquid chlorinated paraffins (and 41–74 kg/year C>20 liquid chlorinated paraffins) may be 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 319

emitted to waste water (and 865–1,570 kg/year of C18–20 liquid chlorinated paraffins and 

41–74 kg/year of C>20 liquid chlorinated paraffin to landfill/disposal) as particulates for 

PVC flooring as a result of wear and subsequent washing (see Section F3.1.2). 
320 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table F4 Estimation of waste remaining in the environment 

 Uses considered for waste remaining in environm

PVC Rubber Sealants/adhesives 

C18–20

liquid 

C>20

liquida 

C>20

liquid 

C>20

solid 

C18–20 

liquid 

C>20

liquid 

C18–

liqu

Amount of LCCP emitted as waste remaining in the environment over technical lifetime of product (kg/year) 

6,900 300 83,452 4,140 5,000–

5,162 

10,140–10,460 

30,632,2

Amount of LCCP emitted as waste remaining in the environment at disposal (kg/year) 

2,270 94 81,782 4,060 4,900–

5,060 

9,940–10,260 

30,031,6

Total amount of LCCP as waste remaining in the environment (kg/year) 

9,170 394 165,234 8,200 9,900–

10,222 

20,080–20,720 

60,663,8

urban soil 75% 75% 75% 75% 75% 75% 

surface water 

Distribution 24.9% 24.9% 24.9% 24.9% 24.9% 24.9of emission 

air 0.1% 0.1% 0.1% 0.1% 0.1% 0.1% 

urban soil 6,878 296 123,926 6,150 7,425–

7,667 

15,060–15,540 

45,543,8

surface water 

2,283 98 41,143 2,042 2,465–

2,545 

5,000–5,159 

15,114,5

Total amount of LCCP as waste remaining in the environment to: (kg/year) 

air 9 0.4 165 8 10 20 61 

Note: a Calculation based on past use in this application. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 321

F5 Summary of emissions estimated 

Table F5 summarises the emissions estimated here for diffusive losses of LCCPs during the 

lifetime of PVC products and during the disposal of articles. Table F6 summarises the emissions 

of LCCPs as particulates (waste remaining in the environment) over the lifecycle of products. 

Table F5 Summary of diffusive losses of LCCPs from PVC during product 

lifetimes and disposal 

Lifestage Emission of LCCP (kg/year) 

Volatility losses to air Leaching loss to water and 

soil 

C18–20 liquid C>20 liquid C18–20 liquid C>20 liquid 

flooring (i) 17–30 0.39–0.70 102–203b 5.3–9.6b Product 

lifetime wall covering (i) 18 0.43 

 coated products, film 

and sheet (i) 

27 0.64 327a,b 15a,b 

 cable (i) 34 0.80 

 hose and profile (i) 22 0.52 

 roofing material (o) 0.14 0.003 23c 1.1c 

 coil coating (o) 3.4 0.080 251c 12c 

 fabric coating (o) 2.9 0.068 212c 10c 

 cable (o) 0.81 

(+3.3 to deep 

soil) 

0.019 

(+0.077 to 

deep soil) 

60c 

(+560 to deep 

soil) 

2.8c 

(26 to deep 

soil) 

 hoses and profile (o) 0.21 0.005 15c 0.71c 

 shoe soles 0.21 0.005 35c 1.7c 

air 126–139 3.0–3.3 

waste water 429–530 20–25 

surface water 298 14 

urban/industrial soil 298 14 

Total 

from 

PVC 

over 

product 

lifetime 

to deep soil 3.3 0.077 560 2 

Waste car shredding 14 1.1 

disposal incineration small small 

 municipal landfill 51b 2.3b 

Total from PVC at disposal 14 

(to air) 

1.1 

(to air) 

51 

(to waste 

water) 

2.3 

(to waste 

water) 

Notes: a Estimated for washing clothing with PVC printing – it is not known if LCCPs are used in 

this application. 

b

 Losses primarily to wastewater. 

c

 Losses to soil and water (assumed to be split 50:50 between surface water and 

industrial/urban soil). 

i = indoor application; o = outdoor application. 
322 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table F6 Summary of waste remaining in the environment during product lifeti

Lifestage Emission of long-chain chlorinated paraffin as particul

Air Surface water Waste water 

C18–20

liquid 

C>20

liquid 

C>20

solid 

C18–20

liquid 

C>20

liquid 

C>20

solid 

C18–20

liquid 

C>20

liquid 

C>20

soli

Product lifetime 

PVC 7 0.3 1,718 75 865– 

1,570a 

41–74a 

 

 Rubber 83 4 20,780 1,031  Sealants/adhesives 5 10 1,245–

1,285 

2,525–2,605 

 

 Paints 31–32 27 6 7,634–

8,023 

6,768–6,823 

1,382 

Waste disposal 

PVC 2 0.09 565 23 

 Rubber 81 4 20,364 1,011  Sealants/adhesives 5 10 1,220–

1,260 

2,475–2,555 

 

 Paints 31–32 27 5 7,475–

7,868 

6,633–6,688 

1,355 

Total 81–83 238 19 19,857–

20,719 

59,643–59,913 

4,779 865–

1,570 

41–74 

Note: a Emission to waste water from washing PVC-flooring. A similar amount estimated to end up in landfill. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 323

In order to generate these figures, a large number of “worst case” assumptions have 

had to be made. This leads to a large uncertainty in the figures obtained, and the 

approach taken may grossly overestimate the actual releases. In particular, the 

information on leaching losses from outdoor outdoors is based on a study where the 

overall loss (including leaching, degradation and particulate loss due to 

wear/weathering) of phthalate plasticiser from roofing material was determined. In the 

study, it was not possible to distinguish between these types of loss and so it has been 

assumed that all the loss was due to leaching. The applicability of this approach to 

estimating the leaching loss of LCCPs from products outdoors is unknown. 

F6 References 

ECPI, 1996 Assessment of the release, occurrence and possible effects of plasticisers 

in the environment. Phthalate esters used in plasticised PVC. European Council for 

Plasticisers and Intermediates, CEFIC, September 1996. (as quoted in the November 

1999 draft of the ESR risk assessment report for DEHP). 

Pastruska G, Kerner-Gang W and Just U, 1988 Langzeitverhalten von PVC-PDachbahnen. Kautschuk Gummi Kunststoffe, 41, 451-454. (as quoted in the draft of the 

ESR risk assessment report for DEHP). 

Pastruska G and Just U, 1990 Weichmacherverlust aus langjährig freibewitternten 

PVC-P-Dachbahnen. Kautschuk Gummi Kunststoffe, 43, 1093-1094. (as quoted in the 

draft of the ESR risk assessment report for DEHP). 
324 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Appendix G Assessment of C16–17

impurities present in LCCPs 

This appendix considers the risks to the environment from the presence of C16–17

chlorinated paraffin impurities in some types of LCCPs. The levels of n-paraffin 

impurities present in the feedstocks used to manufacture LCCPs are shown in Table 

G1. 

Table G1 n-Paraffin impurities present in feedstocks used to 

manufacture LCCPs 

Feedstock Impurities present 

C18–20 <1% C16 (or lower n-paraffins) 

typically 17% C17 (possible range 10-20%) 

C>20 0% C19 (or lower n-paraffins) 

<0.2% C20 paraffins 

Since the C18–20 feedstock contains a significant proportion of smaller chain length nparaffins, the C18–20 chlorinated paraffins produced from this feedstock would be 

expected to contain a similar amount of lower chain length chlorinated paraffins as 

impurities. Thus the C18–20 LCCPs could act as a significant source of C16–17 chlorinated 

paraffins, which are also components of medium-chain (C14–17) chlorinated paraffins. 

The emission estimates for the C18–20 chlorinated paraffins are shown in Table G2. 

These values are taken from the draft risk assessment report on LCCPs. The 

equivalent release estimates for the C16–17 impurities (calculated by assuming the C16–17

impurity typically accounts for 17 per cent of the product) are also shown in Table G2. 

In order to assess the risk to the environment from these impurities, EUSES 2.0.3 has 

been used to estimate the resulting concentrations of the C16–17 impurity. The physicochemical, toxicological and other data used in the model are derived in the risk 

assessment report for medium-chain chlorinated paraffins (of which C16–17 chlorinated 

paraffins are also a component). The values for these parameters are are summarised 

in Table G3. The resulting PECs and PEC/PNEC ratios for surface water, sediment, 

soil and secondary poisoning are shown in Table G4 to Table G7. 

This approach used here is considered a worst case approach as it assumes that all 

the toxicity seen with the medium-chain chlorinated paraffins is due mainly to the C17

component. This is not likely to be the case as there appears to be a general trend that 

chlorinated paraffins become less toxic and bioavailable as their carbon chain length 

increases. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 325

Table G2 Summary of environmental release estimates for C18–20 chlorinated para

Estimated local release Estimated regional release 

(kg/year) 

Use Comment Type of 

LCCP 

air (kg/day) 

waste water (kg/day) 

no of daysj 

air waste 

waterg 

soilm 

Production Generic C18–20 0.063 300 con con con 

calculation C16–17 

impurity 

 0.011 300 

C18–20 0.025a Use in PVC 33 e – 

plastisol coatingh 

Compounding site (formulation) 

C16–17

impurity 

 0.0043a 33 

C18–20 0.025a 0.025a Conversion 33 

site (processing) 

C16–17

impurity 

0.0043a 0.0043a 33 

C18–20 0.025a 0.050a Combined 33 

compounding and conversion site 

C16–17

impurity 

0.0043a 0.0085a 33 

C18–20 0.0075a

0.040b

0.0034c 

0.0445a

0.24b 

0.0204c

Use in PVC 33 e – 

extrusion/other 

Compounding site (formulation) 

C16–17

impurity 

0.0013a 

0.0068b

0.00029c 

0.0076a

0.041b 

0.0035c 

33 

C18–20 0.037a 

0.040b 0.034c 

0.037a 0.040b 0.034c 

 Conversion 33 

site (processing) 

C16–17

impurity 

0.0063a

0.0068b 

0.0058c 

0.0063a

0.0068b 

0.0058c 

33 

Table G2 continued overleaf 
326 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table G2 continued 

Estimated local release Estimated regional release 

(kg/year) 

Use Comment Type of 

LCCP 

air (kg/day) 

waste water (kg/day) 

no of daysj 

air waste 

waterg 

soilm 

C18–20 0.0445a 

0.080b 0.0374c 

0.0815a

0.28b 

0.0544c

Use in PVC 33 e – 

extrusion/other

Combined compounding and conversion site 

C16–17

impurities

0.0076a 

0.014b

0.0064c 

0.014a

0.048b0.0092c 

33 

Raw C18–20 5.2 materials handling (formulation) 

C16–17impurities

 0.88 

Compounding C18–20 0.7 0.7 (formulation) C16–17 

impurities

 0.12 0.12 

C18–20 12 12 

Use in PVC – regional and continental releases 

Conversionf

(processing) C16–17

impurities

 2.0 2.0 

Paints and C18–20 negligible negligible 300 negligible negligible varnishes 

Formulation 

C16–17

impurities

negligible negligible 300 negligible negligible 

Industrial C18–20 0.06 300 180 application of paints (Processing) 

C16–17

impurities

 0.010 300 31 

Table G2 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 327

Table G2 continued 

Estimated local release Estimated regional release 

(kg/year) 

Use Comment Type of 

LCCP 

air (kg/day)

waste water (kg/day) 

no of daysj 

air waste 

waterg 

soilm 

Paints and C18–20 negligible varnishes 

Application by general public (private use) 

C16–17

impurity 

negligible 

C18–20 4x10-4 5×10-4 Formulation <10 I I 

C16–17

impurity 

7×10-5 9×10-5 <10 

C18–20 0.30 

0.60 

Use in oil- 300 based fluids (processing; small site) 

C16–17

impurity 

 0.051 

0.10 

 I 

C18–20 0.025 (plus 

an intermittent discharge of 25 kg/event) 

300 

Metal cutting/ working fluids 

Use in emulsifiable fluids (processing) 

C16–17

impurity 

4.3×10-3

(plus 4.3 kg/event) 

C18–20 0.055i 0.15i Leather fat 300 17 49 

liquors 

Formulation 

C16–17

impurity 

9.4×10-3

i 

0.026i 300 2.9 8.3 

 Use – C18–20 0.9 100 332 

complete processing of raw hides 

C16–17impurity 

 0.15 100 56 

Table G2 continued overleaf 
328 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table G2 continued 

Estimated local release Estimated regional release 

(kg/year) 

Use Comment Type of 

LCCP 

air (kg/day)

waste water (kg/day) 

no of daysj 

air waste 

waterg 

soilm 

Textiles C18–20 8.3 4.3 300 I I 

C16–17

impurity 

1.4 0.73 300 

C18–20 18,060–

25,270 

10+ 881–1,550k 

881–1,550 

Articles – volatile and leaching loss 

Service life 

C16–17

impurity 

 3,070–

5,296 

1.7+ 150–264k 

150–264 

C18–20 8 1,986–

2,072k +87–

157 

5,981–6,241 

“Waste remaining in the environment” 

Service life and disposal 

C16–17

impurity 

 1.4 338–352k + 

15–27 

1,017–1,061 

C18–20 18,098– 

25,308 

541–597 via WWTP 3,002–3,771 direct to surface water 

6,862– 7,791 

Total emissions 

C16–17

impurity 

 3,077– 

4,302 

92–101 via WWTP 510–641 direct to surface water 

1,167– 1,324 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 329

Notes: a Open systems (as defined in OECD, 2004b). 

b Partially open systems (as defined in OECD, 2004b). c Closed systems (as defined in OECD, 2004b). d Continental release = total EU release - regional release. e Releases estimated from OECD (2004b) assuming that 50 per cent of the initial release to air will co

waste water. 

f Regional and continental releases from conversion assume 50 per cent of sites have air emission c

of the industry with such controls is unknown, but is likely to be higher than this figure. 

g An 80 per cent connection rate to waste water treatment plants will be assumed. h Releases from car underbody coating and sealing, and rotational moulding are thought to be negligi Industry-specific release information is also available and has been used to estimate the PEClocal in j Number of days/year over which the local emission occurs. k Emissions occur directly to surface water. m Direct emissions to urban/industrial soil. 

con = confidential information – the regional and continental releases from this source are small com

other sources. 
330 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table G3 Data used for EUSES modelling of C16–17 impurities 

Property Value 

Molecular weight 488 g/mole 

Melting point 0oC 

Boiling point >200o

C 

Vapour pressure 2.7×10-4 Pa at 25o

C 

Log octanol-water partition coefficient (log Kow) 7 

Water solubility 0.027 mg/l 

Organic carbon-water partition coefficient 5.89×105

 l/kg 

Fish bioconcentration factor 1,087 l/kg 

BMF 1 (TGD method) 

1–3 (alternate method) 

Earthworm bioconcentration factor 5.6 kg/kg 

Biodegradability Not degradable 

Rate constant for reaction with atmospheric hydroxyl 

radicals (kOH) 

8×10-12 cm3

 molecule-1 s-1 

Regional concentration in surface watera 0.1 μg/l 

Regional concentration in sediment 0.7 mg/kg wet wt. 

Regional concentration in agricultural and natural 

soila 

0.088 mg/kg wet wt. 

PNEC for surface water 1 μg/l 

PNEC for sediment 5 mg/kg wet wt. 

PNEC for soil 10.6 mg/kg wet wt. 

PNEC for secondary poisoning 10 mg/kg foodb 

Notes: a In the medium-chain chlorinated paraffins assessment, the regional 

concentrations in surface water, sediment and agricultural soil were derived 

based on the available monitoring data, which would include the contribution 

from all sources of C14–17 chlorinated paraffins, including the impurities present 

in LCCPs. 

b

 The PNECoral for medium-chain chlorinated paraffins in the published risk 

assessment is currently 0.17 mg/kg. However, since the assessment was 

published further information has become available that shows that the actual 

NOAEL from mammalian studies for medium-chain chlorinated paraffins is 

around 300 mg/kg food for repeated dose exposure (90-day studies) and 100–

1,000 mg/kg food for reproduction. Applying an assessment factor of 30 to 

these data would give a revised PNECoral of 10 mg/kg food based on the 

repeated dose studies and 3.3–33 mg/kg food based on the reproduction 

endpoints. The PNECoral of 10 mg/kg food is considered to be most reliable for 

medium-chain chlorinated paraffins as the effects seen at 1,000 mg/kg food in 

the reproduction study were not statistically significant from controls and this 

dose level was thought to be very close to the true NOAEL from this study. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 331

Table G4 Estimated PEC/PNEC ratios for surface water 

Scenario Step Estimated PEC 

for C16–17 impurity 

(μg/l) 

PEC/PNEC 

Production Generic 0.12 0.12 

Compounding (O) 0.11 0.11 

Conversion (O) 0.11 0.11 

Use in PVC – 

plastisol 

applications Compounding/conversion 

(O) 

0.12 0.12 

Compounding (O) 0.11 0.11 

Compounding (PO) 0.18 0.18 

Compounding (C) 0.11 0.11 

Conversion (O) 0.11 0.11 

Conversion (PO) 0.11 0.11 

Conversion (C) 0.11 0.11 

Compounding/conversion 

(O) 

0.13 0.13 

Compounding/conversion 

(PO) 

0.19 0.19 

Use in PVC – 

extrusion/other 

Compounding/conversion 

(C) 

0.12 0.12 

Formulation negligible <1 

Industrial application 0.12 0.12 

Use in paints 

Domestic application negligible <1 

Formulation 0.10 0.10 

Use in oil based fluids 

(small site) 

0.20–0.29 0.20–0.29 

Use in emulsifiable fluids 0.11 0.11 

Metal cutting/ 

working fluids 

Use in emulsifiable fluids 

– intermittent release 

8.1 8.1 

Use in leather Formulation 0.13 0.13 

fat liquors Use – complete 

processing of raw hides 

0.38 0.38 

Textiles 1.5 1.5 
332 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table G5 Estimated PEC/PNEC ratios for sediment 

Scenario Step Estimated PEC 

for C16–17

impurity (mg/kg 

wet wt.) 

PEC/PNEC 

Production Generic 1.5 0.30 

Compounding (O) 1.4 0.28 

Conversion (O) 1.4 0.28 

Use in PVC – 

plastisol 

applications Compounding/conversion 

(O) 

1.5 0.30 

Compounding (O) 1.5 0.30 

Compounding (PO) 2.3 0.46 

Compounding (C) 1.4 0.28 

Conversion (O) 1.4 0.28 

Conversion (PO) 1.4 0.28 

Conversion (C) 1.4 0.28 

Compounding/conversion 

(O) 

1.6 0.32 

Compounding/conversion 

(PO) 

2.4 0.48 

Use in PVC – 

extrusion/other 

Compounding/conversion 

(C) 

1.5 0.30 

Formulation negligible <1 

Industrial application 1.5 0.30 

Use in paints 

Domestic application negligible <1 

Formulation 1.3 0.26 

Use in oil based fluids 

(small site) 

2.5–3.7 0.50–0.74 

Use in emulsifiable fluids 1.4 0.28 

Metal cutting/ 

working fluids 

Use in emulsifiable fluids 

– intermittent release 

104 or 2.0–3.1 21 or 0.40–0.62 

Use in leather Formulation 1.7 0.34 

fat liquors Use – complete 

processing of raw hides 

4.9 0.98 

Textiles 19 3.8 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 333

Table G6 Estimated PEC/PNECPNEC ratios for agricultural soil 

Scenario Step Estimated PEC 

for C16–17

impurity (mg/kg 

wet wt.) 

PEC/PNEC 

Production Generic negligible <1 

Compounding (O) 0.16 0.015 

Conversion (O) 0.16 0.015 

Use in PVC – 

plastisol 

applications Compounding/conversion 

(O) 

0.24 0.023 

Compounding (O) 0.22 0.021 

Compounding (PO) 0.80 0.075 

Compounding (C) 0.15 0.014 

Conversion (O) 0.20 0.019 

Conversion (PO) 0.21 0.020 

Conversion (C) 0.19 0.018 

Compounding/conversion 

(O) 

0.33 0.031 

Compounding/conversion 

(PO) 

0.92 0.086 

Use in PVC – 

extrusion/other 

Compounding/conversion 

(C) 

0.25 0.024 

Formulation negligible <1 

Industrial application 0.26 0.025 

Use in paints 

Domestic application negligible <1 

Formulation 0.090 8.5×10-3 

Use in oil based fluids 

(small site) 

0.97–1.8 0.092–0.17 

Use in emulsifiable fluids 0.16 0.015 

Metal cutting/ 

working fluids 

Use in emulsifiable fluids 

– intermittent release 

47 4.4 

Use in leather Formulation 0.54 0.051 

fat liquors Use – complete 

processing of raw hides 

2.7 0.25 

Textiles 13 1.2 
334 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table G7 Estimated PEC/PNEC ratios for secondary poisoning 

Estimated PEC for 

C16–17 impurity 

(mg/kg) 

Scenario Step PEC/PNEC 

Fish Earthworm Fish Earthworm

Production Generic 0.12–

0.48 

negligible 0.012–

0.048 

<1 

Compounding (O) 0.11–

0.44 

0.69 0.011–

0.044 

0.069 

Conversion (O) 0.11–

0.44 

0.69 0.011–

0.044 

0.069 

Use in PVC 

– plastisol 

applications 

Compounding/conversion 

(O) 

0.11–

0.44 

0.92 0.011–

0.044 

0.092 

Compounding (O) 0.11–

0.44 

0.86 0.011–

0.044 

0.086 

Compounding (PO) 0.11–

0.44 

2.5 0.011–

0.044 

0.25 

Compounding (C) 0.11–

0.44 

0.67 0.011–

0.044 

0.067 

Conversion (O) 0.11–

0.44 

0.81 0.011–

0.044 

0.081 

Conversion (PO) 0.11–

0.44 

0.83 0.011–

0.044 

0.083 

Conversion (C) 0.11–

0.44 

0.78 0.011–

0.044 

0.078 

Compounding/conversion 

(O) 

0.11–

0.44 

1.2 0.011–

0.044 

0.12 

Compounding/conversion 

(PO) 

0.11–

0.44 

2.8 0.011–

0.044 

0.28 

Use in PVC 

– extrusion/ 

other 

Compounding/conversion 

(C) 

0.11–

0.44 

0.95 0.011–

0.044 

0.095 

Formulation negligible negligible <1 <1 

Industrial application 0.12–

0.48 

0.97 0.012–

0.048 

0.097 

Use in 

paints 

Domestic application negligible negligible <1 <1 

Formulation 0.11–

0.44 

0.50 0.011–

0.044 

0.050 

Use in oil based fluids 

(small site) 

0.15–

0.76 

3.0–5.3 0.015–

0.076 

0.30–0.53 

Use in emulsifiable fluids 0.11–

0.44 

0.69 0.011–

0.044 

0.069 

Metal 

cutting/ 

working 

fluids 

Use in emulsifiable fluids 

– intermittent release 

0.13–

0.52 

132 0.013–

0.052 

13.2 

Formulation 0.11–

0.44 

1.8 0.011–

0.044 

Use in 0.18 

leather fat 

liquors Use – complete 

processing of raw hides 

0.15–

0.60 

7.8 0.015–

0.060 

0.78 

Textiles 0.72–2.9 37 0.072–

0.29 

3.7 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 335

The resulting analysis indicates that PEC/PNEC ratios >1 could occur for surface 

water, sediment, soil and secondary poisoning from the intermittent release of LCCP 

product used in emulsion metalworking/cutting fluids, and from their use in textiles. For 

the intermittent release scenario for metalworking/cutting fluids, it is not clear if C18–20

liquid chlorinated paraffins are actually used in this application. In addition, it is likely 

that at most sites in the EU the spent emulsion fluid is treated prior to discharge to the 

environment (the emulsion is likely to be split and the oil-phase separated for suitable 

disposal), so an actual risk from this use is unlikely to occur in reality. For the textile 

use, very little information is currently available on the process used, or the amounts of 

C18–20 liquid chlorinated paraffins that could be released from the process. The current 

scenario is based entirely on worst case default assumptions. Further information on 

the actual emissions from this process could therefore refine the PECs for this 

scenario. 

It should be noted that in this assessment, the background regional concentration has 

been assumed to be that from C14–17 chlorinated paraffins, not just the C16–17

chlorinated paraffins. This assumption is likely to overestimate the actual contribution 

from the C16–17 fraction. 
336 Science Report: Environmental risk assessment: long-chain chlorinated paraffins

Appendix H Chloroalkenes 

(chlorinated olefins) 

1 Introduction 

During the evaluation of long-chain chlorinated paraffins, some information has been 

identified for a related chemical group, the chloroalkenes or chlorinated olefins. The 

following two CAS numbers appear to be relevant (these are used on the US TSCA 

Inventory list and the Canadian Domestic Substance List (DSL)). 

Alkenes, polymerized, chlorinated CAS No 68410-99-1 (not on EINECS) 

Alkenes, C12-24, chloro CAS No 68527-02-6 (EINECS no. 271-247-

1) 

2 Production and Use 

Euro Chlor has confirmed that chlorinated olefins are not manufactured in the EU but 

the Chlorinated Paraffins Industries Association (CPIA) have indicated that they are 

produced in North America. It should also be noted that other manufacturers of 

chlorinated paraffins are known to exist in Asia. There is no information about 

whether or not they might produce such compounds. Company specific details have 

been retrieved from Industry product literature, including Internet websites (where 

available). Further details are provided in a confidential annex. This can be made 

available to regulatory authorities on request. Non-confidential information on the 

substances manufactured under CAS No 68410-99-1 and CAS No 68527-02-6 is 

available in the USEPA Inventory Update Reporting IUR database for 20061

. This 

indicates that in 2005 there were two companies producing substances under both of 

these CAS numbers. The uses given for both CAS Numbers are lubricants and 

flame retardants. 

A search of the internet has identified information on some of these products (either 

formerly supplied or currently supplied). The products appeared under the trade 

name CHLOROWAX with the CAS number 68527-02-6, which referred to “Alkenes, 

C12-C24 Chloro”. The CAS number 68927-02-6 also appeared on some of the 

literature for these products but this was probably an error. 

The product description did not distinguish between the chlorinated paraffins and 

chlorinated alpha-olefins in terms of the possible applications, and no details of the 

actual uses of the chlorinated alpha-olefins were given. 

The Material Safety Data Sheet (MSDS) gave chemical formulas for these 

substances that indicated they may have been of a single carbon chain length, 

although this was by no means clear. A range of chlorine contents was given. This 

probably reflected the variation between batches in the chlorination reaction. 

 

1

 Available at http://www.epa.gov/opptintr/iur/tools/data/index.htm (accessed on 6th March 2009). 
337 Science Report: Environmental risk assessment: long-chain chlorinated paraffins

The products identified have similarities with chlorinated paraffins are shown in 

Table H1. As can be seen at least one of these substances has some similarity to 

long-chain chlorinated paraffins. Example formulae were given in the MSDS. These 

indicate that the products were actually effectively chlorinated alkanes rather than 

alkenes (formulae for alkenes would require two less hydrogen atoms/molecule) – 

however, there were several inconsistencies in the MSDS and so this information 

should be treated with caution. This company appeared to make no clear distinction 

between its chlorinated alpha-olefin products and its chlorinated paraffin products 

(they are all sold under the trade name CHLOROWAX, although the alpha-olefin 

products have AO at the end of the name). This means that there is the possibility 

that they could be used interchangeably in some or all applications, although reliable 

information on the actual uses is not available. 

H1 Former commercial chlorinated alkenes of relevance to chain 

chlorinated paraffins 

Trade Name Carbon chain length Example formula Chlorine content 

Chlorowax 500AO C12 C12H20Cl6 57-60% 

Chlorowax 45AO C12 C12H23Cl3 40-43% 

Chlorowax 52AO C12 C12H21Cl5 51.0-53.5% 

Chlorowax 54-120AO C16 C16H28Cl6 53-55% 

Chlorowax 100AO C21? C21H39Cl5 38-40.5% 

3 Possible environmental effects of chlorinated alkenes 

Few details are available on how the chlorinated alkenes were made. It is most 

likely that they were produced in a similar way as the chlorinated paraffins, which is 

by free radical chlorination. 

As olefins contain carbon-carbon double bonds, it is possible that addition of chlorine 

to this double bond could occur during the chlorination reaction, as well as 

substitution of chlorine for hydrogen along the alkyl chain. If chlorine addition to the 

double bond does occur, then the product of the reaction would essentially be a 

chlorinated paraffin rather than a chlorinated olefin. The available information is a 

little unclear as to exactly how these chlorination reactions would proceed and hence 

what the exact products would be. However, mechanistic organic chemistry books 

indicate that the hydrogen substitution reactions would generally become more 

favoured over the chlorine addition reaction to the double bond as the temperature is 

raised. Thus the actual products may be dependent on the reaction conditions used, 

and so may be a mixture of chlorinated paraffins and chlorinated olefins. 

In this respect, several studies included in the respective risk assessment reports for 

short-, medium and long-chain chlorinated paraffins have used various alkene 

feedstocks in order to synthesise chlorinated paraffins of known structure by gasphase free-radical chlorination. The products from these reactions were chlorinated 

paraffins derived by chlorine addition across the double bond. The properties (water 

solubility, vapour pressures, accumulation behaviour and toxicity to fish) of these 

products were in line with those obtained for chlorinated paraffins produced by the 

chlorination of an alkane feedstock. Again, the properties of these products were 
338 Science Report: Environmental risk assessment: long-chain chlorinated paraffins

found to depend on the carbon chain length and degree of chlorination. This 

indicates that chlorinated alkenes, if produced in this manner, would be expected to 

be effectively indistinguishable from chlorinated alkanes in terms of the 

environmental behaviour and effects. 

4 Summary 

Euro Chlor has confirmed that there is no European manufacture of chlorinated 

alkenes. However, the CPIA have confirmed that they are produced in the United 

States (two manufacturers existed in 2005) The situation in Asia is unknown. The 

products formed from the chlorination of alkenes are expected to have a similar 

environmental hazard profile as the equivalent chlorinated paraffin. Their uses are 

unknown, but would be expected to be similar to the equivalent chlorinated paraffin 

as well. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 339

Appendix I Comparison of the 

mammalian toxicity of short-, 

medium- and long-chain 

chlorinated paraffins 

I1 Comparison of short-, medium and long-chain products 

A detailed comparison of the known physico-chemical and toxicological properties of 

the three chlorinated paraffin categories is presented in Table I1.Concerning physicochemical properties, all the categories of chlorinated paraffins are liquids at normal 

temperature and pressure, except for the LCCP C>20 70% Cl products which are solid. 

All have relatively low vapour pressure. All have relatively high log Kow values, which 

tend to increase with increasing carbon chain length. Water solubility tends to decease 

with increasing chain length. These differences in log Kow and water solubility would 

suggest that the extent of systemic absorption of the longer chain chlorinated paraffins 

might be less (and therefore toxicity would be lower), but this prediction is not 

supported by the available toxicity information. The influence of the degree of 

chlorination on log Kow and water solubility cannot be determined from the information 

available. 

Concerning toxicity, all short-, medium- and long-chain chlorinated paraffins that have 

been tested are of low acute toxicity and many can cause slight skin and eye irritation. 

Two tested short-chain products were not skin sensitisers, but one of two tested LCCP 

products had skin sensitising properties; no skin sensitisation data are available for the 

medium-chain substances. 

Although N(L)OAELs for repeated dose toxicity for tested members of the three 

categories of chlorinated paraffins are generally similar, there are qualitative 

differences in the repeated exposure toxicity. The liver is the main target organ for the 

LCCPs whereas the kidney is the main target organ of relevance to humans for the 

short- and medium-chain products. Testing of all the categories of chlorinated paraffins 

for genotoxicity is limited; all the available tests are negative. 

A short-chain product was carcinogenic in a rodent model (causing kidney tumours), 

although there are uncertainties regarding the relevance of this finding for humans. An 

LCCP product caused carcinogenicity in a rodent model (malignant lymphomas), but 

only at extremely high exposure levels. No medium-chain products have been tested 

for carcinogenicity. 

Fertility studies have been conducted only on the medium-chain chlorinated paraffins, 

in which no evidence of effects was seen. No effects on the reproductive organs have 

been seen in the repeated dose toxicity studies conducted on members of all three 

categories of the chlorinated paraffins. No specific effects on development have been 

seen in conventional developmental toxicity studies conducted on short-, medium- or 

long-chain products. A medium-chain product caused maternal deaths at the time of 

parturition and deaths of neonatal offspring due to haemorrhaging resulting from low 

vitamin K levels; the potential to cause such effects has not been investigated for shortor long-chain chlorinated paraffins. 
340 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Overall, the data relating to investigated human/mammalian health endpoints for the 

three categories of product are generally similar, indicating that carbon chain length 

has little identifiable influence on toxicity. Thus, a read-across between the three 

classes has some justification. 

However, any read-across needs to be conducted cautiously because some 

differences in the toxicity profiles have been identified, notably qualitative differences 

with respect to repeated dose toxicity and carcinogenicity and in skin sensitising 

potential. There is also no information on the influence of a product’s chlorination state 

on its toxicity. Finally, as a category, the LCCPs have been defined with a wide range 

of carbon chain lengths (C18–30), but the toxicity of only those with lengths in the middle 

of the range has been investigated. 

To account for these uncertainties any read-across predictions between the chlorinated 

paraffins have been conducted using conservative assumptions and additional 

assessment factors have been used in the risk assessment where appropriate. 

I2 References 

ECB, 2000 European Union Risk Assessment Report: Alkanes, C10–13, chloro. Series: 

1st Priority List, Volume 4. European Commission, Joint Research Centre, Institute for 

Health and Consumer Protection, European Chemicals Bureau. 

ECB, 2007 European Union Risk Assessment Report: Alkanes, C14–17, chloro. Final 

draft human health assessment report of September 2007 for submission to SCHER. 

R331_0907_hh, European Commission, Joint Research Centre, Institute for Health and 

Consumer Protection, European Chemicals Bureau. 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 341

Table I1 Summary of the available physico-chemical and toxicity data for the three categorie

Property SCCPs (C10–13) MCCPs (C14–17) LCCPs 

Physical state at normal temp/pressure 

Liquid (49–70% Cl) Liquid (40–60% Cl) Liquid 

Liquid 

Solid (C

Boiling point > 200oC > 200oC > 200o

Density 1.2–1.6 g/cm3 (49–70% Cl, 25°C) 1.1–1.3 g/cm3 (40–50% Cl, at 25°C) 1.1–1.6 

Vapour pressure 2.1x10-2 Pa (50% Cl, 40°C) 2.7x10-4 Pa (52% Cl, 20°C) 2.7x10

Log Kow 4.4–6.9 (49% Cl) 

5.4–8.0 (71% Cl) 

5.5–8.0 (45% Cl) 5.5–8.0 (52% Cl) 

7.63–>

Water solubility (at 20°C) 

0.15–0.47mg/l (59% Cl, 20°C ) 0.005–0.027 mg/l (?% Cl, 20°C) 0.003 m

0.0059 

Classification Carc Cat 3 R40 No Annex 1 entry. R64, R66 proposed No Ann

Toxicokinetics Limited information. For oral route 

~60% absorption, possibly greater for shorter chains and lower chlorination states. No inhalation or dermal data. 

~50% absorption by oral and inhalation routes, 1% by dermal route. Preferential distribution to fatty tissues. Found in breast milk 

Few da

Acute Inhalation: 48 g/m3 for 1 h, C? 50% Cl: 

slight eye nose irritation Oral: very low toxicity; some signs of toxicity at 2 g/kg Dermal: no systemic toxicity at ~2.5 g/kg 

Oral data only: very low toxicity; clinical signs at 15 g/kg 

Oral daconduc

availabtoxicity 

Irritation C10–13, 59 & 63% Cl: very slight skin 

and eye irritation 

Slight skin and eye irritation (40–51% Cl). Assumed to cause skin dryness or cracking on repeated exposure. 

C19–30, 

slight s

Sensitisation C10–13, 50 & 56% Cl negative No data C22–26, 

C18–27 4

negativ

Table I1 continued overleaf 
342 Science Report: Environmental risk assessment: long-chain chlorinated paraffins 

Table I1 continued Property SCCPs (C10–13) MCCPs (C14–17) LCCPs Repeated dose toxicity 

Oral only, for C10–13, C12, C10–12 52–60% 

Cl. Liver, thyroid identified as target organs in rodents, but these changes were considered unlikely to be relevant to humans. Reduction in bodyweight gain and increase in kidney weight considered relevant to human health: NOAEL 100 mg/kg in rats. 

Oral only, for C14–17, 52% Cl. Liver, 

thyroid, kidney target organs. Liver changes considered adaptive. Thyroid changes seen in rats considered to be not relevant to humans. NOAEL 23 mg/kg/day, based on kidney toxicity. 

Oral onavailab(either 

LCCP 

Liver idKidneyidentifie100 mgand a N70% C

Genotoxicity Data for 50–60% Cl: Ames negative 

(C10–13, C12); in vitro mammalian gene 

cell mutation negative (C10–13); in vivo 

chromosome aberration negative (C10–

12), dominant lethal negative (C10–12) 

Data for C14–17, 40 & 52% Cl: Ames 

negative, in vivo bone marrow chromosomal aberration and micronucleus negative 

Ames n

42% C

In vitro 

C23, 43

In vivo 

43% C

Carcinogenicity Data for C12 60% Cl: in rodents, 

increased incidence of tumours in liver, thyroid, kidney. The 1st two considered 

to be not relevant to humans. Uncertainly regarding the relevance of the kidney tumours, hence Carc Cat 3 classification. Risk assessment assumed no risk of tumour development below the NOAEL for kidney toxicity 

No data Data fo

Rat: mmedullfemale consideof carcMice: ilymphoprovidicarcinohepato5000 mconvinc

Table I1 continued overleaf 
Science Report: Environmental risk assessment: long-chain chlorinated paraffins 343

Table I1 continued Property SCCPs (C10–13) MCCPs (C14–17) LCCPs Reproductive toxicity 

No fertility studies, but reproductive organs not affected in RDT studies. Negative in rat (C10–13, 58% Cl) and 

rabbit (C10–12, 58% Cl) developmental 

toxicity studies 

Most data are for C14–17, 52% Cl. No 

effects on fertility. Maternal deaths at time of parturition at 538 mg/kg/day, due to reduced vitamin K levels. No effects in conventional developmental toxicity studies. Pup deaths at maternal doses of ~74 & 463 mg/kg/day, due to reduced vitamin K levels – NOAEL of 47 mg/kg/day identified. 

No fertorgans DeveloC22–25, 

negativC22–26, increasmg/kg/C22–26, 

Main literature reference 

European Union Risk Assessment Report for Alkanes C10–13, Chloro (ECB, 

2000). 

European Union Risk Assessment Report for Alkanes, C14–17, Chloro, draft 

(ECB, 2007). 

This re

Notes: SCCPs = short-chain chlorinated paraffins; MCCPs = medium-chain chlorinated paraffins; LCCPs = long
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