U.S. Environmental Protection Agency Draft, 12/9/200 9 U.S. Government Internal Deliberative Document, Do Not Quote, Cite, or Release

1 Short-Chain Chlorinated Paraffins (SCCPs)

I. Overview

To support its initial decision to proceed to commence action under TSCA, EPA considered SCCPs toxicity, persis tence, ability to bioaccumulate, widespread exposure, and their demonstrated ability to be transported globally. Ba sed on those factors, as well as the availability of viable substitutes for certain uses of SCCPs, EPA intends to initiate action to address the manufacturing, processing, distribution in commerce, and use of SCCPs.

EPA intends to further evaluate whether the manufacturing, processing, distribution in

commerce and/or use of medium chained chlo rinated paraffins (MCCPs) and long-chained chlorinated paraffins (LCCPs) should also be addressed.

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

II. Introduction

As part of EPA's efforts to enhance th e existing chemicals program under the Toxic Substances Control Act (TSCA) 1 , the Agency identified an ini tial list of widely recognized chemicals, including SCCPs, for action plan de velopment based on their presence in human blood; persistent, bioaccum ulative, and toxic (PBT) 2 characteristics; use in consumer products; production volume; and other similar factors. This Action Plan is based on EPA’s initial review of readily available use, exposure, and hazard information 3 on SCCPs. EPA considered which of the various authorities provided under TSCA and other statutes mi ght be appropriate to address potential concerns with SCCPs in developing th e Action Plan. The Action Plan is intended to describe the courses of action the Agency plan s to pursue in the near term to address its

concerns. The Action Plan does not constitute a final Agency determination or other final Agency action. Regulatory proceedings indicate d by the Action Plan will include appropriate opportunities for public and stakeholder i nput, including through notice and comment rulemaking processes.

III. Scope of Review

Chemical Identity For the purposes of this action plan, SCCPs in clude the chlorinated paraffins that meet the following definition:

1 15 U.S.C. §2601 et seq.

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

. 3 Information sources customarily employed include Inventory Update Reporting (IUR) submissions; Toxic Release Inventory (TRI) reporting; data submitted to the HPV Challenge Program; existing hazard and risk assessments performed by domestic and international authorities includi ng but not limited to U.S. Federal government agencies, the Organization for Economic Cooperation and Development, the Stockholm Convention on Persistent Organic Pollutants, Health and Environment Canada, the European Union; and others. Action plans will reference specific

sources used.U.S. Environmental Protection Agency Draft, 12/9/200 9 U.S. Government Internal Deliberative Document, Do Not Quote, Cite, or Release

2 C

x H

(2x-y+2 )Cl y where x = 10-13; y = 3-12; and the average chlorine content ranges from a pproximately 40 to 70 percent with the limiting

molecular formulas set at C 10 H 19 Cl 3 and C 13 H l6 Cl 12 . Any individual chemical meeting this

definition is considered an SCCP and is covere d by this action plan. Furthermore, this action plan covers any chemical substan ce or mixture that contains a ch emical that meets the definition. For example, CAS registry number 63449-39- 8 (Paraffin waxes and hydrocarbon waxes, chlorinated) denotes chlori nated paraffin waxes of unsp ecified carbon chain length and unspecified degree of chlorinati on. If a portion of that chemical substance falls within the

definition of SCCPs then the entire substance wo uld be subject to this action plan. Likewise, CAS registry number 71011-12-6 named (Alk anes, C12-13, chloro) would only contain chemicals that meet the alkyl range described in the definition and would be subject to the action plan if any of the chlorine content were consistent with the 40 - 70% criteria.

Medium chained chlorinated paraffins (MCCP; C 14-17 alkyl chain) and long-chained chlorinated paraffins (LCCP; generally C 18 - 28 ) are also discussed in this action plan.

Physical-Chemical Properties

EPA has gathered information on the water solubility, vapor pressure, Henry’s Law constant, and partition coefficient (log K

ow ) data for several different SCCP molecular formulae to characterize the SCCPs category.

In general, water solubility decrease s and Henry’s Law Constant and log K

ow of SCCPs increase with increasing carbon chain length an d increasing chlorine content. Short- and medium- chain length chlorinated paraffins ar e liquids while longer ch ain, higher chlorinated paraffins are solids. The SCCPs are viscous liqui ds at room temperature and normal pressure. Vapor pressure of chlorinated paraffins generally decreases with increas ing MW (a function of number of chlorine atoms). All chlorinated paraffi ns have low to negligib le water solubility but the lower molecular weight chlorinated paraffins can be emulsified by adding an organic cosolvent. The octanol-water partition coefficients (log K

ow ) of chlorinated paraffins range from 4.5 to 12, with SCCPs log K

ow s ranging from approximately 4.5 – 7.4. The log K

ow s are generally above 5, the criteria us ed by many national and internat ional authorities to indicate potential for bioaccumulation because it can be re adily measured and calculated on the basis of

structure.

TSCA Inventory

Only four chlorinated fractions are on the TSCA Inventory [Alkanes, C 6-18 , chloro (CASRN 68920-70-7); Alkanes, C 12-13 , chloro (CASRN 71011-12-6); Alkanes, chloro (CASRN: 61788-76-9); Paraffin waxes and Hydrocarbon waxe s, chloro (CASRN 63449-39-8)]. Other

CASRNs associated with SCCPs are not on the TSCA Inventory. The CASRNs associated with certain MCCPs and LCCPs are also not on the TSCA Inventory.U.S. Environmental Protection Agency Draft, 12/9/200 9 U.S. Government Internal Deliberative Document, Do Not Quote, Cite, or Release

3 IV. Uses and Substitutes Summary

Production Volume

The current use of chlorinated paraffins (S CCP, MCCP, and LCCP) in the United States is on the order of 150 million pounds per year. Pr oduction of short-chain and medium-chained chlorinated paraffins (C 9 to C 17 ) was 100 million pounds in 2007. A very small fraction of that number is attributable to import / export busin ess. According to the Chlorinated Paraffins Industry Association, MCCPs repres ent the largest production and use of chlorinated paraffins in North America while SCCPs is only half that vo lume (CPIA, 2009). Marke ting and use of SCCP has been restricted in the European Union. In Canada, SCCPs are not currently manufactured and use was approximately 3000 metric tons in 2000 and 2001, the latest figures reported (Environment Canada, 2008b). In the U.S., Dover Chemical Corp. is the sole manufacturer of chlorinated paraffins and seve ral companies import SCCPs.

Uses

The largest use of SCCPs in the United Stat es is as a component of lubricants and coolants in metal cutting and metal forming ope rations. The second-largest use is as both a secondary plasticizer and a flame retardant in plastics, especially PVC. Other minor domestic SCCP uses are as a plasticizer and a flame-reta rdant additive to a variet y of products including: rubber formulations, paints and other coatings, and adhesives and sealants. For safety reasons, other countries (those in the Eur opean Union and Canada) have allowed SCCPs to be used as a flame retardant in underground mining conveyor belts (rubber formulations) and fire retardants

in dam sealants.

Alternatives

MCCPs are alternatives to SCCPs for ma ny applications. Based on their physicalchemical properties, MCCPs are also expected to be persistent in the environment and several field surveys have shown they ar e present in sediments and biota, demonstrating their release to and persistence in the environment. Field-meas ured bioaccumulation fact ors (BAFs) that are greater than 5000 and biomagnifi cation factors (BMF) greater th an 1 indicate that MCCPs are bioaccumulative in biota and can biomagnify in food chains. MCCPs have toxicity to sensitive aquatic organisms that is similar to SCCPs. Ca nada has concluded that MCCPs are “toxic” as defined by the Canadian Environmental Protec tion Act (CEPA). The European Unions’s 2005 Risk Assessment Report and 2007 draft update concl ude that there is a ne ed for limiting the risks posed by certain uses of MCCPs in th e production of PVC and metal cutting.

LCCPs appear to have been used as alte rnatives to SCCPs in some of the more demanding metal working applications (Helsi nki Commission, 2002). LCCPs also appear to have potential as an alternative in the leat her, paints and coatings, sealants and rubber applications. LCCPs are expected to be persiste nt and bioaccumulative in the environment based on their physical-chemical properties and bio accumulation modeling, respectively. Canada has concluded that LCCPs up to C 20 are “toxic” as defined by CEPA (Government of Canada, 2008).

Canada has not made a determinatio n of whether LCCPs greater that C 20 are toxic.U.S. Environmental Protection Agency Draft, 12/9/200 9 U.S. Government Internal Deliberative Document, Do Not Quote, Cite, or Release

4 A number of other potentia l alternatives, e.g. nitroa lkanes, alkyl phosphate and sulfonated fatty acid esters and vegetable oil based products, are available for specific applications. It is stated that these alternatives are considered less harmful than chlorinated paraffins (UNECE, 2006). These non -chlorinated paraffin alternativ es are often more expensive and may require special handling. A UK estimated cost for completely converting SCCPs to nonSCCPs in metal working was predicted to be £ 4 million per year (UNECE). An analysis of costs

conducted in California found that overall metal working processing costs were more expensive for the SCCP alternatives but including other a ssociated costs (clean up and waste removal) made the non-SCCP alternatives competitive (IRTA, 2004).

V. Hazard Identification Summary

Human Health Acute toxicity of SCCPs (C 10-13 ) is very low. SCCPs may cause skin and eye irritation upon repeated application, but do not appear to i nduce skin sensitization. There was no evidence of developmental effects in prenatal developm ental toxicity studies in rats and rabbits.

The liver, kidney and thyroid are major target organs in repeated-dose studies with rats and mice. When administered by gavage, chlorinated paraffins (C 12 , 60% chlorine) are carcinogenic in rats and mice of both sexes (NTP 1986). The underlying mechanisms for the carcinogenicity of SCCP in rats and mice are not clearly know n. SCCP was not mutagenic to

bacteria with or without metabolic activation. Th ere are some indications that the SCCP-induced kidney tumors in male rats are associated with alpha 2  -globin accumulation in hyaline droplets, a mode of action unique to male rats and irrele vant to humans, but this could not be confirmed by immunocytochemical techniques. There ar e also data showing that the liver toxicity/carcinogenicity induced by SCCP is associated with per oxisome proliferation, whereas the thyroid effects are correlated to altered thyroid hormone homeost asis. A number of scientific working groups (including IARC) have conclude d that liver tumors induced by peroxisome proliferators are not relevant to humans. Humans are expected to be much less sensitive to thyroid hormone perturbation than rats and mice.

There is no experimental evidence usi ng human data that demonstrates the carcinogenicity of SCCPs. Chlorinated paraffins (C 12 , 60% chlorine) are listed as reasonably anticipated to be human carcinogens based on sufficient eviden ce of carcinogenicity in experimental animals (11 th Report on Carcinogens, NCI). They are classified by the International Agency for Research on Cancer (IARC) as Group 2B - possibly carcinogenic to humans based on sufficient evidence of carcinogenic ity in experimental animals and mechanistic considerations (IARC, 1990). The Current European Union hazard classification for SCCPs in regard to human health is: Carcinogen Category 3 ( substances which cause concer n for man owing to possible carcinogenic effects but in resp ect of which the available info rmation is not adequate for making a satisfactory assessment) ; limited evidence of a carcinogenic effect.

Health Canada has determined that all chlorinated paraffins (SCCPs, MCCPs and LCCPs) as “toxic” under CEPA.U.S. Environmental Protection Agency Draft, 12/9/200 9 U.S. Government Internal Deliberative Document, Do Not Quote, Cite, or Release

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

Environmental Effects

SCCPs are highly toxic to aquatic in vertebrates following acute (48-hr EC 50 = 0.043 to 11 mg/L) and chronic ( NOEC = 0.005 to 2 mg/L) exposures . In fish high toxicity is associated with chronic exposures, but not fo r acute exposures (96-hr LC 50 = 300 to 10,000 mg/L and NOEC = 0.0096 to 0.05 mg/L). For aquatic plan ts, there is high toxicity a ssociated with both acute and chronic exposures to SCCPs (96-hr EC 50 s range from 0.043 to 0.39 mg/L and NOEC ranges from 0.012 to 0.39 mg/L).

Both Health Canada and Environment Cana da have characteri zed all chlorinated paraffins (SCCPs, MCCPs and LC CPs) as “toxic” under CEPA.

VI. Fate Characterization Summary

Persistence and Bioaccumulation

SCCPs are persistent and bioaccumulative in the environment. The Persistence Organic Pollutant Review Committee (POPRC) of the St ockholm Convention has c oncluded that SCCPs fulfill the criteria put forth in the Stockholm Convention for Persistence and Bioaccumulation (UNEP, 2009). The EU has concluded that SCCPs meets its criteria for both persistent and bioaccumulative (PB) substance and a very persis tent, very bioaccumulative (vPvB) substance. Canada has concluded SCCPs are persistent and bioaccumulative.

SCCPs released to the atmosphere are expe cted to exist in the vapor and particulate phase in the ambient atmosphere given the range of vapor pressu res reported for these substances. Vapor phase constituen ts are degraded in air by reac tion with hydroxyl radicals with half-lives of less than 1 to slight ly greater than 10 days. A half- life greater than about 2 days in the atmosphere can be a significant factor in f acilitating long-range tr ansport of persistent

chemicals.

SCCPs released to water are expected to adsorb to sediment and suspended particulate matter based on log K

oc values. They are stable to hydrolys is and photolysis. Volatilization from water is expected to be mode rate based on estimated Henry’s Law constants of the individual congeners; however, adsorption to suspended so lids and sediment in the water column may

attenuate the rate of volatili zation. No degradation was observed in sediments under anaerobic

conditions. Detection of SCCPs in sediment co res dating back to the 1940s provides evidence that SCCPs are persistent (UNEP, 2009).U.S. Environmental Protection Agency Draft, 12/9/200 9 U.S. Government Internal Deliberative Document, Do Not Quote, Cite, or Release

6 SCCPs released to soil are expected to have low mobility given their log K

oc . Volatilization from moist soil surfaces is expected to be moderate based on estimated Henry’s Law constants of the individual congeners; how ever, adsorption may a ttenuate the rate of volatilization. Based on laboratory a nd field data, SCCPs degrade at negligible to slow rates and thus are persistent.

Measured data indicate SCCPs bioaccumulate in biota. High bioconcentration factors (BCFs) have been measured, ranging from 1,000 to 50,000 for whole body and/or individual tissues in a variety of freshwat er and marine organisms. Fiel d-derived bioaccumulation factors (BAFs) over 1 million were measured for vertebrate species collected from the Great Lakes and

in arctic marine mammals.

Transport

The Henry’s Law constant values for SCCPs im ply partitioning from water to air or from moist soils to air, depending on environmental c onditions and prevailing c oncentrations in each compartment. Evidence that SCCPs undergo such tr ansport is provided by findings that they are globally dispersed in the envir onment and appear in the Arctic (Hüttig, 2005). The Persistent Organic Pollutant Review Committee (POPRC) of the Stockholm Convention on Persistent Organic Pollutants (POPs) decided that evidence is sufficient to conclude that SCCPs meet the screening criterion on po tential for long-range environm ental transport (UNEP 2009). In December 2009 the Executive Body of the Convention on Long-Range Transboundary Air Pollution will consider adding SCCPs to th e POPs Protocol to the Convention.

VII. Exposure Characterization Summary

Releases

SCCPs have the greatest potential for e nvironmental release and exposure of the chlorinated paraffins. The likely sources of releas es for SCCPs are identified as manufacturing and lubricant applications. In 2000 and 2001, nearly all usage of SCCPs wa s reported to be in metalworking applications. Losses from the use of SCCPs in paint and sealants are generally regarded as much lower than those from me talworking. Releases of SCCPs may occur during production, storage, transportati on, industrial and consumer us age of chlorinated paraffincontaining products, disposal and burning of wa ste, leaching, runoff or volatilization from landfills, and sewage sludge or other waste disposal sites (Tomy et al., 1998).

Major sources of releases of chlorinated pa raffins into the environment are likely the formulation and manufacturing of products containing chlorinated paraffins and use in metalworking fluids as an extreme pressure ad ditive. EPA estimated releases of SCCPs during metalworking fluid use have been estimated us ing generic scenario methodology. Releases to wastewater were estimated to be approximately 2,400 kg/site-yr from c ontainer cleaning, dragout (fluid that remains on the part after shaping), disposal of filter media and spent metalworking

fluid. Releases to landfill and incineration from th ese same release sources were estimated to be approximately 900 kg/site-yr using the generic s ite methodology. Incinerators would not be as significant a source.U.S. Environmental Protection Agency Draft, 12/9/200 9 U.S. Government Internal Deliberative Document, Do Not Quote, Cite, or Release

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

Human Exposure

The primary routes of exposure to chlorinate d paraffins include i ngestion, both directly and through contaminated food, and dermal contact with products. Chlorinated paraffins have been isolated from human liver, kidneys, adipos e tissue and breast milk. Due to their potential for environmental transport, SCCP exposure ma y occur from sources far from their use and release. For example, SCCPs have been found in breast milk samples taken from Inuit women.

There is potential inhalation exposure to mists generated dur ing metal shaping operations in SCCPs use in metalworking fluids. EPA esti mated the potential inhalation exposure range from 1.8 to 8.3 mg/day. There is also potential inhalation exposure to mists in uses where products containing SCCPs are spray applied su ch as in paints, adhesives and sealants.

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

Environmental Exposure

In 1986, EPA/OPPT conducted a monitoring st udy of Sugar Creek near the Dover Chemical manufacturing facility in Dover, Oh io. SCCP concentrations of 0.21 μg/L were detected in water at the outfall and 0.3 μg/L in particulates in water upstream from the outfall. Monitoring of a metalworking fl uid end-user on Tinkers Creek did not detect chlorinated paraffins in either filtered wate r or particulates. The report author s thought that this may be due to analytical difficulties. In 1988, a production plant in the same city reported C10-13, 60% chlorine SCCP concentrations of <150-3300 ng/L in water from an impoundment drainage ditch

that received effluent from ch lorinated paraffins (M urray et al., 1988). SCCPs were detected in the Houston Ship Channel in 1978 at levels rang ing from less than 1.0 μg/L to 1.5 μg/L. In 1977, near a Diamond Shamrock Facility on the Grand Ri ver in Painesville, OH, concentrations as high as 3.0 μg/L were detected upstream and downstream from the plant (EPA, 1993).

As summarized in a draft Risk Profile prep ared by the POPs Review Committee of the Stockholm Convention, SCCPs have been measur ed in a variety of environmental media including air, sediment, surface waters, and wastew ater in North America, Europe, Japan, and/or the Arctic (UNEP, 2009).U.S. Environmental Protection Agency Draft, 12/9/200 9 U.S. Government Internal Deliberative Document, Do Not Quote, Cite, or Release

8 SCCPs have also been measured in a variety biota, including freshw ater aquatic species from North America, Europe and the Arctic, mari ne mammals from several locations in Canada and the Arctic, and avian and terrestrial wild life in Europe. In addition, SCCPs have been detected in samples of human breast milk from Canada and the United Kingdom, as well as in a variety of food items from Japan and va rious regions of Europe (UNEP, 2009).

VIII. Risk Management Considerations

Characterization Summary

SCCPs are persistent, bioaccumulative, and toxic to aquatic organisms at low concentrations. They can remain in the envir onment for a significant amount of time and can bioaccumulate in animal tissues, increasing th e probability and duration of exposure. SCCPs continue to be manufactured, imported, processed and used in industrial applications in the United States. Even relatively small releases of these chemicals from individual facilities that manufacture import, process or use these chemicals or releases from waste management facilities have the potential to accumulate over time to higher levels and cause significant adverse impacts on the environment. Thus, a snapshot of i ndustrial and other releases of SCCPs will

underestimate the environmental load ings and burden in biota, and thus potential risks. Indeed,

SCCPs have been measured in biota and various environmental media, including in terrestrial as well as aquatic organisms.

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

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

IX. Next Steps

EPA is addressing the discrepancy between th e specific chlorinated paraffins companies are actually manufacturing or importing and those listed on the TSCA Inventory. Only a subset of the chlorinated paraffin fractions being manuf actured or imported is on the TSCA Inventory. EPA intends to require companies to submit Pr e-Manufacture Notices for the SCCPs, MCCPs,

and LCCPs fractions that are not on the TSCA In ventory and, if appropr iate, would initiate action under TSCA § 5 to addre ss the potential risks posed by such SCCPs, MCCPs and LCCPs.

Concurrently, EPA intends to initiate action under TSCA § 6(a) to ban or restrict the manufacture, import, processing or distribution in commerce, export, and use of SCCPs based on the persistence, bioaccumulation and toxicity of SCCPs and thei r presence in the environment.

EPA intends to further evaluate whether the manufacturing, processing, distribution in commerce, use and/or disposal of MCCPs and LCCPs should also be addressed under TSCA § 6(a).U.S. Environmental Protection Agency Draft, 12/9/200 9 U.S. Government Internal Deliberative Document, Do Not Quote, Cite, or Release

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

--------------- --------------- ------------ References:
Chlorinated Paraffins Industry Associati on (CPIA) website. Accessed April 1, 2009. http://www.regnet.com/cpia/status_report.html ECHA 2008a. Data on Manufacture, Import, Export, Uses and Releases of Alkanes, C10-13, Chloro, SCCPs...; 2008. http://echa.europa.eu/doc/consultations/recommendations /tech_reports/tech_rep_alkanes_chloro.pdf ECHA 2008b. Agreement of the Memb er State Committee on Identification of Alkanes, C10-13, Chloro (SCCP) as a Substance of Very High Concern. 8 October 2008. http://echa.europa.eu/doc/about/organisation/msc/agreements_svhc/msc_svhc_agreement_sccp.pdf
ECHA 2008c. Data on Manufacture, Import, Export, Uses and Releases of Alkanes, C10-13, Chloro (SCCPs) as well as Alternatives to its Use. 2008.

Environment Canada 2008a. Order Adding Toxic Substances to Schedule 1 to the Canadian Environmental
Protection Act, 1999. Canada Gazette Vol. 142 No. 38 (September 20, 2008). Environment Canada 2008b. Follow-up Report on a PSL1 Assessment for Which Data Were Insufficient to Conclude Whether the Substances Were “Toxic” to the Environment and to the Human Health. August 2008. European Chemicals Agency (ECHA) . Alkanes, C10-13, chloro (SCCPs) : Justification for the Draft Recommendation of Inclusion in Annex XIV; 14 January 2009. http://www.echa.europa.eu/doc/consultations/r ecommendations/justifications/justif_sccps.pdf European Commission (EC), Scientific Committee on Health and Environmental Risks (SCHER). Scientific Opinion on the Risk Assessment Report on Alkanes, C14-17, chloro, MCCP; Human Health Part; 15 January 2008 http://ec.europa.eu/health/ph_risk/c ommittees/04_scher/docs/scher_o_078.pdf Government of Canada. Follow-up Report on a PSL1 Assessment for Which Data Were Insufficient to Conclude Whether the Substances Were “Toxic” to the Environment and to the Human Health. August 2008. Helsinki Commission. Baltic Marine Environment Protection Commision. Project Team for the Implementation of the HELCOM Objectiv e with regard to Hazardous Substan ces 7th Meeting. 11-13 March 2002. Final Report. HSDB, 2008. Hazardous Substances Data Bank. A ccessed, 04/02/09, Chloro nated Paraffins, CASRN

63449-39-8. http://toxnet.nlm.nih.gov/cgi -bin/sis/htmlgen?HSDB Hüttig J and Oehme M. 2005. Presence of Chlorinated Paraffins in Sediments from the North and Baltic

Seas Arch. Environ. Contam. Toxicol. 49, 449–456.

Institute for Research and Techni cal Assistance (IRTA). Alternatives to VOC Emitting Petroleum Based

Lubricants and Chlorinated Paraffin Lubricants: Mi nimizing the Health and Environmental Consequences.

November 2004. Murray, T.M., D.H. Fr ankenberry, D.H. Steele and R.G. Heat h. 1988. Chlorinated paraffins: A report on the findings from two field studies, Suga r Creek, Ohio and Tinkers Creek, Ohio. Vol. 1. Technical report. U.S. Environmental Protection Agency, Washington, D.C. 150 pp. (EPA/560/5 87/012). National Toxicology Program (DHHS). Report on Ca rcinogens, Eleventh Edition; Substance Profile: Chlorinated Paraffins (C12, 60% Chlorine) CAS No. 108171-26-2; Undated. http://ntp.niehs.nih .gov/ntp/roc/eleventh/profiles/s034chlo.pdf National Toxicology Program (DHHS). Toxicology and Carcinogenesis Studies of Chlorinated Paraffins(C12, 60% Chlorine); May 1986. http ://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr308.pdf National Toxicology Program (DHHS). Toxicology and Carcinogenesis Studies of Chlorinated Paraffins(C23, 43% Chlorine); May 1986. http ://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr305.pdf Stanford Research Institute, Chemical Economics Handbook . Page 683.5000 O. Proprietary data source. Stanford Research Institute, Specialty Chemicals , Vol. 7, Flame Retardants . Proprietary data source. Tomy, G.T., A.T. Fisk, J.B. Westmore and D.C.G. Muir. 1998. Environmental chemistry and toxicology of polychlorinated n-alkanes. Rev. Environ. Contam. Toxicol. 158: 53–128. UNEP, 2009. Persistent Organic Pollutants Review Committee. Revised draft risk profile: short-chainedU.S. Environmental Protection Agency Draft, 12/9/200 9 U.S. Government Internal Deliberative Document, Do Not Quote, Cite, or Release

10 chlorinated paraffins. 9 July 2009

. UNEP /POPS/POPRC.5/2. http://chm.pops.int/Convention/ POPsReviewCommittee/hrPOPRCM eetings/POPRC5/POPRC5Document s/tabid/592/language/en-US/Default.aspx United Nations Economic Commission for Europe (UNECE). Short Chain Chlorinated Paraffins Track B

Review for the UNECE LRTAP Task Force on Persistent Organic Pollutants – Final Report. May 2006.United Nations Environment Programme (UNEP): Stockholm Convention on POPs. Summary of shortchained chlorinated paraffins proposal. 7 August 2006. http://www.pops.int/documents /meetings/poprc/chem_review/SCCP/SCCP_Proposal_e.pdf U.S. EPA (Environmental Protection Agency). 1993. RM2 exit briefing on chlorinated paraffins and olefins. Office of Pollution and Prevention of Toxics, Washington, D.C.