U.S. Environmental Protection Agency 12/30/2009 

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

Action Plan 

I. Overview

SCCPs are found world-wide in the environment, wildlife and humans. They are 

bioaccumulative in wildlife and humans, are persistent and transported globally in the 

environment, and toxic to aquatic organisms at low concentrations. Based on these factors, as 

well as the availability of viable substitutes for certain uses of SCCPs, EPA intends to initiate 

action to address the manufacturing, processing, distribution in commerce, and use of SCCPs. 

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

commerce and/or use of medium chained chlorinated paraffins (MCCPs) and long-chained 

chlorinated paraffins (LCCPs) should also be addressed. 

As part of the Agency's efforts to address SCCPs, EPA also intends to evaluate the 

potential for disproportionate impact on children and other sub-populations. 

II. Introduction

As part of EPA’s efforts to enhance the existing chemicals program under the Toxic 

Substances Control Act (TSCA)1, the Agency identified an initial list of widely recognized 

chemicals, including SCCPs, for action plan development based on their presence in humans; 

persistent, bioaccumulative, and toxic (PBT)2 characteristics; use in consumer products; 

production volume; or other similar factors. This Action Plan is based on EPA’s initial review of 

readily available use, exposure, and hazard information on SCCPs. EPA considered which of the 

various authorities provided under TSCA and other statutes might be appropriate to address 

potential concerns with SCCPs in developing the Action Plan. The Action Plan is intended to 

describe the courses of action the Agency plans to pursue in the near term to address its 

concerns. The Action Plan does not constitute a final Agency determination or other final 

Agency action. Regulatory proceedings indicated by the Action Plan will include appropriate 

opportunities for public and stakeholder input, including through notice and comment 

rulemaking processes.

III. Scope of Review

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

the following definition: 

CxH(2x-y+2)Cly

where x = 10-13; 

y = 3-12; and 

the average chlorine content ranges from approximately 40 to 70 percent with the limiting 

molecular formulas set at C10H19Cl3 and C13Hl6Cl12. Any individual chemical meeting this 

definition is considered an SCCP and is covered by this action plan. Furthermore, this action 

 

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/. 

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plan covers any chemical substance or mixture that contains a chemical that meets the definition. 

For example, CAS registry number (CASRN) 63449-39-8 (Paraffin waxes and hydrocarbon 

waxes, chlorinated) denotes chlorinated paraffin waxes of unspecified carbon chain length and 

unspecified degree of chlorination. If a portion of that chemical substance falls within the 

definition of SCCPs then the entire substance would be subject to this action plan. Likewise, 

CASRN 71011-12-6 named (Alkanes, C12-13, chloro) would only contain chemicals that meet the 

alkyl range described in the definition and would be subject to the action plan if any of the 

chlorine content were consistent with the 40 to 70 percent criteria. 

Medium chained chlorinated paraffins (MCCP; C14-17 alkyl chain) and long-chained 

chlorinated paraffins (LCCP; generally C18 - 28) are also discussed in this action plan. 

Only four chlorinated fractions are on the TSCA Inventory [Alkanes, C6-18, chloro 

(CASRN 68920-70-7); Alkanes, C12-13, chloro (CASRN 71011-12-6); Alkanes, chloro (CASRN: 

61788-76-9); Paraffin waxes and Hydrocarbon waxes, chloro (CASRN 63449-39-8)] (EPA, 

2006). Other CASRNs associated with SCCPs are not on the TSCA Inventory. The CASRNs 

associated with certain MCCPs and LCCPs are also not on the TSCA Inventory. 

IV. Uses and Substitutes Summary

The current use of chlorinated paraffins (SCCP, MCCP, and LCCP) in the United States 

is on the order of 150 million pounds per year. Production of short-chain and medium-chained 

chlorinated paraffins (C9 to C17) was 100 million pounds in 2007. A very small fraction of that 

number is attributable to import/export business. According to the Chlorinated Paraffins Industry 

Association, MCCPs represent the largest production and use of chlorinated paraffins in North 

America while SCCPs is only half that volume (CPIA, 2009). Marketing and use of SCCP has 

been restricted in the European Union (ECHA 2008a). In Canada, SCCPs are not currently 

manufactured and use was approximately 3000 metric tons in 2000 and 2001, the latest figures 

reported (Environment Canada, 2008). In the United States, Dover Chemical Corp. is the sole 

manufacturer of chlorinated paraffins and several companies import SCCPs (EPA, 2006). 

The largest use of SCCPs in the United States is as a component of lubricants and 

coolants in metal cutting and metal forming operations. The second-largest use is as both a 

secondary plasticizer and a flame retardant in plastics, especially PVC. Other minor domestic 

SCCP uses are as a plasticizer and a flame-retardant additive to a variety of products including: 

rubber formulations, paints and other coatings, and adhesives and sealants (CPIA, 2009). For 

safety reasons, other countries (those in the European Union and Canada) have allowed SCCPs 

to be used as a flame retardant in underground mining conveyor belts (rubber formulations) and 

fire retardants in dam sealants (ECHA 2008a). 

MCCPs are alternatives to SCCPs for many applications. Based on their physicalchemical properties, MCCPs are also expected to be persistent in the environment and several 

field surveys have shown they are present in sediments and biota, demonstrating their release to 

and persistence in the environment. Field-measured bioaccumulation factors (BAFs) that are 

greater than 5000 and biomagnification factors (BMF) greater than 1 indicate that MCCPs are 

bioaccumulative in biota and can biomagnify in food chains (UNEP, 2009). MCCPs have 

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toxicity to sensitive aquatic organisms that is similar to SCCPs. Canada has concluded that 

MCCPs are “toxic” as defined by the Canadian Environmental Protection Act (CEPA) 

(Government of Canada 2008). The European Union’s 2005 Risk Assessment Report and 2007 

draft update conclude that there is a need for limiting the risks posed by certain uses of MCCPs 

in the production of PVC and metal cutting (EC, 2005, 2007). 

LCCPs appear to have been used as alternatives to SCCPs in some of the more 

demanding metal working applications (HELCOM, 2002). LCCPs also appear to have potential 

as an alternative in leather, paints and coatings, sealants and rubber applications. LCCPs are 

expected to be persistent and bioaccumulative in the environment based on their physicalchemical properties and bioaccumulation modeling, respectively. Canada has concluded that 

LCCPs up to C20 are “toxic” as defined by CEPA (Government of Canada 2008).Canada has not 

made a determination of whether LCCPs greater that C20 are toxic. 

A number of other potential alternatives, e.g. nitroalkanes, alkyl phosphate and 

sulfonated fatty acid esters and vegetable oil based products, are available for specific 

applications. It is stated that these alternatives are considered less harmful than chlorinated 

paraffins (UNECE, 2006). These non-chlorinated paraffin alternatives are often more expensive 

and may require special handling. A UK estimated cost for completely converting SCCPs to nonSCCPs in metal working was predicted to be four million £ per year (IRTA, 2004). An analysis 

of costs conducted in California found that overall metal working processing costs were more 

expensive for the SCCP alternatives but including other associated costs (clean up and waste 

removal) made the non-SCCP alternatives competitive (IRTA, 2004). 

V. Hazard Identification Summary

Human Health Effects 

Acute toxicity of SCCPs (C10-13) is very low (EC, 1999; UNEP, 2009). SCCPs may cause 

skin and eye irritation upon repeated application, but do not appear to induce skin sensitization 

(EC, 1999; UNEP, 2009). There was no evidence of developmental effects in prenatal 

developmental toxicity studies in rats and rabbits (EC, 1999; UNEP, 2009). 

The liver, kidney and thyroid are major target organs in repeated-dose studies with rats 

and mice. When administered by gavage, chlorinated paraffins (C12, 60 percent chlorine) are 

carcinogenic in rats and mice of both sexes (NTP, 1986a; 2005). The underlying mechanisms for 

the carcinogenicity of SCCP in rats and mice are not clearly known. SCCPs were not mutagenic 

to bacteria with or without metabolic activation (NTP 1986a, b). There are some indications that 

the SCCP-induced kidney tumors in male rats are associated with alpha 2μ-globin accumulation 

in hyaline droplets, a mode of action unique to male rats and irrelevant to humans, but this could 

not be confirmed by immunocytochemical techniques. There are also data showing that the liver 

toxicity/carcinogenicity induced by SCCP is associated with peroxisome proliferation, whereas 

the thyroid effects are correlated to altered thyroid hormone homeostasis. A number of scientific 

working groups, including the International Agency for Research on Cancer (IARC), have 

concluded that liver tumors induced by peroxisome proliferators are not relevant to humans 

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U.S. Environmental Protection Agency 12/30/2009 

(IARC, 1990; Klaunig et al., 2003). Humans are expected to be much less sensitive to thyroid 

hormone perturbation than rats and mice. 

There is no experimental evidence using human data that demonstrates the 

carcinogenicity of SCCPs. In the 11th Report on Carcinogens, NCI lists chlorinated paraffins 

(C12, 60 percent chlorine) as reasonably anticipated to be human carcinogens based on sufficient 

evidence of carcinogenicity in experimental animals (NTP, 2005). They are classified by the 

IARC as Group 2B - possibly carcinogenic to humans based on sufficient evidence of 

carcinogenicity in experimental animals and mechanistic considerations (IARC, 1990). 

Health Canada and Environment Canada have characterized all chlorinated paraffins 

(SCCPs, MCCPs and LCCPs) as “toxic” under CEPA (Government of Canada 2008). 

A recent compilation of toxicity data indicates the acute toxicity of MCCPs is low and 

they are not genotoxic. Prenatal developmental toxicity studies in rats and rabbits showed 

reduced fetal body weight. A reproductive toxicity study also showed postnatal developmental 

toxicity as demonstrated by reduced pup body weight, as well as reduced pup survival at higher 

doses; there was no evidence of reproductive toxicity. Repeated-dose studies in rats and dogs 

showed effects on the liver (ECHA, 2008a). 

Environmental Effects 

SCCPs are highly toxic to aquatic invertebrates following acute (48-hr EC50 = 0.043 to 11 

mg/L) and chronic (NOEC = 0.005 to 2 mg/L) exposures. In fish high toxicity is associated with 

chronic exposures, but not for acute exposures (96-hr LC50 = 300 to 10,000 mg/L and NOEC = 

0.0096 to 0.05 mg/L). For aquatic plants, there is high toxicity associated with both acute and 

chronic exposures to SCCPs (96-hr EC50s range from 0.043 to 0.39 mg/L and NOEC ranges 

from 0.012 to 0.39 mg/L) (UNEP, 2009). 

Both Health Canada and Environment Canada have characterized all chlorinated 

paraffins (SCCPs, MCCPs and LCCPs) as “toxic” under CEPA (Government of Canada 2008). 

VI. Physical-Chemical Properties and Fate Characterization Summary

EPA has gathered information on the water solubility, vapor pressure, Henry’s Law 

constant, and partition coefficient (log Kow) data for several different SCCP molecular formulae 

to characterize the SCCPs category (Environment Canada, 2008; HSDB, 2008; UNEP, 2009). In 

general, water solubility decreases and Henry’s Law Constant and log Kow of SCCPs increase 

with increasing carbon chain length and increasing chlorine content. Short- and medium- chain 

length chlorinated paraffins are liquids while longer chain, higher chlorinated paraffins are 

solids. The SCCPs are viscous liquids at room temperature and normal pressure. Vapor pressure 

of chlorinated paraffins generally decreases with increasing MW (a function of number of 

chlorine atoms). All chlorinated paraffins have low to negligible water solubility but the lower 

molecular weight chlorinated paraffins can be emulsified by adding an organic co-solvent. The 

octanol-water partition coefficients (log Kow) of chlorinated paraffins range from 4.5 to 12, with 

SCCPs log Kows ranging from approximately 4.5 to 7.4. The log Kows are generally above 5, the 

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criteria used by many national and international authorities to indicate potential for 

bioaccumulation because it can be readily measured and calculated on the basis of structure 

(UNEP, 2009). 

SCCPs are persistent and bioaccumulative in the environment. The Persistence Organic 

Pollutant Review Committee (POPRC) of the Stockholm Convention has concluded that SCCPs 

fulfill the persistence and bioaccumulation criteria put forth in Annex D of the Stockholm 

Convention on Persistent Organic Pollutants (UNEP, 2009). The EU has concluded that SCCPs 

meets its criteria for both persistent and bioaccumulative (PB) substance and a very persistent, 

very bioaccumulative (vPvB) substance (ECHA 2008b). Canada has also concluded SCCPs are 

persistent and bioaccumulative (Environment Canada 2008). 

SCCPs released to the atmosphere are expected to exist in the vapor and particulate phase 

in the ambient atmosphere given the range of vapor pressures reported for these substances. 

Vapor phase constituents are degraded in air by reaction with hydroxyl radicals with half-lives of 

less than one to slightly greater than ten days. A half-life greater than about two days in the 

atmosphere can be a significant factor in facilitating long-range transport of persistent chemicals. 

SCCPs released to water are expected to adsorb to sediment and suspended particulate 

matter based on log Koc values. They are stable to hydrolysis and photolysis. Volatilization from 

water is expected to be moderate based on estimated Henry’s Law constants of the individual 

congeners; however, adsorption to suspended solids and sediment in the water column may 

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

conditions. Detection of SCCPs in sediment cores dating back to the 1940s provides evidence 

that SCCPs are persistent (UNEP, 2009). 

SCCPs released to soil are expected to have low mobility given their log Koc. 

Volatilization from moist soil surfaces is expected to be moderate based on estimated Henry’s 

Law constants of the individual congeners; however, adsorption may attenuate the rate of 

volatilization. 

Measured data indicate SCCPs bioaccumulate in biota. High bioconcentration factors 

(BCFs) have been measured, ranging from 1,000 to 50,000 for whole body and/or individual 

tissues in a variety of freshwater and marine organisms (Environment Canada, 2008; UNEP, 

2009). Field-derived bioaccumulation factors (BAFs) over one million were measured for 

vertebrate species collected from the Great Lakes and in arctic marine mammals (Environment 

Canada, 2008; UNEP, 2009). 

The Henry’s Law constant values for SCCPs imply partitioning from water to air or from 

moist soils to air, depending on environmental conditions and prevailing concentrations in each 

compartment. Evidence that SCCPs undergo such transport is provided by findings that they are 

globally dispersed in the environment and appear in the Arctic (Hüttig, 2005). The Persistent 

Organic Pollutant Review Committee (POPRC) of the Stockholm Convention on Persistent 

Organic Pollutants (POPs) concluded that evidence is sufficient to conclude that SCCPs meet the 

screening criterion on potential for long-range environmental transport (UNEP, 2009). In 

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December 2009 the Executive Body of the Convention on Long-Range Transboundary Air 

Pollution will consider adding SCCPs to the POPs Protocol to the Convention (UNECE, 2009). 

VII. Exposure Characterization Summary

Releases 

SCCPs have the greatest potential for environmental release and exposure of the 

chlorinated paraffins. The likely sources of releases for SCCPs are identified as manufacturing 

and lubricant applications. In 2000 and 2001, nearly all usage of SCCPs was reported to be in 

metalworking applications. Losses from the use of SCCPs in paint and sealants are generally 

regarded as much lower than those from metalworking. Releases of SCCPs may occur during 

production, storage, transportation, industrial and consumer use of chlorinated paraffincontaining products, disposal and burning of waste, leaching, runoff or volatilization from 

landfills, and sewage sludge or other waste disposal sites (Tomy et al., 1998). 

Major sources of releases of chlorinated paraffins into the environment are likely the 

formulation and manufacturing of products containing chlorinated paraffins and use in 

metalworking fluids as an extreme pressure additive. EPA estimated releases of SCCPs during 

metalworking fluid use using generic scenario methodology. Releases to wastewater were 

estimated to be approximately 2,400 kg/site-yr from container cleaning, dragout (fluid that 

remains on the part after shaping), disposal of filter media and spent metalworking fluid. 

Releases to landfill and incineration from these same release sources were estimated to be 

approximately 900 kg/site-yr using the generic site methodology. Incinerators would not be as 

significant a source. 

The possible sources of releases to water from manufacturing include spills, facility wash 

down and drum rinsing/disposal. Chlorinated paraffins in metalworking/metal cutting fluids may 

also be released to aquatic environments from drum disposal, carry-off and spent bath. These 

releases often ultimately end up in the effluents of sewage treatment plants. In comparison to 

river and lake sediments, concentrations of SCCPs/MCCPs in sewage sludge are much higher, 

especially from waste water treatment plants serving industrial areas. 

Human Exposure 

The primary non-occupational routes of exposure to SCCPs include ingestion, both 

directly and through contaminated food, and dermal contact with products. Chlorinated paraffins 

have been isolated from human liver, kidneys, adipose tissue and breast milk. Due to their 

potential for environmental transport, SCCP exposure may occur from sources far from their use 

and release. For example, SCCPs have been found in breast milk samples taken from Inuit 

women (UNEP, 2009). 

There is potential for inhalation exposure to SCCPs in metalworking fluids from mists 

generated during metal shaping operations. EPA estimated that potential inhalation exposure 

ranges from 1.8 to 8.3 mg/day for this scenario. There is also potential inhalation exposure to 

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mists in uses where products containing SCCPs are spray applied such as in paints, adhesives 

and sealants. 

EPA estimated the potential for occupational dermal exposure for various manufacturing, 

formulation and use scenarios to range up to 1800 mg/day. These exposures could be mitigated 

by the use of personal protection equipment, such as gloves that have been demonstrated to be 

effective in preventing permeation by SCCPs and formulations containing SCCPs. 

Environmental Exposure 

In 1986, EPA/OPPT conducted a monitoring study of Sugar Creek near the Dover 

Chemical manufacturing facility in Dover, Ohio (Murray et al., 1988). SCCP concentrations of 

0.21 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 fluid end-user on Tinkers Creek did not detect 

chlorinated paraffins in either filtered water or particulates. The report authors thought that this 

may be due to analytical difficulties. In 1988, a production plant in the same city reported C10-13, 

60 percent chlorine SCCP concentrations of <150-3300 ng/L in water from an impoundment 

drainage ditch that received effluent from chlorinated paraffins (Murray et al., 1988). SCCPs 

were detected in the Houston Ship Channel in 1978 at levels ranging from less than 1.0 μg/L to 

1.5 μg/L. In 1977, near a Diamond Shamrock Facility on the Grand River 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 prepared by the POPs Review Committee of the 

Stockholm Convention, SCCPs have been measured in a variety of environmental media 

including air, sediment, surface waters, and wastewater in North America, Europe, Japan, and/or 

the Arctic (UNEP, 2009). 

SCCPs have also been measured in a variety biota, including freshwater aquatic species 

from North America, Europe and the Arctic, marine mammals from several locations in Canada 

and the Arctic, and avian and terrestrial wildlife in Europe. In addition, SCCPs have been 

detected in samples of human breast milk from Canada and the United Kingdom, as well as in a 

variety of food items from Japan and various regions of Europe (UNEP, 2009). 

VIII. Risk Management Considerations

SCCPs continue to be manufactured, imported, processed and used in industrial 

applications in the United States. SCCPs are persistent, bioaccumulative, and toxic to aquatic 

organisms at low concentrations. The persistence and bioaccumulative properties of SCCPs 

increase the probability and duration of exposure such that even relatively small releases from 

individual facilities that manufacture, import, process or use them or from waste management 

facilities have the potential to accumulate over time to levels that cause significant adverse 

impacts on the environment. Thus, a snapshot of industrial and other releases of SCCPs will 

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

SCCPs have been measured in biota and various environmental media, including in terrestrial as 

well as aquatic organisms. 

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Other chlorinated paraffins such as MCCPs and LCCPs can be used as substitutes for 

SCCPs. They are also persistent and bioaccumulative although they have lower water solubilities 

than SCCPs. They have also been measured in environmental media and biota. The toxicity of 

MCCPs and LCCPs may appear to be lower based on their lower solubility and bioavailability, 

however, their toxicity is generally not as well characterized as for the SCCPs. 

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

IX. Next Steps

EPA is addressing the discrepancy between the specific chlorinated paraffins companies 

are actually manufacturing or importing and those listed on the TSCA Inventory. Only some of 

the chlorinated paraffin fractions being manufactured or imported are on the TSCA Inventory. 

EPA intends to require companies to submit Pre-Manufacture Notices for the SCCPs, MCCPs, 

and LCCPs fractions that are not on the TSCA Inventory. If appropriate, EPA will initiate action 

under TSCA section 5 to address the risks posed by such SCCPs, and potential risks associated 

with MCCPs and LCCPs. EPA plans to explore these questions in the near future. 

Concurrently, EPA intends to consider initiating action under TSCA section 6(a) to ban 

or restrict the manufacture, import, processing or distribution in commerce, export, and use of 

SCCPs based on the persistence, bioaccumulation and toxicity of SCCPs and their presence in 

the environment. EPA will develop more detailed assessments to support the TSCA section 6(a) 

“presents or will present an unreasonable risk” findings. If these more detailed assessments 

indicate that a different approach to risk management is appropriate, EPA will consider 

additional approaches. 

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

commerce, use and/or disposal of MCCPs and LCCPs should also be addressed under TSCA 

section 6(a). 

As part of the Agency's efforts to address these chemicals of concern, EPA intends to 

evaluate the potential for disproportionate impact on children and other sub-populations. 

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