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

Short-Chain Chlorinated Paraffins (S CCPs) and Other Chlorinated Paraffins

Action Plan

I. Overview

SCCPs are found world-wide in the envir onment, wildlife and humans. They are bioaccumulative in wildlife and humans, are pe rsistent 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 manufactur ing, 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 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 EP A’s initial review of readily available use, exposure, and hazard information on SCCPs. EPA considered which of the various authorities provided under TSCA and othe r statutes might be a ppropriate 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

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

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

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 substan ce or mixture that contains a ch emical 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 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, CASRN 71011-12-6 named (Alkanes, C 12-13 , chloro) would only contain chemicals that meet the alkyl range described in the defi nition 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; C 14-17 alkyl chain) and long-chained chlorinated paraffins (LCCP; generally C 18 - 28 ) are also discussed in this action plan.

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 wa xes, 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 LCCP s are also not on the TSCA Inventory.

IV. Uses and Substitutes Summary

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 business. According to the Chlorinated Paraffins Industry Association, MCCPs represent th e 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 (EC HA 2008a). In Canada, SCCPs are not currently manufactured and use was approximately 3000 me tric 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 a nd 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 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 (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 undergr ound mining conveyor belts (rubber formulations) and fire retardants in dam sealants (ECHA 2008a).

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 biomagnificat ion 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 Canadi an 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 alte rnatives 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 a nd rubber applications. LCCPs are expected to be persistent and bioaccumulativ e in the environment based on their physicalchemical properties and bioaccumulation modeli ng, respectively. Canada has concluded that LCCPs up to C 20 are “toxic” as defined by CEPA (Gove rnment of Canada 2008).Canada has not made a determination of whether LCCPs greater that C 20 are toxic.

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 alternativ es 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 f our million £ per year (IRTA, 2004). An analysis

of costs conducted in Californi a found that overall metal work ing processing costs were more expensive for the SCCP alternatives but includi ng 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 (C 10-13 ) is very low (EC, 1999; UNEP, 2009). SCCPs may cause skin and eye irritation upon repe ated application, but do not app ear to induce skin sensitization (EC, 1999; UNEP, 2009). There was no evidence of developmental effects in prenatal developmental toxicity studies in ra ts 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 (C 12 , 60 percent chlorine) are carcinogenic in rats and mice of both sexes (N TP, 1986a; 2005). The underlying mechanisms for the carcinogenicity of SCCP in rats and mice are not clearly known. SCCP s were not mutagenic

to bacteria with or without me tabolic activation (NTP 1986a, b). Th ere are some indications that the SCCP-induced kidney tumors in male rats are associated with alpha 2 μ -globin accumulation in hyaline droplets, a mode of ac tion unique to male rats and irrele vant 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 per oxisome proliferation, whereas the thyroid effects are correlated to altered thyroid hormone homeost asis. A number of scientific working groups, including the International Agency for Res earch on Cancer (IARC), have

concluded that liver tumors i nduced by peroxisome proliferator s are not relevant to humans

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(IARC, 1990; Klaunig et al., 2003). Humans are expected to be mu ch 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. In the 11 th Report on Carcinogens, NCI lis ts chlorinated paraffins (C 12 , 60 percent chlorine) as reasonably anticipated to be human carcinogens based on sufficient evidence of carcinogenicity in experimental an imals (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” unde r CEPA (Government of Canada 2008).

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, 2008a).

Environmental Effects

SCCPs are highly toxic to aquatic invertebrates 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) (UNEP, 2009).

Both Health Canada and Environment Cana da have characteri zed all chlorinated paraffins (SCCPs, MCCPs and LCCPs) as “tox ic” under CEPA (Government of Canada 2008).

VI. Physical-Chemical Properties a nd Fate Characterization Summary

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 (Environm ent Canada, 2008; HSDB , 2008; UNEP, 2009). In general, water solubility decreases and Henry’s Law Constant and log K

ow of SCCPs increase with increasing carbon chain length and increasing chlorine conten t. Short- and medium- chain length chlorinated paraffins are liquids while longer chain, higher chlo rinated 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 lo w 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 K

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

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

ow s 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 measur ed 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 St ockholm Convention has c oncluded that SCCPs fulfill the persistence and bioaccumulation crite ria put forth in Annex D of the Stockholm Convention on Persistent Organi c Pollutants (UNEP, 2009). The EU has concluded that SCCPs meets its criteria for both persistent and bio accumulative (PB) substance and a very persistent, very bioaccumulative (vPvB) substance (ECHA 2008b). Canada ha s 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 re action with hydroxyl radicals with half-lives of less than one to slightly greater than ten days. A half-life grea ter than about two days in the atmosphere can be a significant factor in facilitating l ong-range transport of pe rsistent chemicals.

SCCPs released to water are expected to ad sorb 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).

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.

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 fres hwater 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 La kes and in arctic marine mammals (Environment Canada, 2008; UNEP, 2009).

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 fi ndings 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) conclude d that evidence is sufficient to conclude that SCCPs meet the screening criterion on po tential for long-range environmen tal 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 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, transportation, industrial and consumer use 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 using generic scenario methodology. Releases to wastewater were estimated to be approximately 2,400 kg/site-yr fr om 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 s ite 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. 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 non-occupational routes of e xposure 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 breas t milk. Due to their potential for environmental transp ort, 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 potentia l inhalation exposure ranges from 1.8 to 8.3 mg/day for this scenario. Th ere is also potential inhalation exposure to

6U.S. Environmental Protection Agency 12/30/2009

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

and sealants.

EPA estimated the potential fo r occupational dermal exposur e 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 SCCP s 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, Ohio (Murray et al., 1988). SCCP concentrations of 0.21 μg/L were detected in water at the outfall an d 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 f iltered 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 C 10-13 , 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 Facil ity on the Grand River in Painesville, OH, concentrations as high as 3.0 μg/L were detect ed upstream and downstrea m 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).

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 various regions of Europe (UNEP, 2009).

VIII. Risk Management Considerations

SCCPs continue to be manufactured, impor ted, processed and used in industrial applications in the United States. SCCPs are pe rsistent, bioaccumulative, and toxic to aquatic organisms at low concentrations. The persiste nce and bioaccumulative properties of SCCPs increase the probability and durati on of exposure such that even relatively small releases from

individual facilities that manu facture, import, process or use them or from waste management facilities have the potential to accumulate over time to levels that cau se significant adverse impacts on the environment. Thus, a snapshot of industrial 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.

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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 some of the chlorinated paraffin fracti ons being manufactured or impor ted are 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 Inve ntory. 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 expl ore these questions in the near future.

Concurrently, EPA intends to consider initia ting action under TSCA section 6(a) to ban or restrict the manufacture, im port, 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.

X. References

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C 10-13 , chloro, SCCPs.as well as Information on Potential Alternatives to Its Use. http://echa.europa.eu/doc/consultations/recommendations/tech_reports/tech_rep_alkanes_chloro.pdf (accessed Dec 11, 2009).

ECHA. 2008b. European Chemicals Ag ency. Agreement of the Member St ate Committee on Identification of Alkanes, C10-13, chloro (SCCP) as a Substance of Very High Concern. Adopted on 8 October 2008. http://echa.europa.eu/doc/about/organisation/msc/ agreements_svhc/msc_svhc_agreement_sccp.pdf (accessed Dec 11, 2009).

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IRTA. 2004. Institute for Research and Technical Assistance. Alternatives to VOC Emitting Petroleum Based Lubricants and Chlorinated Paraffin Lubricants: Minimizing the Health and Environmental Consequences

. Prepared for U.S. Environmental Protection Agency Region IX Under Grant Number EP-97905301. November 2004. 134 pp. http://www.dtsc.ca.gov/PollutionPrevention/upload/P2_REP_Alternative_Lubricants.pdf (accessed Dec 22, 2009).

Klaunig, J.E., Babich, M.A., B aetcke, K.P. Cook, J.C., Corton, J.C., David, R. M., DeLuca, J.G., Lai, D.Y., McKee, R. H., Peters, J.M., Roberts, R.A. and Fenner-Crisp, P.A. (2003). PPAR α Agonist-Induced Rodent Tumors: Modes

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Murray, T. M.; Frankenberry, D. H.; Steele, D. H.; Heath, R. G. 1988. Chlorinated Paraffins: A Report on the Findings from Two Field Studies, Sugar Creek, Ohio and Tinkers Creek, Ohio; Vol. 1. EPA/560/5 87/012. U.S. Environmental Protection Agency: Washington, D.C., 150 pp.

NTP. 1986a. National Toxicology Program. Department of Health and Human Services. Toxicology and Carcinogenesis Studies of Chlorinated Paraffins(C 12 , 60% Chlorine) in F344/N Rats and B6C3F 1 Mice. May 1986. http://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr308.pdf (accessed Dec. 11, 2009). NTP. 1986b. National Toxicology Program. Department of Health and Human Services. Toxicology and Carcinogenesis Studies of Chlorinated Paraffins(C 23 , 43% Chlorine) in F344/N Rats and B6C3F 1 Mice. May 1986. http://ntp.niehs.nih.gov/ntp/htdocs/LT_rpts/tr305.pdf (accessed Dec 11, 2009).

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Tomy, G. T.; Fisk, A. T.; Westmore, J. B.; Muir, D. C. G. 1998. Environmental Chemistry and Toxicology of Polychlorinated n -Alkanes. Rev. Environ. Contam. Toxicol

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Pollutants. ECE/EB.AIR/2009/9. October 2009.

UNECE. 2006. United Nations Economic Commission for Europe. Short Chain Chlorinated Paraffins Track B Review for the UNECE LRTAP Task Force on Persistent Organic Pollutants – Final Report. May 2006.

UNEP. 2006. United Nations Environment Programme: Stockholm Convention on POPs. Summary of ShortChained Chlorinated Paraffins Proposal. UNEP/POPS/POPRC.2/14. 7 August 2006. http://www.pops.int/documents/meetings/pop rc/chem_review/SCCP/SCCP_Proposal_e.pdf (accessed Dec 11, 2009).

UNEP. 2009. United Nations Environment Programme. Stoc kholm Convention on Persistent Organic Pollutants (POPs). Persistent Organic Pollutants Review Committee. Revised Draft Risk Profile: Short-Chained Chlorinated

Paraffins. 9 July 2009

. UNEP/POPS/POPRC.5/2. http://chm.pops.int/Convention/POPsReviewCommittee/ hrPOPRCMeetings/POPRC5/P OPRC5Documents/tabid/59 2/language/en-US/Default.aspx (accessed Dec 11, 2009).

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