Sound Management of Chemicals

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United StatesChemicals Management Petroleum
Sector Approach

• Sound Management of Chemicals
• Working Group Stakeholder Meeting
• April 1-2, 2009

Jennifer Galvin, PhD, DABT, CIH
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The Chemical Management Journey

• Public and Environmental Protection
• is the Goal

This is a journey with chemical management,
environmental and public protection as the
destination
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Overview

• History of Chemical Management
• TSCA HPV Program
• ChAMP
• Globally Harmonized System/REACh
• Globalization

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History of Chemical Management in the US

• 1969
• Federal Insecticide, Fungicide Rodenticide Act
  (FIFRA)
• National Environmental Policy Act (NEPA)
• 1970
• EPA Established
• Occupational Safety and Health Act (OSHA)
• Clean Air Act (CAA)
• 1974
• Safe Drinking Water Act (SWDA) (1979)
• 1976
• Toxic Substances Control Act (TSCA)
• Resource Conservation and Recovery Act (RCRA)
• 1980
• CERCLA Superfund
• 1986
• EPCRA Toxics Release Inventory (TRI)
• 1990
• Clean Air Act Amendments (CAAA)

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TRI Emissions Reductions
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Toxic Substances Control Act (TSCA)

• A few sections of a comprehensive chemical
  control act
• Established inventory of chemicals in commerce
• New Product Manufacture Notification (PMN)
• Reporting of adverse health/environmental effects
• Ability to require data on chemicals via test
  rules

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High Production Volume (HPV) Chemical Testing

• Voluntary Challenge Program
• Data sets to be submitted to the EPA
• Phys/chem data, toxicology and environmental
• Petroleum substances
• 405 substances
• Hundreds of refinery streams
• Multiple product types blended from various
  streams

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Complex Petroleum Substances

• Sources of Variability
• Crude Oil Source
• Distillation Process
• Temperature

UVCB substances of Unknown or Variable
composition, Complex reaction products or
Biological materials
Refinery Products Streams
Each UVCB can be considered to be a category of
molecules often closely related
Sources of Variability
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Number of Paraffin Isomers and Approximate
Boiling Range of Categories
Crude Oil
Gasoline
Diesel No. 2
Lubricating Oils
Asphalt
Jet
Heavy Fuel Oils
Gases
400
500
650
1000
1300
300
60
Boiling Point, DegF
6
8
10
15
20
43
71
Number of Carbon Atoms
5
18
75
gt1000 Trillion
4,000
366,000
Number of Paraffin Isomers
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Categories for HPV

• Petroleum Gases
• Gasoline
• Kerosene/Jet Fuel
• Gas Oils
• Heavy Fuel Oils
• Lubricating Oil Basestocks
• Aromatic Extracts
• Petroleum Waxes
• Asphalt
• Petroleum Coke

• Crude Oil
• Lubricating Grease Thickeners
• Reclaimed Substances
• Hydrocarbons
• Naphthenic Acids
• Disulfides
• Acids/Caustics

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ChAMPChemical Assessment and Management Program

• EPA is evaluating petroleum substances under
  ChAMP
• ChAMP components
• EPA to complete assessments and take action as
  needed on over 6,750 existing chemicals produced
  in levels above 25,000 lbs. per year
• EPA is developing Risk-Based Prioritizations
  (RPBs) and Hazard-Based Prioritizations (HBPs)
• HPV-like program for inorganic HPV chemicals
• Reset of the TSCA Inventory, to involve
  reporting of TSCA Inventory substances

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ChAMPChemical Assessment and Management Program

• Product-focused categories in US
• Used previously for the US HPV Program
• Harmonized with EU 37 categories ? 12 categories
• Canadas categories similar to US EU

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ChAMP the Petroleum Industry

• API is participating in ChAMP development
• Tracking and generally supporting HPB and RPB
  process
• Seeking clarity on framework, schedule, and
  methodology
• Questioning value of Inventory reset
• ChAMP is preferable to a REACh-like framework
• Allows for screening prioritization and more
  efficient use of existing data

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REACh and Globally Harmonized System (GHS)

• REACh Registration, Evaluation and Authorization
  of Chemicals
• EU Product Registration Law Data sharing
• GHS Data on SDS and Labels
• United Nations Guidance for SDS
• US Petroleum efforts to globally harmonize
  classification include
• IPIECA
• CONCAWE for EU GHS

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Globalization of Chemical Management

• The petroleum industry is a global industry, so
  sharing HES data is an ongoing established
  practice
• Ongoing harmonization efforts include
• HPV programs
• GHS
• REACH
• The industry is committed to working with
  regulatory agencies around the globe to satisfy
  their HES needs and requirements

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Questions