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United States Chemicals Management Petroleum Sector Approach. Sound Management of Chemicals Working Group – Stakeholder Meeting April 1-2, 2009. Jennifer Galvin, PhD, DABT, CIH. The Chemical Management Journey. Public and Environmental Protection is the Goal.
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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
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
Overview • History of Chemical Management • TSCA – HPV Program • ChAMP • Globally Harmonized System/REACh • Globalization
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)
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
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
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
Number of Paraffin Isomers and Approximate Boiling Range of Categories Crude Oil Lubricating Oils Gasoline Diesel No. 2 Asphalt Gases Jet Heavy Fuel Oils 300 400 500 650 1000 1300 60 Boiling Point, DegF 20 6 8 10 15 43 71 Number of Carbon Atoms 5 18 75 >1000 Trillion 4,000 366,000 Number of Paraffin Isomers
Petroleum Gases Gasoline Kerosene/Jet Fuel Gas Oils Heavy Fuel Oils Lubricating Oil Basestocks Aromatic Extracts Petroleum Waxes Asphalt Petroleum Coke Categories for HPV • Crude Oil • Lubricating Grease Thickeners • Reclaimed Substances • Hydrocarbons • Naphthenic Acids • Disulfides • Acids/Caustics
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
ChAMPChemical Assessment and Management Program • Product-focused categories in US • Used previously for the US HPV Program • Harmonized with EU 37 categories → 12 categories • Canada’s categories similar to US & EU
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
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
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