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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 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) TRI Emissions Reductions TRI Trend Analysis for NAICS Code 324 (Petroleum) For 1988 Core Chemicals Total On-Site and Off-Site Disposal or Other Releases (lbs/yr) 80,000,000 70,000,000 60,000,000 50,000,000 Total Off-Site Disposal or Other Releases (lbs.) 40,000,000 Total On-Site Disposal or Other Releases (lbs.) 30,000,000 20,000,000 10,000,000 0 1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 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 Sources of Variability Each UVCB can be considered to be a category of molecules often closely related Number of Paraffin Isomers and Approximate Boiling Range of Categories Crude Oil Gasoline Gases Lubricating Oils Diesel No. 2 Jet Heavy Fuel Oils 60 300 400 500 6 8 10 5 18 75 Asphalt 15 650 Boiling Point, DegF 1000 20 43 Number of Carbon Atoms >1000 Trillion Number of Paraffin Isomers 4,000 366,000 1300 71 Categories for HPV • • • • • • • • • • Petroleum Gases • Crude Oil Gasoline • Lubricating Grease Kerosene/Jet Fuel Thickeners Gas Oils • Reclaimed Substances Heavy Fuel Oils – Hydrocarbons Lubricating Oil Basestocks – Naphthenic Acids Aromatic Extracts – Disulfides Petroleum Waxes – Acids/Caustics Asphalt Petroleum Coke ChAMP Chemical 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 ChAMP Chemical 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 Questions