Transcript Slide 1

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
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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
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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