For more see www.epa.gov/oppt/existingchemicals/pubs/actionplans/pbde.html.
SCCPs Action Plan Summary
Short-chain chlorinated paraffins (SCCP) include all individual chemicals or mixtures that contain: CxH(2x-y+2)Cly where x = 10-13; y = 3-12; and the average chlorine content ranges from approximately 40% to 70% with limiting molecular formulas set at C10H19Cl3 and C13H16Cl12. EPA will evaluate whether medium-chain chlorinated paraffins (MCCP) and long-chain chlorinated paraffins (LCCP) also should be addressed. EPA says:
• some specific SCCPs, MCCPs, and LCCPs currently being manufactured and/or used in the U.S. aren't on the TSCA Inventory. Any substance not listed is classified as a new chemical. EPA will address the discrepancy between specific chlorinated paraffins companies are actually manufacturing or importing and those on the inventory.
• will consider action under TSCA Section 6(a) to ban or restrict SCCPs based on persistence, bioaccumulation, and toxicity and their presence in the environment.
• will evaluate whether manufacturing, processing, distribution in commerce, use, and/or disposal of MCCPs and LCCPs should also be addressed.
For more information see www.epa.gov/oppt/existingchemicals/pubs/actionplans/sccps.html.
These plans are bold, and telegraph EPA's intent to modify TSCA. If these plans become a reasonable method of assessment and control, they would be less radical than others proposed. They also indicate that however crippled some may view past TSCA implementation, reform -- , not revolution -- may suffice to meet the needs of a modern chemical control law.
Lynn Bergeson is managing director of Bergeson & Campbell, P.C., a Washington, D.C.-based law firm that concentrates on chemical industry issues. The views expressed herein are solely those of the author. This column is not intended to provide, nor should be construed as, legal advice. You can e-mail her at firstname.lastname@example.org.