United StatesChemicals Management

Petroleum Sector Approach

Jennifer Galvin, PhD, DABT, CIH

Sound Management of Chemicals

Working Group – Stakeholder Meeting

April 1-2, 2009

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

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

Refinery Products & Streams

Sources of Variability•Crude Oil Source

•Distillation Process•Temperature

Each UVCB can be considered to be a

category of molecules often closely related

UVCB = substances of Unknown or Variable composition, Complex reaction products or Biological

materials

60 400 500 650 1000 1300Boiling Point, DegF

Gasoline Diesel No. 2 Lubricating Oils Asphalt

Jet

300

Heavy Fuel Oils

6 8 10 15 20 43 71Number of Carbon Atoms

5 18 75 4,000 366,000 >1000 TrillionNumber of Paraffin Isomers

Number of Paraffin Isomers and Approximate Number of Paraffin Isomers and Approximate Boiling Range of CategoriesBoiling Range of Categories

Gases

Crude Oil

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

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

Questions