Risk assessment of Short and Medium Chain Chlorinated Paraffin’s (SCCP and MCCP)

The present report constitutes deliverable D9 of the OMNIITOX project and is the risk assessment part of the ECB case study (work package 5). The objectives of the case study have been to deliver empirical knowledge for the feasibility study carried out as part of WP5 and to deliver data and inspiration to other work packages (WP 7, 8 and 9). Specifically for this part of the case study (risk assessment part), the aims have been to illustrate the EU risk assessment scheme and to make a basis for comparison with an LCA approach for assessing the same substances. This report presents the main findings of the Short Chain Chlorinated Paraffin (SCCP) and the draft Medium Chain Chlorinated Paraffin (MCCP) risk assessments. The political actions taken as a consequence of the assessments are also described. The risk assessments have been prepared according to the EU Technical Guidance Document (TGD), which therefore is briefly introduced. SCCP and MCCP are chemically similar and the risk assessments have shown that this is also the case for their applications and properties. Consequently the risk assessments end up with comparable conclusions as to where the substances pose risks and where risk reduction measures should be taken. It should be mentioned that there are still a few issues pending in the preparation of the MCCP report, which is therefore currently only in a draft version. The current report therefore fulfils the aim of illustrating the scientific and political aspects of the EU risk assessment scheme. The aim of delivering a basis for comparison with the LCA results has however not been completely meet. The initial part of the case study showed that SCCP has already to a large extent been substituted from metal working fluids (which is a main application of CP’s). For this reason, it has been necessary to focus the LCA part of the case study on a metal working fluid with MCCP and an alternative without CP’s. In order to make a reasonable comparison between LCA and risk assessment evaluations, it would therefore be advantageous to also have a risk assessment of the alternative. However, metal working fluids cannot be modified by simple “drop in” substitution of MCCP. Comparable risk assessments would therefore have to be made on the entire metal working fluid products in order to make sense. These considerably more difficult assessments will be approached by co-operation with an ongoing Danish project dealing with substitution of MCCPs from metal working fluids. The results from that project will become available in the spring of 2003 and where relevant and possible be included in deliverables 40, 47 and/or 49, which are all to some extent dealing with comparison of LCA and risk assessment methods. An important conclusion at this stage of the project is however that risk assessments comparing alternatives cannot always be made at the substance level. It is necessary to take the function that the substances deliver into account. Interestingly this is the default approach in life cycle assessments in which the functional unit is the basis for comparison.