united states chemicals management petroleum sector approach jennifer galvin, phd, dabt, cih sound...
TRANSCRIPT
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)
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