United States Chemicals 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

Boiling Point, DegF GasolineDiesel No. 2 Lubricating Oils Asphalt Jet 300 Heavy Fuel Oils Number of Carbon Atoms ,000366,000 >1000 Trillion Number of Paraffin Isomers Number of Paraffin Isomers and Approximate Boiling 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

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