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Classification and regulations

Chlorinated Paraffins have been classified by a number of bodies:

a) The 25^th Adaptation to Technical Progress to the Dangerous Substances Directive 67/548/EC has formally classified Short Chain Chlorinated Paraffins C_10-13 as Category 3 carcinogens (R40), and as Dangerous for the Environment (R50/53).

b) International Maritime Goods Code (IMDG) listing C_10-13 grades as "severe marine pollutants". Other types are not listed in IMDG so long as the CPs does not contain more than 1 % of C_10-13 products.

c) In Germany C_10-13 grades are classified in KBwS Water Hazard Class 3 (serious water pollution hazard). Long-chain 70% (solid) types are classified in WGK 1 (slight hazard). Liquid grades from C_14-17 and long-chain wax are classified WGK 2.

The Directive 91/689/EC on hazardous waste stipulates ecotoxicity as one of the criteria according to which such wastes are to be classified. Therefore, classification as Dangerous to the Environment would mean that waste containing significant quantities of C_10-13 CPs will almost certainly be regarded as "hazardous waste". At the time of writing, the percentage that would be regarded as "significant" is still unclear, although it is likely that the proposed "Dangerous Preparations Directive" may be used to assess criteria for waste in addition to products.

Longer chain (C₁₄ and above) CPs have much lower aquatic toxicity and solubility than C_10-13 types. These longer chain products are not classified as Dangerous for the Environment. Nevertheless, the EU has proposed the same R50/53 label as for short-chain chlorinated paraffins despite the fact that they are less hazardous to the environment. Consequently, waste containing these products would not be termed hazardous under Directive 91/689/EC.

Currently in the USA under the Federal Resource Conservation Recovery Act (RCRA) system, CPs are not regulated hazardous wastes. Ecotoxicity is among the general properties on the basis of which waste may be classified as hazardous. Therefore C_10-13 CPs could be classified as hazardous in case of an amendment. The detail of US state regulation is available on request.