IPC’18 Base Oils and Waxes

For the second time, the Base Oils and Waxes (BOW) session was held in parallel with the general session on petrochemicals. Organized by AFPM staff and superbly moderated by Ernie Henderson, this session featured three presentations on waxes and one on base oils.

GRAPHIC: Indian Oil
GRAPHIC: Indian Oil's Haldia Refinery

EPA Nomenclature Update
Jim Cooper, Senior Petrochemical Advisor at AFPM, is working with the Alliance for Chemical Nomenclature, to help ensure that any nomenclature for a hydrocarbon-based product which more specifically defines what it is does not trigger regulatory review as a new product. This situation has arisen because EPA has needed to do housekeeping on 60,000+ listings in TSCA, the Toxic Substances Control Act. Much of TSCA’s inventory list are not products “in commerce”, while others are inherently variable because of variations in feedstock. In the arena BOW is concerned about, many products fall under a UVC (Unknown and Variable Composition Classification).

Initial meetings at EPA were not productive, but that improved after regulatory reform that included language in Section 8 that requires EPA to accept existing nomenclature. EPA staff have stated they would now like to use CAS (Chemical Abstracts Service) designations, which are inherently molecular Jim sought the informal consent of the attendees to continue working with the alliance to be more specific on UVC with EPA, and CAS through ACS (the American Chemical Society). No one objected, simply asked that are new classification be backwardly compatible.
Note the revises TSCA bill was passed in bipartisan manner, and includes provision for inactive chemicals, mixture or formulations to be dropped from a company inventory if they have not been used in production for 10 years.

The issue over nomenclature was triggered by enforcement letters, which looked to AFPM, and later the alliance, like trying to promulgate legislation through enforcement. The language now inserted in Section 8 should help to protect against a new chemical review process, simply through designation of a new CAS identifier. The alliance is seeking non-punitive ways to improve reporting, or just stay with the current nomenclature if CAS change is impractical.

Why MOAH Needs to be a Concern for Manufacturers
Tim Yasika, Regulatory Manager at Sonneborn, presented work from Germany by the European Wax Federation to disprove concerns from Germany of the safety of waxes in personal care products. Concern had been raised by an activist group of MOAH (Mineral Oil Aromatic Hydrocarbons) that might be carcinogenic. EWF’s response was to educate regulators, academics and industry about single-ring, double-ring and polyaromatic compounds (PAC) with three rings or more.  Lengthy mouse-painting studies by Exxon and Shell eliminated many specific PACs, but not 3+ ring in mixtures with other PAC or with those containing S or N.

The industry has moved away from testing using animals and developed an extraction-based test known as IP436. This test, correlated with prior mouse-painting data, has resulted in a cut-off criterion based on percent of MOAH. The German regulator which had issued a ruling based on activist concerns has withdrawn the cosmetics warning.
This methodology has been adopted outside of Europe, for example in Australia and Malaysia. Tim Yasika through his membership of ATSM D06 Fuels Committee is maintaining a watching brief in the USA. There are also simpler alternatives to IP436, such as DAB8-UV method which correlates well with an ASTM method.

EU Issues Which Could Affect US Manufacturers
Sasol gave a presentation developed by Dr. Dirk Danneels of EWF. The topic was concern about the use of paraffin wax and microcrystalline was as food additives. The European JEFCA (Joint Expert Committee on Food Additives) had allowed this until a new species of test mice were used in 1989, the Fleischer-344. These mice were used to test the products from different types of wax treatment e.g. acid treating and hydrogenation. Microcrystalline wax and high viscosity oils tested OK, but paraffin wax and low to medium viscosity oils developed swellings in livers of F-344 mice. Follow-up studies failed to convince JEFCA that these findings were not relevant to humans.  Humans can develop encapsulated oil droplets “lipogranulomes” in livers, spleens and lymph nodes, but they have not been shown to be harmful. These tend to be in the C25 to C27 range. The industry did achieve permission to use paraffin wax at 0.05 mg/kg as a lubricant for PVC extrusion.

Public concern was then raised about printing ink from used paper and cardboard used for food packaging, NGOs pushing to be free of MOSH (Mineral Oil Saturated Hydrocarbons). EWF is actively working to clarify for the wider community the differences between waxes and oils, and the fact that human ability to metabolize normal amounts was also seen in the Sprague-Dawley mice tests on the 1960s: these 90-day tests are now being repeated, as part of a dossier to document that n-alkanes do not accumulate in human livers, because they are metabolized. Only the F-344 mice appear unable to metabolize the n-alkanes.

This summary covers the first afternoon, following the keynotes. The final topic of the final presentation within this BOW session “The Future of Electric Vehicles” will be covered in a summary of the second morning general session, which is devoted to transportation and petrochemicals

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