Tuesday, April 22, 2014

OECD Guidance on Naming Oleochemicals Called Confusing if Used by Regulators

If adopted by regulators, guidance the Organization for Economic Cooperation and Development (OECD) recently issued on characterizing oleochemicals could result in US chemical manufacturers needing to obtain new names and identification numbers for chemicals they have made for decades, according to a regulatory affairs official from the American Cleaning Institute.

OECD's guidance on characterizing oleochemicals melds various long-standing chemical identification systems used by regulators in different countries and regions and could introduce confusion in global commerce, according to the institute. It could result in the same chemical having multiple names and identifications in different parts of the world, Kathleen Stanton, director of technical and regulatory affairs at the American Cleaning Institute, told Bloomberg BNA April 17.

Oleochemicals are among a group of chemicals classified as derived from “unknown or variable compositions, complex reaction products and biological materials,” or UVCBs. These chemicals cannot be represented by unique structures and molecular formulas, according to EPA guidance.

Chemicals in this group are derived from tallow, lard, sunflower and other fats and oils as well as petroleum. They are used in many industrial, consumer and medical products, including wire insulation, coolants, lubricants, soaps, detergents and personal care products.

The OECD Task Force on Hazard Assessment published its guidance April 11 detailing an approach to describing and naming oleochemical substances.

OECD's guidance would necessitate new names and possibly new Chemical Abstract Service (CAS) numbers for many of these chemicals, Stanton said.

Chemical manufacturers then would have to submit chemicals that they have made for decades for review to regulatory authorities as if the chemicals were new compounds, she said.

Trade disruption and marketplace confusion could result if a chemical, long known by one name and CAS number, had to be sold under a new name and number, she said.

Adoption, Broader Implication?

Stanton said she doubted whether countries and regions with long-standing inventories, such as Canada, the European Union and the United States, would adopt the OECD's guidance. The approach might be used by a country forming a new chemical inventory, she said.

She urged chemical manufacturers to continue to track nomenclature issues addressing other types of UVCBs that will be considered by OECD's task force.

The OECD task force undertook the oleochemicals guidance as a pilot, Stanton said. The next groups of UVCBs the international organization will examine are renewable fuels and hydrocarbon solvents, she said.

The EPA used several approaches to identifying UVCBs when it developed its inventory of chemicals made and sold in the United States in the late 1970s and early 1980s as required by the Toxic Substances Control Act.

Among the approaches used was a system the EPA developed with the American Cleaning Institute—then known as the Soap and Detergent Association or SDA.

The EPA said in the 1985 version of its TSCA inventory that, although the system had limits, the SDA substance names were “as precisely descriptive of the chemical composition of a substance as possible.” The agency's UVCB guidance requires chemicals be identified as precisely as possible.

By Pat Rizzuto

For more information
  • “OECD Guidance for Characterizing Oleochemical Substances for Assessment Purposes” is available at http://bit.ly/P2OZfH.

Reproduced with permission from Daily Environment Report, 77 DEN 1 (April 22, 2014).
Copyright 2014 by The Bureau of National Affairs, Inc. (800-372-1033)

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