UK’s first-ever plan to tackle ‘forever chemicals’
The UK has published its first plan to address PFAS (‘forever chemicals’), outlining a framework for monitoring, evidence-gathering, and potential regulatory action.
The UK Health and Safety Executive (HSE) has confirmed that phenol, alkylation products (mainly in para position) with C12-rich branched alkyl chains from oligomerisation—commonly known as para-dodecylphenol (PDDP)—meets the WHO definition of an endocrine disruptor with relevance to human health and the environment. Classified under UK REACH as Repr. 1B, Skin Corr. 1C, Eye Dam. 1, Aquatic Acute 1, and Aquatic Chronic 1, PDDP’s persistence, bioaccumulation, and oestrogenic activity raise significant regulatory and operational concerns for industries spanning automotive, marine, energy, and materials manufacturing.
PDDP’s Hazard Profile and Regulatory Status
PDDP, a group of alkylphenols with predominantly 12-carbon branched chains, is widely used as an intermediate in lubricant and fuel additive production—especially in calcium phenates and aryl zinc dialkyldithiophosphates (ZDDPs). These additives are critical in maintaining engine cleanliness, controlling wear, and meeting performance standards for a wide range of engines from passenger cars to large marine diesels.
The HSE’s assessment draws on mammalian toxicity studies showing reproductive effects linked to oestrogenic activity, including altered puberty timing, reduced fertility, and changes in reproductive organ weights. While environmental endocrine-disrupting thresholds could, in principle, be identified, data gaps remain—particularly for aquatic species. PDDP’s persistence and bioaccumulation mean environmental concentrations could rise over time, even if current exposure levels are not yet of concern.
Supply Chain and Use Patterns
At least 90% of PDDP manufactured or imported into the UK and EU is used in lubricant additives. Although manufacturing in Great Britain is now unlikely, imports—both as the raw substance and within additive packages—continue. Residual PDDP in calcium phenates has been reduced in recent years, but completely eliminating residues remains technically challenging, especially for marine and heavy-duty diesel applications.
Minor uses include phenolic resins for printing inks, tyre rubber compounding, varnishes, and oilfield dispersants. These products may contain residual PDDP, though data on release potential is scarce.
Implications for Industry and Compliance
Professionals across the manufacturing value chain should be aware of several key implications:
- Regulatory Exposure Limits – UK REACH identifies Derived No Effect Levels (DNELs) for PDDP, including 0.47 mg/kg bw/day for dermal worker exposure and 0.099 mg/m³ for inhalation.
- Substitution Challenges – While some lubricant applications can transition to alternative chemistries, performance limitations remain in marine and heavy-duty sectors. Reformulation is complex, costly, and can take years to qualify.
- Environmental Risk Management – Even in the absence of immediate exposure concerns, cumulative environmental build-up could trigger future restrictions or bans.
Source:
hse.gov.uk
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