Guidance For Characterizing Oleochemicals For Assessment Purposes Released

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The Organization for Economic Cooperation and Development (OECD) recently released its document "OECD Guidance for Characterising Oleochemical Substances for Assessment Purposes," which is available online. The document seeks to present a "harmonised approach" for characterizing UVCB (substances of unknown or variable composition, complex reaction products or biological materials) oleochemical substances that are derivatives from animal and vegetable oils and fats.

In June 2012, the OECD Task Force on Hazard Assessment endorsed a pilot project to develop guidance on identifying UVCB using oleochemicals/oleoproducts as the pilot chemicals. The development of this guidance was, in part, in response to questions and concerns related to UVCB nomenclature that had been raised by the European Chemicals Agency (ECHA) in response to some UVCB chemical registrations under the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) regulation.

Industry stakeholders, including U.S. chemical manufacturers, have expressed concern that if adopted under current regulatory regimes, the newly released OECD nomenclature guidance will require companies to obtain new chemical names for materials that they have used for many years. This, in turn, could trigger the need for new chemical review under EPA's Toxic Substances Control Act (TSCA).

All stakeholders within the biobased chemical space -- even those not directly engaged in oleo-based products -- should carefully review the existing guidance and monitor future OECD work in this arena as it will have widespread ramifications. OECD has already indicated that it will focus on biofuels in upcoming UVCB nomenclature guidance, a development that will have significant implications for the biochemical industry.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

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