October 2012 Revision: 2. Prepared by the Cefic SPERC Core Team

Transcription

1 Cefic Guidance Specific Environmental Release Categories (SPERCs) Chemical Safety Assessments, Supply Chain Communication and Downstream User Compliance October 2012 Revision: 2 Prepared by the Cefic SPERC Core Team Disclaimer The information contained in this paper is intended as advice only and whilst the information is provided in utmost good faith and has been based on the best information currently available, is to be relied upon at the user s own risk. No representations or warranties are made with regards to its completeness or accuracy and no liability will be accepted by Cefic nor any company participating in Cefic for damages of any nature whatsoever resulting from the use of or reliance on the information. This document does not necessarily represent the views of any company participating in Cefic. 1

2 Table of Contents Foreword General Relevance - Registrants & Downstream Users SPERCs are built on the basis of the REACH Guidance What are SPERCs and their limitations Overview of SPERCs available Naming SPERCs The SPERC emission assessment concepts Distinguishing industrial and wide dispersive uses SPERCs and terminology related to amounts used: Defining the local use rate: ERC vs SPERC Release Factors RMM Efficiencies in Emission Estimation The Municipal Sewage Treatment Plant and SPERCs Information in a SPERC Factsheet Identifying and retrieving SPERCs Release factors Use conditions determining the releases Substance use rates / Amounts used Sections addressing the downstream user SPERC factsheet content in CHESAR Registrants using SPERCs Where to find SPERC information SPERCs and assessment tools: EUSES, TRA, CHESAR SPERC-based environmental assessments in the CSR SPERC-based environmental assessments in the safety data sheet How to refine SPERC-based assessments (registrants) Accounting for additional Risk Management Measures SPERCs and Checking Downstream User Compliance Downstream users obligations Identifying the SPERC matching the DU s operation Scaling What to do if a use is not covered by a SPERC? Developing SPERCs and making them available Quality criteria for SPERC derivation and documentation Information sources available for SPERC development The SPERC Development process Guidance on documenting SPERCs in SPERC factsheets Making SPERCs available Appendix 1: SPERC Factsheet Examples...22 Appendix 1a Industrial use of Me-salts in Conversion Coating...22 Appendix 1b Formulation & (re)packing of substances and mixtures Industrial (Solvent-borne)...30 Appendix 2: Chesar determinants and SPERCs...38 The Chesar Data Structure...38 Information elements forming a determinant...38 Matching SPERC information elements to Chesar data structure...40 Appendix 3 Extracts of Chesar- generated and SPERC-based CSRs...45 Appendix 3a Industrial Use of Metal Salts in Conversion Coating Appendix 3b Formulation & (re)packing of substances and mixtures Industrial (Solvent-borne)...48 Appendix 4 Environmental RMMs in the Cefic RMM Library Appendix 5 - Experiences and Examples from the SPERC Development until mid

3 Foreword This guidance is issued by the Cefic Exposure Scenario Task Force, which provided the project lead for the SPERC-project. The participating sector organizations retain the responsibility for the content of the SPERCs. This is the second edition of the SPERC guidance document, developed using the version dating from July 2009 as a starting point. The feedback on SPERCs was taken into account, particularly that received through the UBA-study and via the discussion at the Cefic workshop on SPERCs, which was held in April, 2011.It also addresses the relationship between SPERCs and CHESAR, the chemical safety assessment and reporting tool developed by ECHA. All SPERCs which have been made available through the Cefic SPERC project will be made available to CHESAR users as so-called CHESAR SPERC files. This document serves several purposes. It outlines the concepts behind the SPERCs and presents the terminology used in conjunction with the SPERCs (Section 1). In Section 2 the concept of emission assessment under REACH is addressed in order to provide the necessary background information. Section 3 explains the SPERC factsheet, in which the full set of SPERC information is documented. It also outlines the relation of SPERCs with CHESAR. Section 4 outlines how registrants (and the consultants working for them) can find and make use of SPERC information. The downstream user perspective is addressed in section 5 with emphasis on how downstream users check whether they are covered by a SPERC. Section 6 addresses sector groups and trade associations and provides information on how to develop SPERCs. The appendices contain detailed information and examples. SPERCs have been developed in response to novel challenges arising from REACH chemical safety assessments. These require that exposure scenarios be developed for the uses of dangerous substances which are produced in excess of 10 tons per year. REACH exposure scenarios are a new concept for establishing and communicating conditions of safe use of substances in the supply chain. This is a particular challenge for the environmental aspects. Here, the conditions of safe use encompass amounts handled in an operation, fractions of substance amounts lost from the process to air, water and soil and the efficiency of risk management measures. In the past, such information was not subject to routine risk assessments. However, REACH requires considering these factors in the Chemical Safety Assessment, and the development of REACH exposure scenarios which define conditions under which control of risks is warranted. SPERCs address the above challenges, originating from the need to have standardized emission estimates, and were developed with the following in mind: 1) The quantitative nature of standardized environmental assessments needs to be carried through the supply chain. This facilitates adapting conditions of use, which are defined at a generic level, to the conditions prevailing at specific sites. 2) The conditions of use are developed with the actual use conditions in mind. To that end, this document provides guidance on how to describe these conditions in terms which feed into risk assessments. 3) Redundant communication in the supply chain is to be avoided. To that end, this document attempts to foster standardization of assessments and their communication. 3

4 1. General Relevance - Registrants & Downstream Users 1.1 SPERCs are built on the basis of the REACH Guidance Chapter R16 of the REACH Guidance on Information Requirements & Chemical Safety Assessment (IR&CSA guidance) introduces Environmental Release Categories as generic, broadly applicable emission scenarios. They define the fractions of a substance emitted during a process/application, and provide default assumptions for the local environmental properties. An industry evaluation concluded that ERCs provide for standardization while leading to unrealistically conservative emission estimates. The IR&CSA guidance acknowledges that an ERC should be used as a starting point for emission estimation and explicitly encourages the use of more refined or specific information for emissions. This document provides guidance on the development, and use of specific ERCs (SPERCs). It defines SPERCs, and describes how they are developed and how they can be accessed by registrants and downstream users. It provides guidance for registrants to use SPERCs in performing environmental safety assessments, and to communicate the results to the downstream users. In addition it addresses how downstream users check whether their own uses are covered by a SPERC-based Exposure Scenario. 1.2 What are SPERCs and their limitations These are the key aspects regarding SPERCs: SPERCs are an element of standardized supply chain communication of environmental assessments, e.g. in GES SPERCs are developed by industry sector groups, and trade associations SPERCs usually refine the ERC-based emission estimation SPERCs describe typical operational conditions that are relevant with regard to the emissions of substances to the environment SPERCs define realistic default values of the fractions which are released to water, air, soil and, where appropriate, waste SPERCs define risk management measures that are typically employed to reduce emissions SPERCs are documented in SPERC factsheets, deposited in ES library SPERCs are / will be available in exposure assessment tools such as in CHESAR (ECHA s Chemical Safety Assessment tool), ECETOC TRA, Petrorisk, and EasyTRA The comparison of SPERCs with ERCs is shown in Table 1.1. Table 1.1: Comparison of SPERCs and ERC. ERC Specific ERC (SPERC) Emission estimate Standardized Standardized Defaults Worst case Good practice RMMs Not included Considered Responsible ECHA Trade associations, sector groups of registrants, end users, or formulators While SPERCs provide refined emission estimates in comparison with ERCs, the SPERCs employ conservative values of release factors: In cases where the use of SPERCs does not yield successful exposure estimates, the emission assessment may need to be refined (see section 4.5). 4

5 1.3 Overview of SPERCs available SPERC factsheets have so far been developed by a variety of trade groups and sector organizations. These organizations are the owners of the SPERCs and retain the responsibility for SPERC content. Table 1.2 provides an overview of the trade groups that have made SPERCs available and the uses addressed by their respective SPERCs, and the web-addresses at which the SPERC factsheet can be accessed. As of fall 2012, so-called CHESAR SPERC files will also be available at these web-sites. Such files can be uploaded into CHESAR by anyone who wants to perform environmental exposure assessments with CHESAR, the chemical safety assessment and reporting tool developed by ECHA. CHESAR SPERC files facilitate the assessment and reporting of the assessment outcome in CHESAR. 1.4 Naming SPERCs SPERCs will be identified with an unequivocal and systematic name in order to facilitate searching. For instance the SPERC for formulation of detergents and maintenance products is abbreviated as A.I.S.E. 2.1.v1. In this code, the first part (A.I.S.E.) specifies the entity (i.e. A.I.S.E., the European Association for cleaning and maintenance products), which is responsible for the contents of the SPERC. The first number (i.e. 2) specifies the ERC, which is refined by the SPERC. The third part ( 1 ) is an index number given by the entity, which is responsible for the contents of the SPERC. One SPERC may contain several sets of default values. These will be indicated by lower case letters, as can be seen in the example SPERC for formulation of detergents and maintenance products. Part four ( v1 ) is the version number. 5

6 Table 1.2: Overview of SPERC development activities. Developer Acronym 1 Uses addressed Factsheet available at European Automobile ACEA Industrial use of coatings in the automotive Manufacturers' Association industry Req/Page?eas:template_im=100087&eas:d at_im=101aed#spercs Global federation of national trade organisations in the area of vehicle repairs. AIRC Small scale industrial use of coatings in car repair body shops Req/Page?eas:template_im=100087&eas:d at_im=101aed#spercs International Association for Soaps, Detergents and Maintenance Products European Sector Group of the producers and users of paints, printing inks, industrial coatings and artists colors European trade association of the cosmetics industry Europeam trade organization of producers of pre-coated metal. European Crop Protection Association European Federation for Construction Chemicals European Metal Packaging (EMPAC) European Solvents Industry Group / Downstream users of solvents AISE Formulation of and industrial and wide dispersive use of laundry, cleaning, and maintenance products CEPE Cosmetics Europe ECCA ECPA EFCC EMPAC ESIG/ESV OC Formulation of coatings and inks, industrial applications Formulation of and wide dispersive use of personal care products. Industrial use of coatings in strip coating of metals (coil coating) Wide dispersive use of non-active ingredients of plant protection products Formulation of and industrial and wide dispersive uses of construction chemical products Industrial uses of paints and coatings in metal packaging All uses of solvents. ss_sub4 Req/Page?eas:template_im=100087&eas:d at_im=101aed#spercs Req/Page?eas:template_im=100087&eas:d at_im=101aed#spercs litems.aspx Req/Page?eas:template_im=100087&eas:d at_im=101aed#spercs information/reach/ges-library/ges-spercs- 2/ 1 For explanation of abbreviations, please see the following sections 6

7 European Tyre & Rubber Manufacturers' Association EU federation of adhesive and sealant manufacturers European Association of Metals Federation of the textile chemical industry and German textile industry federation ETRMA Manufacture of rubber products. ach/emission-factors FEICA Formulation of and industrial and wide dispersive uses of adhesives and sealants Eurometaux Manufacturing, formulation and industrial uses of metal and metal compounds toolbox/spercs-tool-for-metals/ TEGEWA Industrial applications of textile treatment and at chemicals 7

8 2. The SPERC emission assessment concepts The emission assessment is one step in the process of the environmental exposure assessment. It defines the amounts emitted into the environment per unit of time. The point of departure of the emission assessment is the amount of chemical which goes to a certain use. In the emission assessment, a local and a regional amount used are defined as use rates (see 2.3). The use rates multiplied with release factors yield amounts emitted to the environmental compartments air, water and soil. The SPERCs support the estimation of the use rates and they define release factors. The relationships between these numerical parameters and the operational conditions, and, if appropriate, risk management measures are detailed in the SPERC factsheets. 2.1 Distinguishing industrial and wide dispersive uses From emission assessment perspective, wide dispersive uses are due to uses by consumers or professionals. These uses result in more or less evenly distributed substance emissions over time and in the geographical region under assessment. In addition, there are typically no technical measures by which consumers and professionals can control emissions. Industrial uses in contrast assume the use of substances at an industrial site which is a point source. This site operates certain applications and processes. Two important characteristics of industrial uses are that the operator is obliged to have an emission permit and that he has access to technical emission control. This interpretation means that small scale uses such as car-wash installations, car-repair body shops, etc are considered industrial uses. Table 2.1 presents an overview of how industrial and wide dispersive uses from an emission assessment point of view align with consumer, professional and industrial uses from a human health assessment view. Table 2.1: Sorting SPERC types vs Main User Groups and the underlying criteria. Main User Group Emission permit and / or Obligation to take SDS SPERC Type access to general technical emission control recommendation into account Industrial Use Yes Yes Industrial Use Professional Use* No** Yes Wide dispersive Consumer Use* No No Use * Professional and consumer users are in charge of release control by following instructions for equipment cleaning and disposal. ** Specific measures may be encountered in some professional uses. 2.2 SPERCs and terminology related to amounts used: When performing Environmental Safety Assessments as part of the REACH Chemical Safety Assessments, different types of amounts need to be distinguished. First, there is the mass of substance registered for a use in the EU, Q Use (in tons/year). A fraction thereof is defined to be used in one region. The corresponding amount is referred to as amount used regionally Q Use,Region (in tons/year). At the local level the local amount used is referred to as M Local. (kg/d). For industrial uses, a part of the SPERCs define values of M Local. These values are referred to as M SPERC. A fifth term, M Safe, refers to the value of M Local at which PEC=PNEC(i.e. RCR =1). M Safe is the outcome of the environmental exposure assessment and derived for the compartment with the maximum value of RCR. 2.3 Defining the local use rate: ERC vs SPERC The local amount used (M Local ) is one of the key parameters for the emission estimation. In the ERC based emission assessments, this parameter is estimated according the EU TGDusing fixed default values. In contrast, in SPERCs for wide dispersive uses the value of 8

9 F Mainsource, can be defined. For industrial use, the local amount used is estimated independently of the TGD-default values. Table 2.2outlines these differences. It is partly reproduced from the ECETOC Technical Report 114 Table 2.2: Overview of the parameters used in the REACH emission estimation and how they are used in Tier 1, SPERC-based, and higher tier assessments Parameter Abbreviation Unit ERC based emission assessment ECHA Guidance SPERC based emission assessment Mass of substance registered for a use in the EU Fraction of Q Use which is used in one region Regional amount used For industrial uses: Fraction of amount used in a region (Q Use,Region ) which is used in one point source For wide dispersive uses: Fraction of Q Use,Region, which is used in the unit town of Inhab Number of days per year during which emissions occur Industrial use Local amount used Wide dispersive uses Local amount used Q Use t / a Defined by Registrant use market intelligence F Region Q Use,Region F Mainsource Unitless 1 Industrial use F Mainsource dispersive uses Unitless Default values: 0.1 and 1. Defined by Registrant use market intelligence Default values (0.1, 1) used in standard mode, free choice of value in advanced mode. t / a Q Use,Region = Q Use F Region Q Use,Region = Q Use F Region Unitless T Emission d / a Default values: 10, 20, 100 or 300 days according to guidance M Local Kg/d M Local = Q Use, Region 1000 F Mainsource / T Emission M Local Kg/d M Local,Dispersive = Q Use,Region 1000 F Mainsourc e / T Emission Not used in derivation of M Local See SPERC factsheets* Defined in SPERC factsheets, not relevant for emission estimation. M SPERC realistic worst case estimate of M Local must be overwritten by registrant if M Local is known to be higher than M SPERC ; may be overwritten in other cases. 2.4 Release Factors The release factors (F Release ) are specified as numeric values for all three emission routes (air, water, and soil). The values of.f Release express the fractions of M Local, which are emitted to the environment via water, air, or soil. For most SPERCs, the initial release factors define the primary emissions from a process, i.e. these release factors do not account for the mitigating effect of risk management measures. 9

10 The sector association have used a variety of approaches and starting points to derive values of F Release.These include for instance BREF documents, OECD emission scenario documents, measured emission data, sector knowledge and expert judgment.appendix 5 gives an overview of the approaches followed by several sectors. Where appropriate, release factors have been defined to be dependent on substance properties. In those instances, release factors are assigned to ranges of vapor pressure and/or volatility. As a consequence, a SPERC factsheet may specify a whole suite of release factors. 2.5 RMM Efficiencies in Emission Estimation For most SPERCs, the initial release factors (F Release ) define the primary emissions from a process. The risk management measures are explicitly addressed by accounting for their efficiency (RE Total, RMM-Water ). This efficiency defines the degree by which the emissions are reduced. The release factor for the primary emission and efficiency of the risk management measure are combined according to Equation 2.1 to obtain the resulting overall emission factor F Overall. F Overall, water = F Release,Water RE Total, RMM-Water Equation 2.1 For a number of SPERCs (e.g. those of Eurometaux) the effect of the risk management measures is already accounted for in the initial release factors. For such SPERCs, F Overall equals F Release and is not deduced according to Equation The Municipal Sewage Treatment Plant and SPERCs For many substances, the process occurring in the municipal sewage treatment plant provide for efficient removal from the wastewater. Nonetheless, the municipal sewage treatment plants are not considered to be a risk management measure in the framework of SPERCs, since they are not under the control of the downstream user. 3. Information in a SPERC Factsheet The set of information, which constitutes a SPERC definition is documented in a SPERC factsheet. A SPERC factsheet according to the Cefic agreed format has 12 sections and an Appendix. Table 3.1.provides an overview of the SPERC factsheet format. 3.1 Identifying and retrieving SPERCs The first four sections (Title of SPERC, SPERC code, Scope, Related use descriptors) provide information which is to support the user of a SPERC in deciding whether a SPERC is relevant to him or in helping him retrieving SPERCs in databases, e.g. in a libraries of SPERCs. This can be done on the basis of the title of the SPERC, the SPERC code, the description of the scope, or the related use descriptors. 3.2 Release factors This section specifies the release factors and a justification for the release factors. The justification explains on which basis the release factors were derived. It may provide references to literature or methods or direct links to related documents. Where appropriate, the fraction of substance, which is diverted through an RMM from an emission pathway to waste is indicated by a release factor. 10

11 Table 3.1: Overview of the SPERC factsheet format. Section Content of Section Title of SPERC short title of SPERC SPERC code Structured Code of SPERCs (e.g. A.I.S.E. 8a.1a.v1) Scope Limitations of coverage compared to ERC relating to: User groups (if not already obvious from Title) Substance groups or functions (e.g. solvents, additives) Types of products (e.g. coatings, water borne mixtures) Processing conditions (e.g. dry processing, no high temperatures) Explicitly specifies conditions or processes which are not covered Related use SU, PCs, PROCs or ACs if relevant descriptors Operational Clear description of the operational conditions that determine the conditions emission. Specification of concepts such as efficient resource use by quantified indicators (e.g. % of raw materials use) or qualitative conditions (e.g. Obligatory onsite RMMs Substance use rate Days emitting Release factor (air, soil, water, soil, waste) Optional risk management measures for iteration Narrative description Scaling Appendix processing techniques) Clear description of risk management measures that are to be applied and the existence of which is assumed in the (initial) release factors. no RMMs needed to be explicitly stated, if release factors apply without any RMM Value of the substance use rate (in tons/day), if defined for the SPERC. Can be replaced in the assessment. Value of the number of emission days. Without influence on the emission estimation, can be useful for deriving annual substance use rate. Numeric value Justification of value by reference to literature or methods. Direct link to related documents. Specifies RMMs that are not considered in the release factor or the obligatory RMM. Optional RMMs are intended to provide guidance to - registrants for iterating his assessment. - downstream users to find alternative RMMs (if the obligatory RMMs are inappropriate for his specific situation) - downstream users to find RMMs which can be used when a SPERC w/o RMM is insufficient to cover the use at his site. If possible and available, risk management measures should be named and efficiencies in relation to substance groups should be provided. Short and concise flow text description. Relevant items to be specified: Abstract description of full process (e.g. storage, automated pumping of substances to mixing vessels, continuous or batch wise processing, automated packaging, cleaning of equipment, local exhaust ventilation) Explicit mentioning of whether or not cleaning of equipment and side activities are covered. Unambiguous description of conditions regarding waste management and wastewater discharges (e.g. if there are no restrictions in scope, statement that any type of waste disposal is covered). No justification should be included. Reference to the Cefic guidance on how to communicate scaling rules to DU. Only Scaling information that is specific to the sector / SPERC should be provided The determinants for use in the CSR and to be used in CHESAR need to be specified in the tabular format outlined in Appendix 2. 11

12 3.3 Use conditions determining the releases The sections Operational conditions, Obligatory onsite RMMs, and Narrative description provide the description of the conditions of use which are related to the release factors. The narrative in asperc factsheet is intended to be used for identifying the process step(s) which is (are) critical for the emissions to the environment and for rationalizing what fraction of a substance is lost from a process to water, air, and soil. In that manner the narrative explanation of typical sector operational conditions provides justification for the selection of the initial release factors. Following the suggestions from the SPERC workshop, the existing ambiguities regarding whether Risk Management Measures (RMMs) are already accounted for in release factors or whether RMMs act to reduce the release factor have been eliminated. As part of current practice, emissions are controlled by RMMs, if so required. SPERCs reflect this by including RMMs, where these are applicable for the operations. RMMs impact on the exposure assessment by reducing the emission. To that end, RMMs can be assigned a numerical value for their substance removal efficiency in the release streams, particularly, of air and wastewater. Such efficiency values have been defined in the BAT- BREF-documents. They are available via the Cefic library of RMMs and are abbreviated as RE RMM. (see Appendix). If more refined information is available, it can of course be used in developing a SPERC. Appendix 4 shows the default efficiencies of RMMs included in the Cefic library of RMMs. It is important to note that RMM efficiencies often depend on substance properties and process characteristics. Hence, default efficiencies are indicative, however may not reflect technically achievable efficiencies (i.e., actual efficiencies may be less than or greater than the default value). Consequently, the risk assessor is responsible in deciding whether the assumptions made regarding RMM efficiencies are appropriate/relevant for the process/use and the substances being evaluated. In the Appendix of the SPERC factsheet, the essence of this information is summarized in the form of CHESAR determinants. According to the CHESAR model terminology, operational conditions and risk management measures are referred to as determinants. CHESAR includes a library in which systematically defined determinant types can be stored, in order to facilitate the re-use of determinants across assessments. Further explanation is given in Appendix Substance use rates / Amounts used The section Substance use rate can be used to specify values of M SPERC, i.e. indicative values of M Local for the SPERC. The value of M SPERC is intended to provide orientation to registrants that do not have much information about typical substance uses rates in downstream applications. 3.5 Sections addressing the downstream user The Days emitting provides the number of days during which a process is operated. This information should support downstream users in identifying the SPERC applicable to their process. In addition to the required risk management measures, the section on Alternative Risk management measures can be used to suggest risk management measures that can be used to replace the obligatory risk management measures. The information can also be used by downstream users to adapt risk management measures in case a SPERC-based equivalent exposure scenario does not cover the downstream user s operation. The section on scaling information may be used to define information in relation to adapting the generic SPERC-based exposure scenario to the specific downstream user operation. The downstream user issues are discussed in further detail in Section 5. 12

13 3.6 SPERC factsheet content in CHESAR The trade associations which have developed SPERCs have decided to make SPERCs available for registrants using CHESAR. This requires that the information from the SPERC factsheets is made available in files that can be imported into CHESAR. These files are named CHESAR SPERC files. Herein, information from the SPERC factsheets is organized according to the data structure underlying CHESAR. Further details on the CHESAR data structure are detailed in the documentation on CHESAR. In the CHESAR model, the operational conditions and the risk management measures are jointly addressed under the term determinants. CHESAR contains two libraries: one for determinant types and one for SPERCS. Appendix 2 displays the list of determinants as they have been defined for the SPERCs available so far. 4. Registrants using SPERCs 4.1 Where to find SPERC information Information on SPERCs is available from different sources. More detail is provided in the SPERC overview ( ). Most sector groups that have developed SPERCs provided so called use mappings on their homepages. Where not included yet, these mappings will be amended with the information on which SPERCs are relevant for which uses. In that manner, the use mappings will support the selection of the appropriate SPERCs. 4.2 SPERCs and assessment tools: EUSES, TRA, CHESAR Chapter R16 of the REACH Guidance on Information Requirements & Chemical Safety Assessment (IR&CSA guidance) mentions several tools for supporting environmental exposure assessments. These include ECHA s chemicals safety assessment tool CHESAR, EUSES, and the TGD Excel Sheet. PETRORISK and ECETOC TRA ENV are additional tools which are based on the TGD Excel Sheet and which offer complementary functionalities. All these tools implement the exposure assessment rules as laid down in Chapter R16 of the IR&CSA guidance. SPERC-based emission estimates can be employed/used as input values in each of these tools. PETRORISK and ECETOC TRA ENV have implemented functionalities which support the automated use of SPERCs. Table 4.1 specifies how to perform SPERC-based emission assessments in conjunction with these tools. SPERCs are progressively developed and revised, but assessment models are not revised concomitantly. It is thus the assessor's responsibility to check that the SPERCs proposed by the model are up-to-date. Table 4.1.Overview of environmental exposure assessment tools and how they relate to SPERC-based emission estimation. Tool Use of SPERC-based emission estimation CHESAR EUSES TGD Excel Sheet. ECETOC TRA ENV PETRORISK EasyTRA - SPERCs will become available as CHESAR SPERC files to be used in CHESAR exposure assessments - SPERCs not implemented - SPERC-based emission estimates are derived off-line - Manual entry of emission estimates - SPERCs implemented with selection via pick-list - SPERC-based emission automatically feeds into exposure estimation 13

14 The responsibility for issuing new or revised SPERCs lies with the associations. It is their task to inform tool owners about new and revised SPERCs. If such new information is published but not implemented in a tool, the assessor can use it for example by manually entering relevant SPERC release fractions in the model. 4.3 SPERC-based environmental assessments in the CSR The registrant submits his assessment to ECHA in a CSR. The CSR should provide a comprehensive set of information required to understand the assessment and to check it for plausibility. For SPERC-based assessments it is recommended to provide the essential information on operational conditions and risk management measures in the CSR. This can be accomplished by inserting the so-called determinants into the CSR. The determinants are listed in the Appendix of the SPERC factsheets. In that manner, dossier evaluators are provided with information on OCs and RMMs, which allows them to judge whether the SPERC based environmental assessment fits with the overall Exposure Scenario. In addition, the SPERC used for the emission estimation and the information needed to perform the quantitative environmental assessment should be reported in the CSR. This includes the substance use rates for the region (Q Use,Region ),the local amount used (M Local ) and the release factors. Finally, the CSR specifies the outcome of the assessment by detailing for instance the PECs, the RCRs, or the value of M Safe. 4.4 SPERC-based environmental assessments in the safety data sheet As outlined above, the Exposure Scenarios in the CSR contain an extensive amount of information. Much of the information reported in the exposure assessment is difficult to understand by the non-expert user, thus only parts of it are relevant for the downstream user. The downstream user checks whether his application is addressed in the risk assessment. For that reason, the information to be communicated to downstream uses should be reduced to those information items which are essential. From this perspective, the level of information communicated for wide dispersive uses versus industrial uses need to be distinguished according to the guidance provided in section 2.1. Wide dispersive uses. As outlined in section 2.1, consumers and professional users have limited capability of controlling emissions. For that reason, there is no added value in communicating explicit information with respect to SPERCs beyond the minimum requirements. The producers of end-use products only need to be informed whether the use of the substance in their professional and/or consumer application is safe. The producer of end use products has to translate the operational conditions specified in the respective SPERC factsheet into instructions. They can be communicated in the safety data sheet to professional users and on the packaging to consumers. For solvent-borne paint such instructions could read Wash brushes with XYZ solvent. Do not dispose paint and washing with wastewater. Allow solvent to evaporate prior to disposal with solid waste. Industrial uses. In contrast to professional users and consumers, industrial end users can control their emissions and align the conditions of use at their site. The information provided to them in the safety data sheet therefore may include the following - the identity of the SPERC - the operational conditions (coded in phrases) - the risk management measures (coded in phrases) and its assumed efficiency. - an indication whether scaling is appropriate if scaling is appropriate: the dilution factor assumed in the assessment, and the value of M Safe (alternative to M Safe, the value of M Local is assumed in the assessment, the values of RCR, and the maximum value of RCR to which the assessment may be adjusted. This value represents the limit set by the registrants and must be respected by the downstream user.) 14

15 4.5 How to refine SPERC-based assessments (registrants) SPERCs are part of a generic approach to derive environmental exposures. Hence, SPERCbased environmental exposure assessments are still lower tier assessment. That means that assessments employing SPERC-based emission estimates may indicate a possible risk. In such cases refinement may be needed. Figure 2 shows that beyond ERC- and SPERCbased assessments there are higher tier environmental exposure estimation options as well as the option to base the assessment on measured environmental concentrations/ monitoring data. For more detailed information on refining environmental exposure assessment, please refer to Appendix H of ECETOC Technical Report 107 and to ECETOC Technical Report 114. Figure 4.1: Tiered environmental exposure assessment. 4.6 Accounting for additional Risk Management Measures In the course of iterating the Exposure Scenarios, the assessor determines which RMM efficiency or removal efficiency is required for demonstrating safe use. In many cases, the required removal efficiency may be met by the RMMs and associated efficiencies (individually or in combination) defined in the SPERC factsheet. If the combined effect of multiple RMMs can be assumed linear (i.e., RMMs in combination are equally as effective as when implemented alone), overall or total removal efficiencies should be calculated according to Equation 4.1. The resulting value of RE Total,RMM can then be used to recalculate the overall release fraction according to Equation 2.1. RE Total,RMM = 1 (1 RE RMM, 1 ) x (1 RE RMM,2 ) x (1 RE RMM,n ) Equation 4.1 Ultimately, the assessor must conclude whether or not the SPERC-based emission assessment was successful, i.e. safe use was demonstrated, within the appropriate boundaries of typical substance and process/use conditions, and that reasonable RMM removal efficiencies have been assumed. When this is not the case, the assessment may need to be refined beyond the boundaries set by the SPERC-based emission assessment. 15

16 5 SPERCs and Checking Downstream User Compliance 5.1 Downstream users obligations According to Art.31 the extended safety data sheet (esds) will provide information on the conditions under which a substance can be safely used. This information is termed Exposure Scenario and encompasses information relating to environmental safety. According to Art.37.5 in the REACH regulation, the recipient of the information has to check that his operations conform to the conditions outlined in the esds and that, if necessary, he applies appropriate risk management measures. Further information on this can be found in Cefic s REACH Practical Guide on Exposure Assessment and Communication in the Supply Chains and in ECHA s Practical Guide for Downstream Users. Both documents do not specifically address SPERCs. Such information is given below. Section 5.2 addresses the qualitative check of whether the SPERCs communicated (as part of the Exposure Scenarios) in the safety data sheet address the uses relevant to the downstream user (or his customer) SPERCs. Section 5.3 outlines the quantitative aspects of this check. 5.2 Identifying the SPERC matching the DU s operation In the first step, the downstream user of a substance may want to assess qualitatively whether his operation is covered by the SPERC which is part of the Exposure Scenario communicated to him via the safety data sheet. To this end, the downstream user checks whether the SPERC is identical with the SPERC that the downstream user has identified to be relevant for the operation in which he uses the substance. This requires knowledge of the SPERC(s) relevant to the operation(s). Typically, smaller businesses operate one or a few similar processes and the number of relevant SPERCs is small. Hence, a downstream user may have to identify the limited number of SPERCs that are relevant for his operation. This includes checking whether the operational conditions and risk management measures implemented in his operation match with the SPERCs. To that end, the SPERC factsheets could be used. Alternatively, the sector organizations of the formulators of end use products could issue targeted information for their members and the customers of their members. Such publications could be helpful by leaving aside the assessment detail presented in the SPERC factsheets and by focusing on the operational conditions and risk management measures instead. 5.3 Scaling Upon concluding that the own operation is covered qualitatively by a SPERC. The quantitative part of the evaluation can be started. This quantitative evaluation is termed Scaling. For SPERC-based environmental assessments it answers the set of conditions prevailing in the DU s operation are covered by the set of conditions communicated in the suppliers SDS. This question is particularly relevant if the supplier has indicated in his safety data sheet that quantitative matching is appropriate for the use described by the SPERC. In most cases the combination of factors such as local amount used, risk management measures implemented and dilution of wastewater in the sewer and receiving river will be compared. Currently, the discussion on scaling is not concluded. For that reason this document does not go into any more detail on this topic. 5.4 What to do if a use is not covered by a SPERC? If an actor in the supply chain concludes that a certain use is not covered by a SPERC, there is the possibility to address this issue in the relevant trade association and to stimulate the development and publication of a SPERC according to the mechanism outlined above. Guidance on developing SPERC factsheets is provided in section 6. 16

17 6 Developing SPERCs and making them available 6.1 Quality criteria for SPERC derivation and documentation SPERC factsheets are intended to provide the background documentation of the thoughts underlying a SPERC. Table 6.1 summarizes the elements which need to be addressed in a SPERC factsheet to be of sufficient quality. These elements need to be addressed in order to enable registrants, and downstream users to properly apply SPERCs. In addition, the quality criteria for SPERCs are to support authority representatives in understanding the proper application of SPERCs. Table 6.1. List of quality criteria for SPERCs Formal criteria In each SPERC it should be clearly identified what processes and/or activities are covered. Each SPERC should be identified with a unique identifier. The standard factsheet format developed by Cefic should be used (see ). Criteria related to content The operational conditions which are typical for the application covered by the SPERCs should be described. The description of the operational conditions should enable downstream user to judge whether their specific operation is covered by a SPERC. Release factors to water, air, and soil should be provided. If on-site risk management measures are prescribed by a SPERC, this should be clearly stated and the assumed efficiency of the RMM should be specified. Where it applies releases to off-site waste treatment and waste management should be specified. The reference document(s) which was (were) used as the departing point for the SPERC derivation should be cited. Criteria related to reasoning applied in the SPERC definition The reasoning applied in the choice of release factors should be reported in the SPERC factsheet. If release factors are lower than those in the reference documents used for developing the SPERC, a justification should be provided. If release factors are set to zero, a justification relating to the operational conditions should be provided. If the release factor to soil is set to zero, a standard justification suffices. Criteria related to the availability of SPERCs Industry associations should maintain and update the SPERC factsheets. (all versions of SPERCs should be kept available). 6.2 Information sources available for SPERC development Several sources of for information on typical processes and emission rates can be used as starting point for development of SPERCs. The most relevant are the OECD Emission Scenario Documents (ESDs), Best Available Technology Reference Documents (BREFs) and emission values from the A- and B-tables of the Technical Guidance Document on Risk Assessment (European Chemicals Bureau, 2003).. Additional resources can be monitoring data, market research data and questionnaires at sector association level. 17

18 6.3 The SPERC Development process Setting up an expert group. Based on the experience made so far, the SPERC development process starts with setting up a group of individuals who are knowledgeable about the processes and related emissions. In the past, these individuals have frequently been recruited from member companies of sector organisations. In certain instances sector associations involved consultants as well. Collect information and compile into factsheet. The first task handled by this group is the identification of the process which is covered by a SPERC and by identifying suitable starting information. Subsequently, this information is evaluated with regard to suitability for the SPERC development. From the reference documents relevant pieces of information (release factors, operational conditions and risk management measures) are selected and compiled for documentation into the SPERC factsheets. Quality-check and publish SPERC factsheet. Once the selection and compilation of the SPERC factsheet is completed, the draft factsheets should be quality assessed based on the criteria outlined above. This quality assessment should be performed by a broader group of individuals from the sector organization which holds the responsibility for the SPERC. Upon successful completion of the quality assessment, the SPERC factsheets can be published on the sector organization s homepage and the Cefic Exposure Scenario working group needs to be informed. 6.4 Guidance on documenting SPERCs in SPERC factsheets. As outlined above the information describing a SPERC is summarized in a SPERC factsheet. The factsheet contains 12 sections as indicated in Table 3.1. Below instruction for providing appropriate information for all sections is given such that the quality criteria for a SPERC factsheet (see above) are met. Title of SPERC: This section is to specify the title of a SPERC as a string of text. SPERC code: This section is to specify the unique code for the SPERC. For unequivocal identification of SPERCs the coding system outlined in Chapter 1.5 of this document is used. Scope: This section is to specify domain of applicability of the SPERC. This information is to inform the downstream user of the SPERC information such that he can decide whether the SPERC relates to his operation.if relevant please provide information on User groups (if not already obvious from Title) Substance groups or functions (e.g. solvents, additives) Processing conditions (e.g. manufacturing or processing of solvent-borne mixtures, manufacturing or processing of water-borne mixtures, processing of solids, dry processing, no high temperatures) If relevant, specify explicitly which conditions or processes are not covered Related use descriptors: This section is to specify the use descriptors (SU, PROC, PC, ERC, AC) which correspond to the use described in the SPERC factsheet. Operational conditions: Please provide a clear description of the operational conditions that determine the emission. These are communicated in phrases. In free-text please provide a specification of concepts such as efficient use of resources by quantified indicators (e.g. % of raw materials use) or qualitative conditions (e.g. processing techniques). 18

19 Obligatory onsite RMMs: Please provide in phrases: Clear description of risk management measures that are to be applied and the existence of which is assumed in the release factors. Explicitly state, if no RMM is required. Please provide numerical values of the efficiency of the phrases. Substance use rate: Please provide (a) numerical value(s) of an indicative realistic worst case estimate of the amount of a substance used per day at a typical site (= M SPERC ). Days emitting: Please provide a numerical value of a typical value of the number of days at which the process is operated and emissions occur. Release factors: Two sets of information are to be provided. The release factors as numeric values. This set of information consists of the fractions of the substance used in the process, which are released to air, water, and soil. A fourth release factor to waste may need to be specified if, as a result of obligatory risk management measures, a fraction of the substance is diverted to waste. In addition, a free text justification for the values by reference to literature or methods or by providing the rationale behind the derivation of the value. It may prove useful to provide direct links to related documents or to document the reasoning applied in adapting the information in the reference document, the rationale for setting the release factors. Optional risk management measures for iteration: If relevant, please provide in phrases: Clear description of risk management measures that are intended as a recommendation. Please provide numerical values of the efficiency of the optional risk management measures. Note, specifying optional risk management measures is to guide downstream user in selecting risk management measures he might want to apply in case of that he is not covered by the SPERC-based Exposure Scenario. Narrative description: Please provide in a concise free text description. Relevant items to be specified are: Abstract description of full process (e.g. storage, automated pumping of substances to mixing vessels, continuous or batch wise processing, automated packaging, cleaning of equipment, local exhaust ventilation) Explicit mentioning of whether or not cleaning of equipment and side activities are covered. Unambiguous description of conditions regarding waste management and wastewater discharges (e.g. if there are no restrictions in scope, statement that any type of waste disposal is covered). Scaling: This section provides the information required for the quantitative evaluation of whether the use of a substance in own (i.e. specific) operation is covered by the generic set of conditions, which is defined by the SPERC. This quantitative evaluation is termed Scaling. This section can include the scaling equation relevant to the SPERC, a reference or a link to a scaling tool, the parameters by which the SPERC can be scaled to site specific conditions, etc. 6.5 Making SPERCs available. The SPERC factsheets are the product of the SPERC development. They are published as reference information on the homepages of the associations / trade groups. The factsheets provide the comprehensive background information, which justifies the improved emission estimation (in comparison with the ERCs). They are meant as reference documents for those 19