Industry Consortium CB4REACH. Information Letter 3

Transcription

1 CB4REACH Industry Consortium CB4REACH Information Letter 3 November 2009 Dear SIEF member, After receiving replies to our second SIEF Information Letter various questions were raised and clarification on the concentration range for heavy metals was specifically requested. This 3 rd SIEF information letter intends on clarifying the following issues: - heavy metals content - analytical methods used - declared uses of Carbon Black. 1. Heavy metals Carbon Black (CAS # , EINECS # ) is registered with the following heavy metals as potential impurities : Antimony (Sb), Arsenic (As),Barium (Ba), Cadmium (Cd), Chromium (Cr), Cobalt (Co), Copper (Cu), Lead (Pb), Nickel (Ni), Mercury (Hg) and Selenium (Se). The concentration range of each individual metal is equal to or less than 10 ppm. Note: If your pre-registered Carbon Black is not in the concentration range listed in the SIEF Information Letter 2 your company is not automatically excluded from the joint submission. It is important that your substance fulfils the mono-constituent rules as described in the ECHA Guidance document on registration and that your declared impurities do not lead to a classification of the registered Carbon Black! Cabot Corporation, Cancarb Limited, Columbian Chemicals, Continental Carbon Company,

2 2 2. Analytical methods Quantification of Polycyclic Aromatic Hydrocarbons (PAHs) in Carbon Black: No internationally recognized test standard for the quantification of PAHs in carbon black is currently available. Laboratories are usually using test protocols based on the method described in the FDA CFR21 section a. This consists of a Soxhlet toluene extraction on the carbon black followed by a quantification of the individual PAHs of interest by GC-MS. a FDA Method: Determination of PAH Content of Carbon Black, July 8, 1994 incorporated by reference to 21 CFR part 178, US Federal Register 62, (90), May 9,1997, 21CFR Quantification of Heavy Metals in Carbon Black: Various internationally recognized test standards are available for the determination of various individual heavy metals in materials like carbon black. One consists in combusting carbon black in a muffle furnace at 550 C as per ASTM D 1506 b prior to digesting the remaining ash with hot concentrated acids. The individual heavy metals are then quantified in the digested ash solution using an appropriate analytical technique (ICP-AES, ICP-OES, ICP-MS, etc.) c. Another consists in digesting entirely the carbon black with nitric acid in a closed quartz reaction vessel under a pressure of approximately 100 bar at 250 C. Such technique minimizes the potential loss of some volatile metal oxides for Hg or As. The individual heavy metals are then quantified in the digested solution using an appropriate analytical technique (ICP-AES, ICP-OES, ICP-MS, etc.) c. b Standard Test Method for Carbon Black - Ash Content", Annual Book of ASTM Standards, Volume 9.01, Method D c ISO17294 Part 1and 2 (ICP-MS), Application of inductively coupled plasma mass spectrometry. Part 1: General guidelines (ISO :2004). Part 2: Determination of 62 elements (ISO :2003).

3 3 2. Uses Uses and Main use category (X) Industrial use (X) Professional use ( ) Consumer use In final applications like consumer products, Carbon Black is usually embedded in a matrix (polymer, rubber, liquid, etc.). Furthermore, Carbon Black being an inorganic non-migrating substance, consumers are normally not exposed to airborne, unbound Carbon Black of respirable size when using finished lacquers, coatings, printing inks, rubber and plastic articles, etc. Specification for industrial and professional use (X) Used in closed system (X) Use resulting in inclusion into or onto matrix (X) Non-dispersive use (X) Dispersive use Significant routes of Human (X) Oral (X) Dermal (X) By inhalation Environmental (X) Water (X) Air (X) Solid waste (X) Soil Pattern of (X) Accidental / infrequent (X) Occasional ( ) Continuous / frequent

4 4 Identified uses Table 3: Description of identified uses IU1: Additive for rubber (approximately 80% of carbon black SU11: Manufacture of rubber products PC1: Adhesive, Sealants, PC 32: Polymer Preparations and Compounds IU 2: Additive for plastics (approximately 10 % of carbon black SU12: Manufacture of plastics products, including compounding and conversion PC1: Adhesive, Sealants, PC 32: Polymer Preparations and Compounds

5 5 IU 3: Pigment (approximately 9% of total carbon black SU5: Manufacture of textiles, leather, fur SU6: Manufacture of pulp, paper and paper product SU11: Manufacture of rubber products SU13: Manufacture of other non-metallic mineral products, e.g. plasters, cement other products: PC1, PC5, PC9, PC10, PC18, PC 23, PC 26, PC 32. PC 39 IU 4: Chemical reagent (< 1 % of total carbon black SU8: Manufacture of bulk, large scale chemicals (including petroleum products) SU13: Manufacture of other non-metallic mineral products, e.g. plasters, cement SU14: Manufacture of basic metals SU15: Manufacture of fabricated metal products, except machinery and equipment other products: PC 2, PC 7, PC 21; laboratory chemicals; PROC 1: Use in closed process, no likelihood of IU 5: Refractories (< 1 % of total carbon black SU8: Manufacture of bulk, large scale chemicals (including petroleum products) other products: thermal insulator PROC 12 Use of blow agents for foam production PROC 15 Use of laboratory reagents in small scale laboratories exposur

6 6 IU 6: Portable energy (< 1 % of total carbon black IU 7: Other carbon preparations (< 1 % of total carbon black SU14: Manufacture of basic metals SU16: Manufacture of computer, electronic and optical products, electrical equipment other products: catalyst support other products: PC 33: Semiconductor Other products: e.g. automotive parts PROC 14: ion of preparations or articles by tabletting, compression, extrusion, pelettisation PROC 15: Use of laboratory reagents in small scale laboratories PROC 22: Potentially closed operations with minerals at elevated temperature PROC 1: Used in closed process, no likelihood of PROC 14: ion of preparations or articles by tabletting, compression, extrusion, pelettisation PROC 15: Use of laboratory reagents in small scale laboratories PROC 1: Used in closed process, no likelihood of exposur

7 7 PROC 14: ion of preparations or articles by tabletting, compression, extrusion, pelettisation Uses advised against Use as pigment in Tattoo colours for humans. Uses covered by legislations other than REACH: Please note that carbon black uses for cosmetics, medical, food or food contact applications are regulated by specific legislations other than REACH. The health aspects for this kind of applications are consequently out of the scope of REACH (see Regulation (EC) No 1907/2006 of the European Parliament and of the Council of 18/12/2006, Title I, Chapter 1, Article 2 ) and compliance with these specific regulations still applies. In the next information letters we will inform you about the subsequent steps for the registration process. Individual offers are being prepared based on the tonnage band indicated in your response to the Information Letter 1. This step will require the signature of a Non-Disclosure Agreement (NDA). The SIEF Information Letters are available on With kind regards CB4REACH Consortium Patrick Wellmann Dr. Knoell Consult, Leverkusen