DU obligations according to REACH and CLP in relation to exposure scenarios

Transcription

1 Kerstin Lundin 2013 DU obligations according to REACH and CLP in relation to exposure scenarios Univar Nordic a chemical distributor Suppliers : 500 Products : Customers:

2 What to do when you receive an esds? Downstream users need to check whether their use (of substances on their own or in a mixture) and their conditions of use are covered in the SDS received. This check may include the foreseeable use of these substances further down the supply chain. Annex: Exposure Scenarios - Methyldiethanolamine 1. Formulation & (re)packing of substances and mixtures SU10; ERC2; PROC3, PROC5, PROC8a, PROC8b, PROC9; PC0 2. Use as an intermediate SU3; SU9; ERC6a; PROC1, PROC2, PROC3, PROC4, PROC8a, PROC8b, PROC9; PC19 3. Use as laboratory reagent/agent SU3; SU22; ERC4, ERC6a; PROC15; PC21 4. Use in gas treatment SU3; SU8; ERC7; PROC1, PROC2, PROC3, PROC8b; PC20 5. Use in Lubricants, Use in Metal working fluids / rolling oils, Use in Hydraulic fluids SU3; SU22; ERC4, ERC8a, ERC8d; PROC2, PROC3, PROC8a, PROC8b, PROC9, PROC17, PROC18; PC24, PC25 6. Use as catalyst in polymerisation SU3; ERC3, ERC5; PROC7, PROC8a, PROC8b, PROC10, PROC14, PROC21, PROC24; PC32 7. Use as catalyst in polymerisation SU22; SU12, SU19; ERC8c, ERC8f; PROC8a, PROC8b, PROC10, PROC11, PROC14, PROC13; PC32 8. Use in coatings SU3; ERC5; PROC7, PROC8a, PROC8b, PROC9, PROC10, PROC13; PC9a 9. Use in coatings SU22; ERC8c, ERC8f; PROC8a, PROC8b, PROC10, PROC11, PROC13; PC9a 10. Use in concrete and cement SU22; ERC8f; PROC5, PROC8a, PROC10, PROC13, PROC19, PROC21, PROC24 4 2

3 Customer Question We are using Methyldiethanolamine in washing and cleaning products and I cannot find this use in the exposure scenarios. What to do? Our use is: SU 22 - Professional use PC 35 -Washing and cleaning products (including solvent based products) PROC8a - Transfer of substance or preparation (charging/discharging) from/to vessels/large containers at non-dedicated facilities. PROC10 Roller application or brushing PROC11 - Non industrial spraying. ERC8a - Wide dispersive indoor use of processing aids in open systems. 5 Important - Communication If your use is not covered, you should inform your supplier or take alternative actions without delay, as you have 12 months to implement whatever measures you decide to take. If you have to report to ECHA because you intend carrying out a DU CSR or if any exemptions apply, you have 6 months to do so. 6 DU CSR = downstream user chemical safety report 3

4 Supplier contact We have customers using methyldiethanolamine in washing and cleaning products. I cannot see that the product category PC35 is covered. Is it OK to use this material in washing and cleaning products? Can you please make an exposure scenario for PC 35? 7 Supplier - answer An explicit use of MDEA as a component in washing and cleaning products has not been included in the current registration. Your customers should have a look at scenario called "Use in coatings". The included PROCs 7, 10,11 and 13 are typically also used to describe cleaning procedures and may be relevant in your case. We did not use "special" coatings-tools to assess this use, so the measures to ensure a safe use should also apply to your customer s handling. 8 4

5 Question to our authority As our customer's use of a substance in washing and cleaning agents was not mentioned in the exposure scenario. I sent a question to our supplier and got the following response: "an explicit use of MDEA as component in washing and cleaning products has not been included in the current registration" What does this mean? Our supplier says further : " they should have a look at scenario No. 8 and 9 called "Use in coatings". The included PROCs 7, 10, 11 and 13 are typically also used to describe cleaning procedures and may be relevant in your case." 9 The Authority's response The simple answer is that they should not use the substance in a detergent, at least not if they buy a substance from a supplier that does not support that use. 10 5

6 Practical Guide 13 How DU can handle exposure scenarios How downstream users can handle exposure 11 Conditions of use are covered by the exposure scenario If your use is covered by the set of exposure scenarios, no further action is needed in that regard. Document your actions and conclusions and keep them available for authorities upon request. If you supply the substance in mixtures, inform your customers about conditions of safe use. They, in turn, are responsible for performing their own check concerning their uses and conditions of use, based on the information provided by you. 12 6

7 Conditions of safe use and appropriate risk management advice Upon customer request, we have added oxidative water treatment with 99% efficiency to raise the maximum amount of safe use from ~43 kg/d to 4257 kg/d. 13. Check if you are exempt from the requirement to undertake a DU-CSR. This may be because: The substance is exempted in a mixture in concentrations below threshold limits set in Article 14(2) of REACH. Your total annual usage is less than one tonne. 14 7

8 If you use an exemption - You may have to report to ECHA. Your total annual usage is less than one tonne. You have to do this within 6 months. You can report to ECHA using a Downstream User Report webform, which is accessed from the downstream user pages of the ECHA website. 15 All good things come in threes Head Heart Hand 16 8

9 Thank you for your attention. 17 9