HSE Meeting January 2013-03-18
A number of important items were discussed during the latest HSE group meeting in January in Brussels (Belgium). A special focus was given to metalworking fluid items, but also to REACH.
Lubrizol gave a short presentation on biocides. Biocides are key additives for water-miscible metalworking fluids (MWF). According to the new biocide directive, all products treated with biocides are Treated Articles (TA, MWF are also considered as "article”(!)) and TA have to follow special label requirements:
- Note regarding use of Biocide Product
- Still in discussion: revealing all Active Substance + its concentration
- Handling instructions and precautions based on the Biocidal Product in the Treated Article
- Labeling with all relevant use instructions including safety measurements, if needed to protect human and environment
- Labeling easy to read and visible, permanent, and in the official language of the country of sales: on package, technical data sheet and letter of guarantee
Thus an additional label is required.
Another challenge for our industry is the high possibility that formaldehyde will be classified as CMR category 1B within the next years, likely in 2015. Although formaldehyde releasing biocides contain free formaldehyde only in minor amounts and a re-classification is likely not needed, some users may ask for formaldehyde free products. The HSE group will follow this process closely an provide information, also for communication on these items with formulators and users.
Another important issue for our industry is boric acid: apparently there is a dossier in preparation to re-classify boric acid into CMR, Category 2 (CLP). This would mean that boric acid will be withdrawn from the SVHC list and use restriction will not apply. However, this process will take several years but shows that EC decisions can be challenged.
The HSE group set up a new project named "indoor air quality”. Our aim is to provide information on substances evaporating from lubricants and their risk on human health, if applicable. In addition, we may set up a
Thanks to the UEIL office, Ms. P. Hualde, policy officer of the European commission gave a presentation on "REACH review”. She began by stating that the review is still not available to the public and that conclusions from the European Commission (EC) would come in the days following the meeting. Ms. P. Hualde gave a presentation on the REACH Review issue. The presentation contained an overview of the review’s objectives, indications to take from performed studies, planned follow-up from the EC (a stakeholders’ conference is predicted for March), and the link between this review and Industrial Policy (EU-level). After the presentation, the group took the opportunity to ask a number of questions on REACH an raise concerns especially of small and medium sized enterprises (SME) e.g. (answers is brackets)
- if there is a way for the EC to measure REACH’s impact on Competitiveness and Innovation? (Three of the studies (desk research) mentioned in the presentation cover this issue).
- how much evidence there is of companies not complying, and if these companies have been more advantaged in terms of market competitiveness. (enforcement is mainly the responsibility of National Authorities. The latter have to come up with legislation creating sanctions – and other measures. REACH regulation foresees nonetheless forums where National Authorities can exchange practices. The EC encourages every Member State to increase their respective authorities to further participate on these activities.)
- costs that REACH has implied to companies are too high, mainly through employment. (the EC is aware of this. Studies have shown, nevertheless, that the recruited personnel is regularly an Research and Development professional that companies might benefit from in the future.)
- there is too much legislation reaching companies simultaneously, making it impossible to be in compliance because it takes to too long to do so. (EC realizes that the lack of skills is an issue, and informed that the European Chemicals Agency (ECHA) is working on that as well through the establishment of programs and modules in Universities that would allow for students to be better prepared to help companies right after they graduate.)
- if mixtures would be included in the review. (the exercise aimed at looking to the overall impact of REACH, not specifically on any substance.)
The full Q&A section can be found in the minutes of the HSE meeting available on the UEIL website. The lubricant industry consists mainly of SME enterprises suffering more than other companies from REACH. REACH was selected by SMEs as the most challenging legislative initiative of the EU in the last decade: http://ec.europa.eu/enterprise/policies/sme/public-consultation-new/index_en.htm.
Mixtures – UBA Conference
The next steps of European legislation on chemicals may arise: The UBA (German Office for Environment) organized a conference on mixtures. Unfortunately only a very few industry representatives were invited (about 10 out of 60). Some authorities and independent consulting agencies are looking for (eco-) toxicological "synergistic effects” of mixtures. In an initial paper, UBA looks for test methods and test criteria to asses the toxicological properties of mixtures. This could become of course a new thread on chemical industry and the HSE committee as well as other industry working groups will follow this discussion carefully
ATIEL/ATC use groups available on the ATIEL website
The ATIEL/ATC working-group has published the long time expected Generic Exposure Scenarios (GES) for lubricants on its Website (www.atiel.org/reach) along with some guidelines and flowcharts. REACH requires that suppliers of (dangerous) substances inform users about risks and risk management measures (RMM). This applies also for substances in mixtures, e.g. lubricants. In order to standardize the hazard communication, ATIEL/ATC set up 6 standard exposure scenarios for all kind of lubricants to ease the hazard communication between additive suppliers, lube manufacturers and end users.