UEIL. Independent Union of the European Lubricants Industry

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1 UEIL Independent Union of the European Lubricants Industry

2 HSE Committee Report HSE Committee Meetings 29 th January & 14 th May 2014 Caroline Slinn Afton Chemical

3 VSI Survey on CLP labelling VSI conducted a survey of Germany companies on the CLP labelling requirements (presentation available). In summary very few companies comply fully with the present system. For example companies tend to use just 1-3 languages, not fulfilling the requirement to label in all languages where the product is sold. Concerns regarding the requirement to print the labels in all 27 languages where the product is sold. The group discussed the idea of folded labels in a standard format for some cases (small / irregular sized packaging). Concerns regarding the costs for companies relating to potential new printing systems etc.

4 CLP labelling Information document has been drafted and will be available on UEIL website soon. Document explains to end users that they will see a different symbols and phrases but the formulation of products will be the same and not a result of any additional testing. Will include a few illustrations and examples. Explains the background to CLP

5 Live Projects Indoor Air Quality Stage 1 = Identify various measurement devices presently used to measure indoor air quality and a benchmark which gives reproducible results Stage 2 = Evaluate the effectiveness of the methods (practicality, size, price, accuracy etc.) Stage 3 = Find a workshop and evaluate UKLA will pay for first next stage as part of the project in conjunction with the HSL results expected at June s MWF PSG meeting. A 2 year project has recently started in Finland indoor air quality (specifically as a result of oil mixed filters) Finnish research centre and the Institute of working environment.

6 Live Projects Ionic mixtures MIPA / MEA with various chain length fatty acids. Eyes: C16 and above not classified (MIPA/C16 to be re-tested) (same for MEA / MIPA) Skin: C14 and above not classified the results for MEA /Lauric acid differ rom the ECHA info. (ECHA data says C14 is irritant) Draft summary documents summarising the work and results have been prepared - two separate documents, as two different hazard classifications, possibility to merge in the future. To be published on open section of UEIL website, intended for people to use to generate SDS s. The group s interest is to have consistency, the more people that use it the better. Project should be referred to as ionic mixtures, authorities will want salts registered. The salts were made purely for this research, don t exist in MWFs.

7 Boric Acid Polish proposal was for reclassification of boric acid from 1B to 2 (developmental effects) and removal of classification for fertility effects. Opinion of RAC (committee for risk assessment, part of ECHA) is that they do not support any change in classification 21/3/14 likely that ECHA will adopt this opinion. The present special concentration limit for boric acid is 5.5%. This was not mentioned in the polish dossier, therefore RAC couldn t comment as part of the official opinion on the polish dossier. RAC did comment that original special concentration limit was calculated using an old method and should be calculated according to CLP criteria. Based on new criteria a special concentration limit of 0.3% would be applied (same as general / default limit). This isn t officially part of RAC s opinion but leaves the topic open to further review. No news yet on whether or not boric acid will be prioritised for authorisation.

8 Boric Acid Paper in Germany supports keeping the classification as it is. Very clear paper explaining all the issues relating to boric acid and it s safe use in mwfs. Now translated into English. Potential for this paper and the UKLA position paper to form the basis of a UEIL paper. All agreed that education is vital, difference between hazard and risk. The market for boron containing products slowly declining. Customers are having to decide now, whether or not to go boron free, they can t wait for decisions.

9 REACH / SDS, Mixtures & MWFs Confusion around exposure limits, if a material in the formulation has an exposure limit then it has to be mentioned in the SDS section 8, even if it is does not have a hazard classification and does not appear in section 3. Project in Germany looking at creating a REACh type regulation for mixtures has now been put on hold.

10 ATIEL / ATC GES was presented to ECHA in February 2014, the strategy is to communicate this approach to as many people as possible so that people will use it. Need to convert everything in GES into CLP, change from R to H, then need to check boundary conditions meet the new phrases.

11 Biocides MWFs can be: Biocidal products Treated articles Neither George Mansveld of Cimcool has convinced Dutch authorities that MWFs are not biocidal products, but are treated articles. This is now incorporated in their manual of decisions. This also covers Base packages, but should only refer to the products as concentrates which are diluted for use. The recommendation of the HSE committee is that if MWF producers do not claim any biocidal activity in any of the literature or labeling associated with the product and then they will not have to state that the product contains a biocide on the label. Examples of incorrect claims which should be avoided could be : a long life due to the inclusion of biocides the biocides in use increase the working life of the MWF

12 Formaldehyde in Metalworking Formaldehyde to be reclassified as carcinogenic 1B and germ cell mutation category 2 under CLP, April ECHA expected to put formaldehyde on SVHC list Similar to boric acid situation, any product containing more than 0.1% formaldehyde to be classified toxic. For formaldehyde releasers that have <0.1% of free formaldehyde (as supplied) there is no change in labeling expected, therefore no change to the labeling of the MWF will be required. AS THINGS STAND AT THE MOMENT! All hazard label requirements at the moment assume no change to the ingredients chemically. Presently a working group in Germany looking at measuring free formaldehyde and formaldehyde releasers.

13 Formaldehyde in Metalworking MBM is the first formaldehyde releaser to be looked at as part of BPR approval process Austria looking at MBM Austria have put a substitution proposal forward for MBM Criteria are based on the intrinsic hazardous properties in combination with the use An active substance will be considered as a candidate for substitution if any of the following criteria are met It meets at least one of the exclusion criteria (such as classified as a CMR- this could cause the active to be refused approval and substitution mandated). It is classified as a respiratory sensitiser Its toxicological reference values are significantly lower than those of the majority of approved active substances for the same product type and use It meets two of the criteria to be considered as PBT It causes concern for human or animal health and for the environment even with very restrictive risk management measures It contains a significant proportion of non-active isomers or impurities Austria are arguing that formaldehyde is instantly released in use Worst case scenario this could be reclassified 1B Cefic (FABI) lobbying against this, support requested. If MBM is reclassified then by default all other formaldehyde releasers could follow suit.

14 Triethanolamine Occupational health insurers (INRS) in France produced a paper recommending not to use TEA. No rationale behind this as yet. They suggest TEA can form DEA, but provide no reaction conditions. Could also be that some grades of TEA contain DEA doesn t state and does not set any limits. Worry that they are sending the wrong message, Michael Rocker to speak to his contacts at INRS.

15 Country Issues France - Second year of having to declare nanopartlicles - producer registers with a number and passes all the way down the supply chain. Phased introduction of system of the compulsory registration of hazardous materials (formulation details ) with the authorities Germany - Paper on aspiration hazards now available in English DCHA and Sodium Pyrithione papers to follow soon in English Italy - Federchimica / GAIL putting pressure on authorities re: excise duty. SISTRI online registration system to track hazardous waste online starts Jan 1 st 2015 Turkey - A shadow CLP system will become effective 1 year behind CLP Substances June 2015 / mixtures June 2016 Proposal to introduce a system of import declaration on imports over 200L has been postponed

16 Forthcoming Events ILMA MWF symposium Chicago th September 2015 UEIL Congress Madrid 22 nd - 24 th October 2014

17 Rue du Luxembourg, 22-24, B-1000 Brussels Tel:

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