Filed under: ECHA, EU Information, REACH/CLP | Tags: chemicals, REACH, SVHCs
There has been some activity in the long-running dispute within the EU regarding how to calculate the level of substances of very high concern (SVHCs) in articles. The European Commission have written to those Member States disagreeing with the guidance issued by ECHA, the European Chemicals Agency.
Delegates attending the Government Chemist Advisory Seminar in February 2012 on REACH and CLP in the vehicle and construction sectors will recall that this issue was raised by more than one speaker. It centres around the fact that 5 Member States – Austria, Belgium, Denmark, Germany and Sweden – consider the guidance given by ECHA is incorrect. Whereas the ECHA guidance states that an SVHC at a concentration of greater than 0.1% by weight in an article will require the article to be notified under Article 7(2) of REACH, these 5 Member States (plus non-EU Norway) believe that the 0.1% threshold applies to all components of the article. This means that if any component of the final product (= article) contains an SVHC above 0.1% by weight, then the product needs to be notified. This approach could relate to more articles being notified, although the OVERALL concentration of SVHC is less than the threshold.
There is an analytical measurement dimension to this. The level of laboratory work required to measure SVHCs in each individual component of an article is greater than that if the article as a whole is taken. Of course, in some cases individual components do have to be taken for analysis, and we need to consider in such a case that the summation of all individual measurement to arrive at an overall SVHC level will have a significantly higher uncertainty due to the combination of all measurement uncertainties from each component.
The 5 Member States have now replied to the Commission, which is now studying these to decide if a breach of Treaty rules has occurred, and whether further action is necessary.
It will be interesting to see how this situation develops.
Major textile and garment manufacturers have been moving towards a hazardous chemical free position for some time now. 15 have signed up to Greenpeace’s detox campaign. Many of these are also members of the Zero Discharge of Hazardous Chemicals (ZDHC) Group.
The group wish to move to a position in 2015 where a defined list of hazardous substances can be phased out completely, and to that end need to talk to all their suppliers – which form a very complex supply chain with a significant number of companies across many different countries – to enable this to happen.
These chemicals, which are detailed in this list, will require monitoring in order to check whether they have been removed from the supply chain. This will require validated methods to be used and, where necessary, developed to enable such monitoring to be effective. This may become of particular importance in the future as some of the chemicals on this list – including phthalates, and lead – have been identified in a report as potentially being involved as endocrine-disrupting activity which plays a part in the development of obesity.
Filed under: EU Information, RoHS/WEEE, Uncategorized | Tags: chemicals, toxic mercury, WEEE/RoHS
The European Commission has announced that it is to evaluate only 4 substances for inclusion in the list of restricted substances under the Restriction of Hazardous Substances (RoHS) directive. The substances in question are:
- Hexabromocyclododecane (HBCDD), a brominated flame retardant
- Diethy hexyl Phthalate (DEHP)
- Benzyl Butyl Phthalate (BBP)
- Dibutyl Phthalate (DBP)
These substances are of concern where present in waste streams. Measurement methods do exist for the determination, but the development of Certified Reference Materials (CRMs) of simulated wastes containing these substances would be of significant benefit to laboratories, both regulatory and in industry, wishing to check waste products for their presence and quantity.
Filed under: chemicals, Water | Tags: endocrine disrupters, testing, Water Framework Directive
Researchers at the Goethe University Frankfurt in Frankfurt am Main, and the German Federal Institute of Hydrology have conducted tests on bottled water which have shown the presence of the endocrine disrutping chemical (EDC) di(2-diethyl hexyl) fumarate (DEHF).
Tests were carried out using bioassay which confirmed endocrine disrupting behaviour, followed by High Resolution Gas Chromatography Mass Spectometry (HR-GCMS) to identify the EDC substance itself.
Although the report does not indicate the levels of DEHC in the bottled water, so the risk cannot be easily estimated, many EDCs are known to be active at exceptionally low levels and can be considered not to have an threshhold value.
Industry bodies representing the digital technology industry have submitted their comments to the European Commission on the proposed list of EEE (electrical and electronic equipment) substances to be controlled under the revised Restriction on Hazardous Substances (RoHS) directive.
Their comments indicate several problems with the proposed list, including the number of substances proposed which are already on the list or controlled by other regulations such as REACH. This is a continued indication of the lack of a joined-up approach to EU regulations of chemicals across the different Directorates-General and sectors. The number of proposed substances not used in the digital technology industry – and therefore not needed to be controlled – was also an issue.
However, one of the more worrying comments in this response concerned the “lack of use or wrong use of CAS numbers concerning several entries makes the review of the inventory difficult. In case of substance groups being proposed for restriction, all relevant CAS numbers should be provided”. The nomenclature of substances is a fundamental underpinning factor in the correct description and subsequent regulation of chemicals and needs to be correct otherwise any regulation based upon it is undermined.
Filed under: chemicals, ECHA, REACH/CLP | Tags: CLP; REACH; Chemicals; ECHA, Consultation, SVHCs
EU Member States have proposed a further seven substances to be added to the REACH Candidate List for Substances of Very High Concern (SVHCs). This is due to their CMR (carcinogenic, mutagenic and reproductive toxicity) properties. A public consultation from ECHA, the European Chemicals Agency is underway until 17 October 2013.
The seven substances are:
- Cadmium sulfide
- Dihexyl phthalate
- Disodium 3,3′-[[1,1′-biphenyl]-4,4′-diylbis(azo)]bis(4-aminonaphthalene-1-sulphonate) (C.I. Direct Red 28)
- Disodium 4-amino-3-[[4′-[(2,4-diaminophenyl)azo][1,1′-biphenyl]-4-yl]azo] -5-hydroxy-6-(phenylazo)naphthalene-2,7-disulphonate (C.I. Direct Black 38)
- Imidazolidine-2-thione; 2-imidazoline-2-thiol
- Lead di(acetate)
- Trixylyl phosphate
The European Chemicals Agency, ECHA, has updated its figures concerning the number of registrations granted following the May 2013 2nd REACH Registration deadline.
Detailed analysis shows that following completeness checks carried out by ECHA up to 31 August 2013, registration numbers have been granted to 9 030 submissions. There are 17 dossiers still pending because the registrants have to resubmit their dossier following a request for further information from ECHA.