Health and Safety Executive

REACH news

Dichloromethane (DCM) Restriction

A new ban on some supply and use of paint strippers containing the hazardous substance ‘dichloromethane’ (DCM, and also known as methylene chloride) is coming into force.  For the purposes of this ban, the term 'paint stripper' is taken to mean DCM (or mixtures containing it) intended for stripping paint, varnish or lacquer.

Pure DCM (or mixtures containing it) sold and used for other purposes (e.g. degreasing) aren’t banned and can continue to be sold and used (although not for stripping paint).

The new ban makes a distinction between three types of use:

  • ‘Industrial’ use of paint strippers in ‘industrial installations’ (i.e. facilities where paint stripping takes place) – this is allowed to continue as long as certain safe working practices are followed.
  • ‘Professional’ use by workers where this takes place away from an industrial installation.  This will be banned, but UK can choose to allow continued safe use by specifically trained professionals.
  • ‘Consumer’ use by the general public, such as DIY.   Supply to consumers is banned.

Industrial use

Use of DCM-based paint strippers can continue in industrial installations so long as certain safe working practices are followed. Supply for these uses is also permitted. The required conditions for continued industrial use are listed in paragraph 4 of the restriction text:

(a) effective ventilation in all processing areas, in particular for the wet processing and the drying of stripped articles: local exhaust ventilation at strip tanks supplemented by forced ventilation in those areas, so as to minimise exposure and to ensure compliance, where technically feasible, with relevant occupational exposure limits;

(b) measures to minimise evaporation from strip tanks comprising: lids for covering strip tanks except during loading and unloading; suitable loading and unloading arrangements for strip tanks; and wash tanks with water or brine to remove excess solvent after unloading;

(c) measures for the safe handling of dichloromethane in strip tanks comprising: pumps and pipework for transferring paint stripper to and from strip tanks; and suitable arrangements for safe cleaning of tanks and removal of sludge;

(d) personal protective equipment that complies with Directive 89/686/EEC comprising: suitable protective gloves, safety goggles and protective clothing; and appropriate respiratory protective equipment where compliance with relevant occupational exposure limits cannot be otherwise achieved;

(e) adequate information, instruction and training for operators in the use of such equipment.

Paint strippers supplied for industrial use must be labelled in accordance with either the CHIP Regulations or CLP, and must also be 'visibly, legibly and indelibly marked' with the text 'Restricted to industrial use and to professionals approved in certain EU Member States — verify where use is allowed.' Suppliers will wish to satisfy themselves that mixtures are being supplied for legal uses, in order to explain such a due diligence approach if challenged.

Professional (mobile) use

The ban first took effect on 6 December 2010.  Since then formulators of DCM-based paint strippers have not been allowed to put their products into the supply chain for use outside industrial installations. Suppliers could however continue to sell existing stocks to professionals or the public for a further year, until 6 December 2011. On the 6 June 2012 all use of DCM-based paint strippers by professionals outside industrial installations will have to cease.

DCM-based paint strippers are particularly effective at removing very durable coatings – including leaded paint – quickly and without damaging the substrate.  Along with normal paint stripping, DCM-based strippers are widely used the heritage, aerospace and maritime sectors, and for graffiti removal. HSE will consult in the next few months on taking up the derogation to allow continued professional use.  In order to do so, both the government and stakeholders would need to make certain arrangements.  Although we don’t expect to be able to take up the derogation in time for the 6 June 2012 deadline, subject to consultation these measures may be made available later.

Current REACH consultations

Restrictions:

1) Chromium VI in leather articles

The six month consultation period runs from 16th March to 16th September 2012 however, ECHA encourages interested parties to give their comments by 1 June 2012.

Denmark has submitted a report proposing a restriction on the placing on the market of articles of leather coming into direct and prolonged or repetitive contact with the skin if the leather contains chromium VI in concentrations above a certain limit.

Chromium VI is not intentionally used in the preparation of leather from skins and hides and in the manufacturing of articles of leather, but may be formed during the processing. The presence of chromium VI in tanned leather and articles of tanned leather can be avoided, under properly controlled conditions.

Chromium VI is known amongst other effects to cause severe allergic contact dermatitis in humans and to be able to elicit dermatitis at very low concentrations. The dossier demonstrates that extractable chromium VI from shoes and other articles of leather represents a risk for the development of contact allergy to chromium for the consumers and workers.

Surveys of chromium VI in articles of leather in some of the Members States have demonstrated that more than 30% of the tested articles of leather contained chromium VI in concentrations above 3 mg/kg (which is the proposed concentration limit).

2) 1,4-dichlorobenzene used in air fresheners and toilet blocks

The six month consultation period runs from 19th June to 19th December 2012 however, ECHA encourages interested parties to give their comments by 1 September 2012.

The European Chemicals Agency (ECHA) has, on the request of the European Commission, submitted a report proposing a restriction on the placing on the market and use of 1,4-dichlorobenzene-based air fresheners and toilet blocks. These products are mainly used to deodorise public and domestic toilets.

The air fresheners and toilet blocks targeted by this restriction typically contain up to 99% 1,4-dichlorobenzene, the remaining 1% being dye and/or perfume. Consumers are exposed to the substance when they use 1,4-dichlorobenzenebased products at home or when they visit public toilets deodorised with these products. In addition, professional workers employed in the public toilets are also exposed.

1,4-dichlorobenzene has been classified as a category 2 carcinogen (liver tumours). It also affects the kidneys and respiratory tract. The dossier demonstrates that consumers using 1,4-dichlorobenzene products at home, and professionals employed in public toilets where 1,4-dichlorobenzene products are used are exposed above safe levels, i.e. the risks from the substance in these population groups are not adequately controlled.

It is estimated that the benefits of the restriction would be between 9 and 22 times higher than the costs. Given the costs to society and estimated health benefits the proposed restriction is considered proportional to the risks.

The dossiers, information notes and commenting forms for both restrictions can be found on the ECHA website;

Public consultation on the evaluation of new scientific evidence concerning the phthalates DINP & DIDP

ECHA have produced a draft report reviewing the scientific evidence on the risks posed by articles containing the phthalates DINP & DIDP. Comments are invited from interested parties until 31st July 2012

The report and commenting form can be found on the ECHA website

Authorisation:

Draft recommendation of ten new priority substances to be included in the Authorisation List – 4th prioritisation exercise.

ECHA regularly recommends to the European Commission substances from the Candidate List for inclusion in the Authorisation List (Annex XIV of REACH). Based on an assessment of the available information, ECHA currently plans to recommend the following substances:

  1. formaldehyde, oligomeric reaction products with aniline (technical MDA)
  2. arsenic acid
  3. dichromium tris(chromate)
  4. strontium chromate
  5. potassium hydroxyoctaoxodizincatedichromate
  6. pentazinc chromate octahydroxide
  7. bis(2-methoxyethyl) ether (diglyme)
  8. N,N-dimethylacetamide (DMAC)
  9. 1,2-dichloroethane (EDC)
  10. 2,2'-dichloro-4,4'-methylenedianiline (MOCA)

Further information & the commenting forms can be found on the ECHA website;

Public consultation on ECHA's fourth recommendation of priority substances to be included in Annex XIV

E-Team - A new project to evaluate REACH Tier 1 exposure assessment models

The Institute of Occupational Medicine is evaluating the different Tier 1 exposure assessment models under REACH: the ECETOC TRA, MEASE, EMKG-Expo-Tool and Stoffenmanager.

The 18-month project, which is sponsored by the German Federal Institute for Occupational Safety and Health (BAuA), will investigate the conceptual bases of the models, evaluate their user-friendliness and reliability, and then compare model predictions of inhalation and dermal exposure with real workplace exposure data. The study will provide guidance for model users, industry and regulators on the range of applicability of models across different exposure situations.

If you would like further information, or are interested in participating in the study, please visit the project website www.eteam-project.eu


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Updated 28.06.12