A pragmatic approach is needed when selecting what use descriptor, sector of use and process category a particular area of polyurethane manufacturing falls into under the EU’s REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulation.
And this selection needs to be done by a whole sector, rather than by individual processors, emphasised REACH expert, Dr Jürgen Grönen of ISL Chemie.
Otherwise part makers could find themselves swamped by paperwork, because they feel their process(es) fall into several categories, he indicated.
As a result of this realisation, the REACH committee of the FSK (The German association for producers of foam plastics) has intensified its dealings with ISOPA (the European Diisocyanate and Polyol Manufacturers Association), Grönen said.
Since the start of 2009, there has been “constant contact with ISOPA, to find common ground,” he added, in a presentation at the 10-11 Nov meeting of the FSK.
Processors of materials do not have to prepare raw material dossiers within REACH.
But they have to describe and classify their processes, so that material suppliers can feed this evaluation into their data, for assessment of risk during processing of the materials.
Use descriptors needed for risk
Polyurethane processors must produce an exposure scenario, and define their production conditions in a standard way. Then they can evaluate hazard and risk in handling and so devise an environmental exposure assessment (EEA) for their plants.
For downstream users, ECHA — the European Chemicals Agency which oversees REACH — lists ‘Use Descriptors’ for the EEA:
• Sector of Use (SU-Code)
• Product Category (PC-Code)
• Process Category (PROC-Code)
• Article Category (AC-Code)
• Environmental Release Category (ERC).
But these use descriptors (UDs), “will have a big impact on how the material is controlled in the chain,” he stressed, noting that UDs strongly influence risk evaluation and risk procedures.
The language in the REACH documentation is very technical, Grönen said, and PU does not fit easily into the UDs given.
If product makers decide their process fits into a lot of categories, things can get “intensely complex,” he said: “No-one would be able to handle it.” Processors need to pick the most appropriate code and stick with that.
It is not sensible for individual companies to develop process categories: “Even ECHA has said industries should do this together in groups,” commented Grönen.
In discussions between the FSK, ISOPA and Europur (the European Association of Flexible Block Foam Manufacturers), the groups decided they needed to make the system workable.
Categories for PU identified
“We decided we would look and see if we could use these SUs (sectors of use), and sort them into appropriate categories for CASE (coatings, adhesive, sealants and elastomers), flexible and rigid foam and polyureas,” Grönen said. FSK carried out preliminary mapping with ISOPA, Grönen said.
Users simply need to ask themselves, “Where am I working?” This approach is very sensible and produced five basic SUs for PU, with most focus on three: SU8 Raw materials manufacturers SU3 Industrial uses SU10 Formulation (SU22 Professional use) (SU21 Consumer use) Everyone can identify a category for themselves in this way, he added. The first action is to simply put what you do into words and see which category fits best.
So far the recommendation covers only PU materials and not additives such as flame retardants and antioxidants, Grönen said.
He also stressed that if a raw material manufacturer wants to purchase an isolated intermediate (aiming for low registration costs out of REACH) and “if you are a downstream user and purchase this and mix it, you have broken all the REACH rules.” Grönen went on to describe the regulations on CLP (classification, labelling and packaging) as like, “a Damocles sword hanging over us.” In discussions, Grönen said the FSK would warmly welcome collaboration with any other groups in Europe working on these areas.
