Transcript Transferring Knowledge to Enable Safe Working With Hazardous Chemicals in Small Firms : A Chemical Industry Perspective on What Really Matters Chris Money Cardiff, 6th March.

Transferring Knowledge to Enable
Safe Working With Hazardous
Chemicals in Small Firms :
A Chemical Industry Perspective on
What Really Matters
Chris Money
Cardiff, 6th March 2008
Outline
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Core considerations for successful knowledge transfer
Supplier systems for knowledge development and
transfer in the chemicals supply chain
To what extent are existing systems working
satisfactorily?
To what extent might REACH lead to improvements?
Core Considerations For Successful
Knowledge Transfer
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The chemical industry generally considers the following to
be core to any process for successful knowledge transfer
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Relevance of the information for the user
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Correctness
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It needs to be seen as being trusted
Understandability
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It should not be too generic/abstract e.g. “wear gloves”
Practical, pragmatic, oriented to sector terminology, etc.
Any knowledge transferred without consideration being
given to these considerations is unlikely to be wholly
successful
What Characterises How Chemical
Suppliers Communicate Risk?
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A series of considerations characterise the nature of information
provided by chemical suppliers
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The nature of the products marketed
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Product stewardship aspirations of the company
Available technical competences
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Both at the supplier and subsequent (formulator) levels
Liability
Effectiveness of the communications
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Are they generally perceived as being hazardous?
Complex communications inevitably lead to questions
This leads to inconsistencies across the supply chain
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When seen against the complexity of the chemicals supply chain (substances
and preparations) and
The number of suppliers/substances/preparations/uses
Supplier Systems For Knowledge
Development And Transfer
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Information on chemicals risks is communicated (by
suppliers) through a number of different mechanisms
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Safety Data Sheets
Supply chain dialogue
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Trade associations
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Sales, technical support, technical applications notes
At the regional and national level
National authorities
(Joint initiatives) e.g. UK HSE IACs
To What Extent Are Existing Systems
Working Satisfactorily?
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The primary system through which industry
communicates knowledge is based on the SDS
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Supported on an ad hoc basis by technical advice issued at the
company, sector or national level
Is there evidence that there is a failure of this system to
properly work?
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Poor SDSs exist as well as good ones
Both types of SDS are supplied to SMEs
Some SMEs respond positively to SDS (and other)
information, while others do not
The picture is complex
To What Extent May REACH Lead To
Improvements?
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Fundamental concepts behind REACH are that
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Every substance has to be registered for (safe) supported uses
(throughout the life cycle)
The safe uses must be communicated down the supply chain (via
Exposure Scenarios [ESs] contained in the SDS)
Although the supply of ESs is only applicable to some types of substance
But as the primary responsibility rests with the M/I, will M/Is
‘copperplate’ the ES in order to guarantee the substance's
registration?
And as most SMEs handle chemicals as preparations, what
requirements does REACH place on formulators?
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Formulators are obliged to ‘pass on’ the information received from
suppliers. Is such an obligation workable for complex preparations (i.e.
multiple Exposure Scenarios)
Content of an Exposure Scenario (1)
Short title:
1
2
3
Description of activities + processes
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5
6
Physical form of product
Duration and frequency of use, with adequate control of risk
Product specification (concentration or % of substance in preparation
or article)
Maximum amount per time or activity, with adequate control of risk
Other operational conditions of use (if relevant)
• temperature, pressure
• emission or release factors determined by technology
• capacity of receiving environment (e.g. room size x ventilation rate)
• other
Content of an Exposure Scenario (2)
Short title:
7
Risk management measures for adequate control of risk:
options to be phrased as instructions
impact of single measure or combination of measures to be quantified
structure according to exposure routes often useful
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Waste related measures (incl. substances in articles at the end of
service life)
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• Prediction of exposure and reference to the source of prediction;
• Risk control indicator/parameter if applicable (e.g. “safe amount”)
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Variables and algorithm for scaling at DU level (including underlying
assumptions)
• Other methods to check compliance
Exposure Scenarios
1. Short title of Exposure Scenario
Exposure to a solvent (hazard group A[1]), solvents based products [PC35], coatings and paints, fillers, putties, thinners [PC9] in building
and construction work [SU19] by professional spraying outside industry settings and/or applications [PROC11] using air dispersive
techniques [OU9].
2. Description of activities/process(-es) covered in the Exposure Scenario
Professional indoor spraying of paints containing PGME [107-98-2]. The process also involves the mixing (homogenizing) of paint and
filling of the spray gun before application and cleaning of the spray gun by rinsing with water, followed by wiping with a cloth afterwards.
3. Operational conditions
3.1. Duration and frequency of use for which the ES ensures adequate control of risk
The full process can be done up to 300 days per year per professional company.
Individual workers can perform this task daily (approximately 250 days/year). The work is done in situ, not at a fixed working place, actual
spraying takes up to 8 hours.
•3.2. Other operational conditions determining exposure
•The operations are carried out at room temperature and atmospheric pressure. Water is the preferential target compartment at equilibrium
according to the predicted distribution (para 8a)
4. Physical form of product
The product is a water based liquid paint.
5. Product specifications
PGME in water based paints at a maximum concentration of 5%. The density of paint is 1.3.
6. Risk Management Measures that, in combination with the operational conditions of use, ensure adequate control of risk related to the
different target groups
Exposure Scenarios
6. Risk Management Measures that, in combination with the operational conditions of use, ensure adequate
control of risk related to the different target groups
RMM’s to ensure safe use (maximum amount of solvent used 5% of 20 liter paint = 1 liter, ref ESIG control
strategy 1):
 Ventilation; keep windows and doors open during application.
 More extensive indoor spraying (medium scale > 1 litre solvent or 20 litres paint ): provide extraction booth
large enough to contain all equipment. Spraying on site (e.g. construction sites) requires mechanical
ventilation/ extraction fan and respiratory protective equipment, Air-purifying Half-Mask (with gas/vapourcartridge, that can be combined with a particulate filter (APF = 10, W30.09)
 When extractor fan is used ensure sufficient uncontaminated make up air is provided.
 Visual check ventilation equipment at least weekly (e.g. using smoke) to ensure that it is working and has
not been damaged. Get ventilation systems checked periodically against the performance specification and
keep records of the tests.
 Clean spray gun regularly.
 Conduct periodic air monitoring to assess potential for exposure based on local operational conditions.
 Avoid contact with skin and eyes.
 Give worker information on the hazards or solvents; provide training on handling solvents safely.
 Check that control measures are in place and being followed.
Exposure Scenarios
8a. Prediction of exposure resulting from the conditions described above (entries 3-6) and the substance properties
8b. Control thresholds derived from the exposure prediction, like e.g. maximum emission, “safe to use amount” (msafe) or “safe concentration
in product” (csafe)
8a. Worker exposure resulting from the conditions described above (entries 3-6) and the substance properties is:
Maximum inhalation exposure during application of paint ranges is 370 mg/m3.
Dermal exposure = 256 mg/day (homogenizing paint, filling the spray gun, cleaning the spray gun) (EASE)
Combined internal exposure= 6.4 mg/kg bw/day
The predicted distribution of PGME is as follows: 4,1% to air, < 0,1% to soil, 95,8% to water, << 0,1% to sediment, 0% to suspended
sediment, 0% to biota (fish)
Local PEC in surface water during emission episode (dissolved) <1 mg/L (0.281 mg/L)
8b. It was not necessary to calculate the safe to use amount (msafe) nor the safe to use concentration in product (csafe). This ES assumes a
concentration of 5% in paint.
9. Where relevant: A set of variables and a suitable algorithm which together indicate safe use. Other methods to check compliance at DU
level may be included here as well.
This generic ES ensures safe use of low hazardous solvents within the boundaries described.
[Product evaluated]: ESIG group A solvents; propylene glycol methyl ether [107-98-2].
[Substance properties]: maximum vapour pressure = 1200 Pa (pure PGME). Partial vp used : 60 Pa
TRA: [scenario] spraying of substance mg/m3 [fugacity] Low [LEV] No task = 374 mg/m3
Dermal exposure input parameters (EASE 2.0): task = spraying [Use pattern] Wide dispersive use [Aerosol formation] Yes [Tendency to
become airborne] High [Process fully contained] No [Pattern of control, inhalation] Direct handling with dilution ventilation] [Pattern of
control, dermal] direct handling [Level of contact, dermal] Intermittent (1-10 times/day)] [Area of skin exposed: Two hands = 840 cm2]. Task
= 256 mg/day
100% absorption through inhalation, 30% dermal absorption. Workers 8 hours exposure, 70 kg bw. 10m3 inhalation
EUSES 2.0 (Number of emission days per year = 300. Production volume in EU (tonnes.yr-1) 1,88E+05 Regional production volume =
7,73E+04. Fraction of tonnage for application = 0,077. Fraction of chemical in formulation = 0,2. Fraction of tonnage for application = 0.007.
Emission tables = A4.5 (specific uses), B4.5 (specific uses) IC = 14, UC = 48 (water based). LOCAL PEC = [INDUSTRIAL USE]
Maximum Derived No Effect Level (DNEL) indicating safe use; Inhalation exposure (eye irritation) 374 mg/m3 (8 hour average Occupational
Exposure Limit value). Internal exposure, systemic effects (Adaptive liver changes): 20 mg/kg bw/day .The Predicted No Effect concentration
(PNEC) for freshwater = 10 mg/L.
REACH Exposure Scenarios
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DUs generally find the REACH Exposure Scenarios (ESs) to be
helpful and much better than existing SDS guidance
But the REACH TGD description of the ESs is abstract for many
DUs i.e. they find it difficult to identify those ESs of relevance for
them
DUs are also not clear how they are meant to respond to some
portions of the ES e.g. compliance checking
Some DUs commented that the REACH ESs appear to contain more
information than may be necessary to simply describe exposure
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They also commented that the ‘duplication’ of information across the eSDS was
unnecessary
Generic ESs have therefore been suggested as a better solution for
SMEs to more easily identify those ESs of relevance to their
activities/operations
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Based in part upon the COSHH Essentials and ?? ideas
Generic Exposure Scenarios
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Rather than indicate which specific ESs are relevant for a
particular area of application, it may be possible to consolidate
the information from such ESs into a composite ES for the
broad area of use/application (termed a Generic Exposure
Scenario)
Can approaches such as the COSHH Essentials aid in the
identification of suitable generic/composite ES for an use?
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Provides opportunity for alignment of REACH with Chemicals Agents
Directive etc
Many DUs are most supportive of this type of ES
Composite ESs also have the potential to more efficiently deal
with how information on complex preparations is
communicated/ transmitted in the supply chain
Generic Exposure Scenarios
Risk
management
measures
Human health
-Pouring from small containers : undertake in a well-ventilated area. Wear
suitable gloves (type EN374, code FJ) if skin contact likely.
-Spraying : carry out in a vented spray booth. If no dedicated facility
available, then use a respirator conforming to EN140 (with Type A filter) or
better standard and undertake in a well-ventilated area segregated away
from other work activities.
-Manual applications e.g. brushing, rolling, spreading : undertake in wellventilated workplace. Use long handled brushes and rollers where possible.
Wear gloves (type EN374, code FJ) if prolonged contact with coatings
expected.
-Equipment clean-down : Wear gloves (type EN374, code FJ) if prolonged
contact expected. Transfer wash-downs in sealed containers. Use liquors as
recycle solvent or send for disposal or recycle.
Waste related
measures
Dispose of used containers according to local regulations.
Prediction of
exposure
Estimated workplace exposures (using the ECETOC[ TRA model) during
spraying are not expected to exceed 50ppm (when undertaken in a spray
booth) and 500ppm (when not). Estimated workplace exposures for brushing
and printing are not expected to exceed 20ppm (with extract ventilation) and
100ppm (without extract ventilation). EASE indicates that exposures to
areas of unprotected skin can typically be in the order of 100μg/cm2/day and
up to 1000μg/cm2/day during spraying activities.
Might REACH Have Any Other
Shortfalls?
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Extent to which consistency will be forthcoming
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Transparency
Accessibility
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Across suppliers/substances/uses/sectors/countries
And across time (phase-in periods)
M/I REACH obligations do not necessarily equate to
usefulness for DUs
The REACH Regulation and Guidance might be perceived as
having been written by technocrats for technocrats
Supporting information
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REACH is not an end to Product Stewardship e.g. nonclassified substances; phase-ins; non-SHE communications;
etc.
Summary
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System for the current provision of chemicals safe
handling advice to SMEs is variable
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REACH will formalise supplier duties concerning the
provision of information
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The system could be improved through voluntary initiatives
e.g. Responsible Care
But there will be a need to ensure that the information
supplied remains useful to SMEs
Whilst also enabling EChA (and others) to oversee the
integrity of the substance registrations
REACH has paid no formal attention to the specific
needs of SMEs or the role of social partnerships at the
workplace