How to read an eSDS? Yvonne Jansma NVvA – January 26th, 2012

Transcription

How to read an
eSDS?
Yvonne Jansma
NVvA – January 26th, 2012
C t t
Content
• Introduction IHS
• eSDS within REACH regulation
• Set up of the eSDS
• Exposure
E pos re Scenario information
• eSDS in the workplace
• Conclusion
Copyright © 2010 IHS Inc. All Rights Reserved.
2
The Leading Source of Critical Information
• IHS provides content,
content software and expert analysis
that supports an organization’s ability to advance
critical decisions with speed and confidence.
55 000 customer organizations in
• We serve 55,000
180+ countries around the world
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our customers address challenges in six key areas
areas…
3
Th eSDS
The
SDS within
ithi th
the REACH regulation
l ti
4
E
Exposure
A
Assessmentt
Required when :
• If substance is manufactured / imported >10 tpa
AND
Classified as dangerous according 67/548/EEC
OR
• Persistent, Bioaccumulative and Toxic (PBT) OR very Persistent and
very Bioaccumulative (vPvB) acc. to REACH
Result is communication to DU as Annex to SDS (Art. 31 (7) of
REACH regulation*)
g
)
(*): Regulation (EC) No 1907/2006
5
El
Elements
t off the
th eSDS
SDS
Extended SDS
SDS (section 1 to 16)
ANNEX (Exposure Scenario)
6
SDS REACH information
SDS:
i f
ti in
i section
ti 1
REACH Registration Number
(RRN):
¾Listed for substance SDS in
section 1 (14 digits for
substance ID + 4 digits for legal
entity).
¾No RRN for mixtures.
mixtures See
section 3 for RRN of
ingredients. Only 14 digits will
be displayed.
Uses/Uses ad
advised
ised against
against:
¾ It is important that the use of
the substance in the workplace
is among the “identified uses”.
¾The identified uses are
described in the Annex of the
SDS. If not described/different:
ÆThere is an issue
¾If the use of the substance is
described as “uses advised
against”
7
ÆThere is a – bigger - issue!
SDS REACH information
SDS:
i f
ti in
i section
ti 8
PNEC: Predicted No Effect
Concentration
(environment)
DNEL: D
DNEL
Derived
i dN
No Eff
Effectt L
Levell (h
(health):
lth)
• DNELS for oral/dermal/inhalation
• DNELS for consumers/workers
g term/short term
• DNELS for long
• DNELS normally lower as MAC
(ACGIH acrylonitrile = 4,3 mg/m3)
8
E
Exposure
S
Scenarios…
i
Wh
Whatt format?
f
t?
• In 2010 ECHA Proposed 4 Templates – related to …
•
•
•
•
…uses of substances carried out by workers
…uses of substances carried out by consumers
…service life of substances in articles (handling by workers)
…service life of substances in articles (handled by consumers)
• 4 Sections each…
• + optionally…
E
Exposure
S
Scenario:
i section
ti 1 (Titl
(Title))
USE
DESCRIPTORS
CONTRIBUTING
SCENARIO
(environment and
health)
10
U D
Use
Descriptors
i t
Objective: Pre-defined categories/phrases to help suppliers and users to structure their
communication with each other.
Categories:
• SU: Sector of UseÆ describes in which sector of the economy the substance is used.
•
•
•
•
This includes mixing or re-packing of substances at formulator’s level as well as
industrial, professional and consumer end-uses. (SU18: Manufacture of furniture)
PC: chemical Product CategoryÆ describes in which types of chemical products (=
substances as such or in mixtures) the substance is finally contained when it is
supplied
pp
to end-uses. ((PC25: Metal working
g fluids))
PROC: Process CategoryÆ describes the application techniques or process types
defined from the occupational perspective (PROC07: Industrial spraying)
ERC: Environmental Release CategoryÆ describes the broad conditions of use from
the environmental perspective.
perspective (ERC01: Manufacture of substance)
AC: Article Category Ædescribes the type of article into which the substance has
eventually been processed. (AC7: Metal Articles)
11
C t ib ti S
Contributing
Scenario
i principle
i i l
• For industry it is assumed that operational conditions (OC) and risk management
measures (RMM) ffor a substance
b t
are related
l t d tto ttask/workplace
k/
k l
((= contributing
t ib ti
scenario’s). Release of substance to environment is assumed to be site related.
Æ An exposure
p
scenario on industrial spray
p yp
painting
g may
y include multiple
p health
contributing scenarios to describe the different tasks and various conditions
under which the task is safe to be carried out, so:
• conditions for mixing and filling of equipment (manually)
• conditions for mixing and filling of equipment (automated)
• conditions of cleaning the equipment (manually)
• conditions of cleaning the equipment (automated)
• etcetera
This is mostly linked in the exposure scenario to only one contributing
scenario for environment, for example.
• Spraying/fogging by machine application
12
Section 2: Exposure Controls
Product characteristic
Amount used
Frequency and duration of use/
exposure
Human factors not influenced by risk
management
RMM to prevent release of substance
to
the worker.
worker
- Process control
- From source
- Organisational
- PPE, hygiene
yg
Linked to a “Health Contributing
Scenario!
13
A th example
Another
l
14
Section 3: Exposure estimation and reference
t its
to
it source
Tool for exposure
assessment. Like
“Stoffenmanager”,
“EMKG/BAUA”
Compare with DNEL
(workers):
• Long term inhalation: 2.7
mg/m³
• Long term dermal: 1.4
mg/kg bw/day
15 < 1
Exposure/DNEL must be
(= Risk Characterization)
S ti 4
Section
4: G
Guidance
id
tto d
downstream
t
user.....
How much
additional
i f
information
ti
does this
give?
16
E
Exposure
S
Scenario:
i summary
• Set of conditions that describe how a substance is (safely)
manufactured or used
• Including Operational Conditions (OC’s) and Risk Management
Measures (RMM’s) to control exposures of humans and the
environment.
• May cover one specific process or use or several processes or uses
as appropriate
• Covers the complete life-cycle of a substance
17
W k
Workers
rights
i ht concering
i eSDS
SDS
• Workers (Reps) have the right to examine if the intended uses are
covered by the Exposure Scenarios set out in Safety Data Sheet (SDSs)
• Workers (Reps) can check if employers apply the Risk Management
Measures provided for in Safety Data Sheets
• Workers (Reps) can challenge proposed Risk Management Measures if
they do not think that they are adequate enough
18
Employers tasks (and Occupational Hygienist
t help)
to
h l )
• Make sure the instructions in the SDS on safe use of chemical substances are
implemented
p
and followed.
• If the eSDS contains an Exposure Scenario of a relevant use: make sure the
Risk Management Measures are implemented.
• If the relevant use of the substance is NOT described as one of the identified
uses in the eSDS:
• Inform the manufacturer/importer of the substance on this particularly use OR
• Create your own CSR on the particularly use and register this use with ECHA (if the
use is > 1 tpa)
• Search suppliers how did describe the relevant use
• Change how the substance is used.
• If the description
p
of a relevant use is different from the own use:
• Create your own CSR on the particularly use and register this use with ECHA (if the
use is > 1 tpa)
• It might be possible to use “scaling” (in ES duration is 4 hours, in real duration is 8
hours) Æ ECHA guidance available
available.
19
M
More
information
i f
ti
http://www.rijksoverheid.nl/docu
menten-enpublicaties/brochures/2012/01/18
/reach-informatie-ten-behoevevan-het-arbobeleid-inbedrijven.html
20

How to read an eSDS? Yvonne Jansma NVvA – January 26th, 2012

Transcription

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