ERGTC Andreas Dodos, Chairman of the European REACH Grease Thickener Consortium


During a face to face meeting with European Chemical Agency (ECHA), the European REACH Grease Thickeners Consortium (ERGTC) proposed that they prepare sector specific guidance (SSG) on the handling of substances which are manufactured in situ in base oil. A first draft the SSG is expected soon and the ERGTC intend to discuss the SSG further with ECHA.


The ERGTC’s SSG aims to ensure a consistent approach to REACH registration is taken across the sector and discusses the following topics, applicable to grease thickeners but which may also be relevant for other types of substance: • The nature of grease thickeners and how they are almost exclusively manufactured and used within a grease base;


• Justification for why grease thickeners are registered as isolated substances;


• Information on chemical analysis and substance identity;


• Technical challenges for hazard testing;


• Bioavailability testing to reflect that most grease thickeners are not bioavailable as they are manufactured and used in a base oil matrix.


The bioavailability testing approach is based on a theory outlined in the OECD Emission scenario document on lubricants and lubricant additives (OECD 2004, Series on Emission Scenario Documents No. 10) that, in environmental media, additives (or, in the present case, grease thickeners) will remain within the grease base due to their partitioning properties. Therefore, there will be limited environmental or human health exposure because the substance is not bioavailable.


The ERGTC are conducting experimental testing to develop this hypothesis and to include information to support the REACH registration. The results


Figure 1. Update to poster presented at the 2017 SETAC in Brussels 16


LUBE MAGAZINE NO.142 DECEMBER 2017


from this testing will be used to support waiving certain testing and in the development of exposure scenarios. Further information on the ERGTC bioavailability testing can be found in the update to the poster presented at the 2017 SETAC in Brussels (see Figure 1). Please note that the poster has been adapted from that which was presented at SETAC as the ERGTC’s approach is currently being reviewed and updated in order to be adaptable to a larger subset of substances, not only grease thickeners. A similar approach to that proposed by the ERGTC is already followed by other groups outside the ERGTC, such as the Additives Technical Committee (ATC).


sector specific guidance


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