TALKING HEADS Continued from page 10
machine element, in most cases in a closed system under severe operating conditions. Additionally, their use is in most cases very limited to specific applications. A perfect example of this is Lithium 12-Hydroxystearate, the chemical used as the grease thickener in around 80% of all grease used globally for the last 60 years but has very limited uses outside this industry. This meant that, although there are vast publications on the performance of this chemical in grease applications with still numerous technical and scientific papers being written yearly, there was very little information on the chemical itself that could be used for purposes such as REACH. This is further underlined by the fact that a significant number of EU manufacturers or importers had difficulties in isolating and identifying their grease thickener substance when this was called upon as a “substance identity” prerequisite for REACH registration. Gaining knowledge on the chemical and preparing the REACH registration dossier enabled the non-hazardous nature of the above thickener to be recognised and substantiated. Since gaining this information significant steps have been made to introduce this thickener to incidental food contact greases, where it has in the past been excluded, due to the lack of scientific data and the perception that it could have harmful effects.
Another advantage of REACH is the integration with other regulatory frameworks. These could be chemical safety frameworks (such as Turkey REACH, Korea REACH, the Chinese chemicals regulations, TSCA in the US and many other registry schemes) and other potential regulations, that are seemingly unconnected, such as the FDA rules on food safe substances. EU manufactures or importers are in this sense much better prepared to deal with such regulations, as REACH was a pioneer in significantly extending the information required to assess and ensure the safe use of chemicals.
The phase-in provision of REACH (i.e. the stepwise registration of chemicals based on their tonnage band and chemical impact over an 8 year period) has helped minimise the effects of supply chain disruption, as the lubricants industry is in most cases the user of chemicals rather than the producer of such (possibly with the exception of lubricating grease and metalworking fluids). Lubricant formulators have therefore had time to substitute chemicals where the risk associated with their use was a concern and/or
12 LUBE MAGAZINE NO.144 APRIL 2018
the cost of complying with the regulation reduced the number of chemical suppliers, thereby minimising the disruption to production and performance of their formulated lubricant products.
Utilising the spirit of the REACH legislations to minimise testing on vertebrate animals and to jointly develop the datasets required for substance registrations, the lubricants industry has gathered in pan European consortia to generate the information and resolve problems they faced during the registration process. Such consortia include CONCAWE, ATIEL, ATC, FATAC, ERGTC as well as others all of whom are working on their specific chemicals that in combination form a functional lubricant. The development of data sets (particularly (eco)toxicity data) within consortia helped constrain costs on a European level. Furthermore, this allowed for smaller players (so called small to medium sized enterprises (SMEs)) to participate and contribute their fair share in the decision-making throughout the process whilst remaining competitive, maintaining compliance and able to continue to operate alongside the majors.
Overall, REACH has been a steep learning curve for everybody involved: the regulators from the ECHA to the local authorities, the chemical industry from senior management to laboratory assistants, the contract laboratories and the consultants. No matter which position one has had in the process, this was a unique experience. Now, with only a few months left to go until the 2018 deadlines, most parties agree that although it has not been a smooth ride, it has been an honourable process with majors and SMEs working together in the spirit of REACH towards a common goal. Along the way we have gained knowledge and formulated approaches to meet the challenges posed by REACH for complex substances like grease thickeners and demonstrated we understand the human health as well as environmental hazards and risks posed by our products. The regulators in turn have gained an insight of the chemicals industry and the purpose it serves within the European economy. So, with a few unexpected surprises and without significant upsets to the operations of our business sector, the European lubricants industry is ready to face the new challenges the future will bring.
LINK
www.eldons.gr
Page 1 |
Page 2 |
Page 3 |
Page 4 |
Page 5 |
Page 6 |
Page 7 |
Page 8 |
Page 9 |
Page 10 |
Page 11 |
Page 12 |
Page 13 |
Page 14 |
Page 15 |
Page 16 |
Page 17 |
Page 18 |
Page 19 |
Page 20 |
Page 21 |
Page 22 |
Page 23 |
Page 24 |
Page 25 |
Page 26 |
Page 27 |
Page 28 |
Page 29 |
Page 30 |
Page 31 |
Page 32 |
Page 33 |
Page 34 |
Page 35 |
Page 36 |
Page 37 |
Page 38 |
Page 39 |
Page 40 |
Page 41 |
Page 42 |
Page 43 |
Page 44 |
Page 45 |
Page 46 |
Page 47 |
Page 48 |
Page 49 |
Page 50 |
Page 51 |
Page 52 |
Page 53 |
Page 54 |
Page 55 |
Page 56 |
Page 57 |
Page 58 |
Page 59 |
Page 60 |
Page 61 |
Page 62 |
Page 63 |
Page 64 |
Page 65 |
Page 66 |
Page 67 |
Page 68
