HSE Committee Working Group
UEIL HSE Committee Working Group Major changes of the European legislation are ahead. The HSE Committee has started several joined activities together with ATIEL and ATC. The UEIL, ATIEL and ATC have indeed co-signed position papers on Lithium salts re-classification to “CMR 1A” and the proposed “essential use” concept in REACH. In parallel, UEIL and ATIEL have also worked together on a joint position for the call for evidence on the introduction of new hazard classes in the CLP regulation. Other papers will follow. The strategy is to bundle our activities and present a united position throughout the lubricant industry, which will significantly increase our chances of being heard.
The REACH revision has been postponed to Q4 2023, perhaps due to the difficulties of definitions and the willingness by the European Commission to adopt new concepts such as “grouping” and “essential use”.
There are also new developments in the CLP regulation: new hazard classes, such as endocrine disruptors are being introduced unilaterally in Europe. Hence, non-ferrous metal passivators and antioxidants could be affected. Some metalworking fluid (MWF) manufacturers are concerned about the proposal to classify medium chain chlorinated paraffins (MCCP) as “substance of very high concern” (SVHC) with a subsequent restriction proposal. Moreover, this will also include “long chain” chlorinated paraffins, since they often contain traces of MCCP. The Committee is currently looking into this issue.
Classification, Labelling and Packaging (CLP) Regulation The Classification, Labelling and Packaging (CLP) Regulation ((EC) No 1272/2008) is based on the United Nations’ Globally Harmonised System (GHS) and its purpose is to ensure a high level of protection of health and the environment, as well as the free movement of substances, mixtures and articles. CLP sets detailed criteria for the labelling elements: pictograms, signal words and standard statements for hazard and prevention, for every hazard class and category. It requires manufacturers, importers and downstream users of substances or mixtures to classify, label and package their hazardous chemicals
appropriately before placing them on the market. It also sets general packaging standards to ensure the safe supply of hazardous substances and mixtures. CLP is legally binding across the Member States and directly applicable to all industrial sectors.
The European Commission proposed in September a draft act introducing new hazard classes as part of its revision which probably will come effective in 2023. Hazard classes and criteria are added for endocrine disruptors and substances that are persistent, bioaccumulative, and toxic (PBT), very persistent and very bioaccumulative (vPvB), persistent, mobile, and toxic (PMT), or very persistent and very mobile (vPvM). The inclusion of the new hazard classes is part of the Chemicals Strategy for Sustainability (CSS), and as a building block for the European Green Deal, and to ensure a high level of protection for human health and the environment.
With these new hazard classes, the whole on value chains relying on chemicals will be impacted. If your chemical falls within one of these new hazard classes, this could trigger restrictions and bans under the generic approach to risk management (GRA procedure in REACH). This is currently being applied to substances with CMR properties, and to the use by the consumer. Future intentions on the GRA procedure is to broaden the scope for use in the professional sector, and addition of the new hazard classes.
Manufacturers may also decide to suspend certain substances to avoid having a product labelled as hazardous. Several other general issues are also worrying such as alignment with UN GHS. This may jeopardise the free movement of substances, mixtures and articles. Not to mention the lack of clarity for these new hazard classes which will add layers of confusion to an already complex approach to hazard classification.
Technical & Competitions Committees The UEIL General Assembly which took place in Athens on 19 October 2022 was notably the opportunity to present the report of the Technical and Competition Committees.
LUBE MAGAZINE NO.172 DECEMBER 2022 39
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
