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What changes will the industry notice? Changes to a substance’s hazard classification mean that the hazard labelling used on a product must be changed. The reclassification of our fluxes for the purposes of labelling and supply is already underway and where the rules are clearly defined, the labelling of our fluxes will change accordingly. Similarly Safety Data Sheets will be amended to reflect the new classifications. It should be noted that a classification for labelling and supply may not be the same as for transport, where different rules apply. For transport classifications reference should be made to Section 14 of the product’s Safety Data Sheet. For reaction type fluxes the classification situation
as a reproductive toxin. The fact that sodium tetraborate has been classified and included on the list unlike potassium tetraborate does not make sense. Although there are boric acid-free fluxes, most
contain some form of soluble borates, for example potassium tetraborate, and are likely to be classified in the same way at some point in the future. Most brazing fluxes are straightforward mixtures of a number of different substances and their classification for the purposes of labelling and supply is determined by the percentages of each substance and their individual hazards. If a flux contains ≥ 5.5% boric acid it has to be labelled as toxic and use the risk phrases R60 (may impair fertility) and R61 (may cause harm to the unborn child). Some types of flux, such as Johnson Matthey Metal Joining’s Easy-flo™ Flux Powder, use boric acid as a starting ingredient, which during manufacture undergoes a series of chemical reactions with the other ingredients used in the formulation of the product. The reactions that take place result in the formation of new substances, one of which has not been identified. The formation of these ‘new’ substances must be registered under REACH and the cost of doing so will run into six figure sums.
Easy Flo Flux Powder from Johnson Matthey
is currently unclear and clarity on this point is unlikely to be achieved before June 2013, and may not be obtained before 2018. It is important to understand that there are no foreseen issues with the future supply of brazing fluxes. The EU undertakes impact studies when looking to legislate against any substance and they are unlikely to impose legislation, which would put the EU at a technical and financial disadvantage against the rest of the world, unless the hazard is such that a ban or restriction on its use is warranted. See
www.jm-metaljoining.com for more information. ■
Following the completion of this article, we need to report that the Polish Bureau for Chemical Substances have submitted a dossier to the European Chemicals Agency (ECHA) proposing that boric acid is reclassified as a reproductive toxin category 2, a lesser classification than it has at present. Should ECHA agree to reclassification this would mean that the boric acid would no longer meet the requirements for a Substance of Very High Concern (SVHC). The submission is also likely to impact upon the other borate substances currently listed as SVHCs
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