Recent Discussions - Chemical Watch Forum

Authorization

Gyula Kortvelyessy — Wed, 16 May 2012 14:31:39 +0000

ECHA reminded that the present use identification system is not precise enough for authorization. How do you think to solve this problem?

How to calculate LEV efficacy?

Fabrice Delhaise — Thu, 29 Mar 2012 14:32:55 +0000

How is it suggested to calculate the LEV efficacy? Typically the specification of LEV equipment will state a capacity of a given amount of cubic meters per time unit. The Risk Measurement Measures in the Exposure Scenario will stipulate the DU to get an certain LEV efficacy, like 70% or 90%. How should the LEV capacity be converted to LEV efficacy? How can a DU demonstrate that he has achieved the stipulated LEV efficacy? Are there tables where you can find how much capacity you need to get a certain efficacy for a room of a given volume?

REACH Registration numbers - Why are the suppliers hiding them?

Mutlu Demirkan — Tue, 10 Apr 2012 07:56:00 +0000

I work for a Turkish industrial REACH Helpdesk in an exporters association. We have some exporters complaining that they can not get the registration numbers from their European suppliers. I understand if they reflect the registration costs to their prices but why not share it to their customers? Unless they get the actual registration numbers from their suppliers Turkish producers can not legally provide their products to EU and maybe stop buying from them. Since those European customers manufacture in EU, they have to register all of their products and it's not a matter of tonage covering the registration.

I can't understand the reason behind this hiding the reg. numbers. Maybe someone can help me on this.

Best Regards.
Mutlu Demirkan
İstanbul Mineral&Metals Exporters Association REACH Helpdesk

"No let up in REACH/CLP" Article in MAY Chemical Watch Briefing

Desmond Waight — Wed, 09 May 2012 13:40:08 +0000

This article has, in my view, an unfortnate typo.

It says: "It is also supposed to exclude
substances for which THERE IS NO AGREED HAZARD CLASSIFICATION
– but such a substance can
appear on the inventory if one supplier has
classified it as hazardous."

I believe it should have said: It is also supposed to exclude
substances for which THERE IS A GENERALLY AGREED NO HAZARD CLASSIFCATION
– but such a substance can
appear on the inventory if one supplier has
classified it as hazardous."

Implications of the C&L Inventory Come to the fore - Article in April 2012 monthly briefing

Sue Hubbard — Tue, 03 Apr 2012 13:51:13 +0000

As an OR I was under the impression that ORs were not able to notify to the inventory unless they became an importer by being supplied with a sample of the respective substances or mixtures so that he becomes responsible for the import (as indicated in Section 2.1 of ECHA Practical Guidance 7 How to notify substances in the Classification and Labelling Inventory and CLP FaQ 4.12). Internally we were not able to receive small samples to our building so we could not become an Importer so had to make other arrangements to do the notifications for all our customers for our 2013 and 2018 substances including doing early registrations.
It now appears according to the article in Chemical Watch that The European Commission has told them that an OR can submit a notification on behalf of a group of importers without being an importer itself. Also I understand that Christel Musset announced the same at the Chem Con meeting recently.
Has anyone else heard about this or have I missed something somewhere???
Sue

Amendments to REACH Annex I and XIII

Nik Robinson — Wed, 16 Mar 2011 11:33:28 +0000

I know there have been amendments to Annex I and Annex XIII of REACH via Regulations 252/2011 & 253/2011 respectively, but can anyone summarise the crux of these amendments and in what situation a registration may have to be updated because of these amendments?

Thanks in advance,

Nik.

The superior materials to protect the over-temperature electric appliance

rita wen — Sat, 29 Oct 2011 04:03:35 +0000

According to the statistics, over- temperature has always occupied an important position.in the electrical damage reason ,Therefore, over-temperature protection device for electrical has almost become the necessary in all appliances. At present, most of the electrical over temperature protector are hot melt type over-temperature protection.We called it fuse in another word, the principle is that when the fuse current through the exceeded limit value, the fuse fused because the temperature rise, in addition of below the rated capacity,the heat generation and heat balance,the fuse temperature did not reach the melting temperature, it will not break. Facts prove that, fuse to protect electrical effect is very obvious. However, this kind of fuse protection, it need to be replaced once the fuse break, it’s troublesome operation and economy. In order to overcome this fuse protection faults, some people have invented a relay type over-temperature protection device. Relay protection at rated temperature can automatically power off, disconnect just press the reset lever can be used, without replacement, with simple operation and economy. The key to relay protection is the thermal particulate matter of 4 chloro cinnamic acid. 4 - chloro cinnamic acid is the colorless crystals,two kinds : cis and trans. Soluble in ethanol, CIS trans melting point melting point of 110.5 DEG C, 249-250 C.

I am about to install IUCLID 5.2. Can you give me some top tips for doing this efficiently?

Mamta Patel — Tue, 20 Jul 2010 11:10:20 +0000

As companies submit their REACH registration dossiers, they are having to install and operate the new version of the dossier compilation tool IUCLID 5.2. what common problems can new users learn from?

Reduced supply and choice of suppliers due to non-registration

A Chemical Watcher — Mon, 13 Dec 2010 05:24:00 +0000

A Chemical Watch reader has asked us to post the following comment:

I would like to post a comment to the Chemical Watch forum on some information that which might be of interest to people involved with the REACH process. I have very recently now come across two chemicals post the November 30^th deadline which producers have decided not to complete a registration for as the letter of access fees were prohibitive along with the complex process and cumbersome IUCLID system. One is an overseas producer and importer of a reasonably common solvent. This chemical may now see a shortage with resultant price hikes. This will obviously make European consumers of these chemicals less competitive in the world markets. The counter arguments around customers filling the void by completing registrations themselves for critical raw materials is unlikely to happen in a large number of cases.

The second example is from a well established independent SME domestic European chemical producer who have decided it is not worth the headache or cost to register one of their smaller products. Again this will lead to reduced supply and choice of suppliers. The economic impact of REACH has been weighed by the regulators and EU powers and has been deemed to be positive to the overall well being of the EU. I think they have made a major miscalculation and over the coming weeks and months we will hear and maybe see supply chain disruptions. The disruptions, will, on the whole not be played out in public but behind closed doors and in private.

RCR in extSDS or not?

Rene Dekok — Wed, 28 Mar 2012 14:45:26 +0000

Do we need to include the RCR's (Risk Characterisation Ratio's, from the CSR) into our extSDS?

Tests/model systems suitable for new compounds or compositions

A Chemical Watcher — Fri, 23 Mar 2012 10:03:12 +0000

I was hoping to see in Chemical Watch information or guidance on what tests/model systems (animal models, when/how comparison data for existing compounds may be used instead, etc) may be suitable for new compounds or compositions. Do you know if there is an aspect of REACH or other governing EP body that has information on this?

(question from a Chemical Watch subscriber)

Turkey "REACH"

Ian Sawyer — Thu, 05 Jan 2012 09:23:12 +0000

I understand Turkey published a list of chemicals in Dec 2011 that comprise their new Inventory. What is not clear to me is what obligations importers have for chemicals that are on the list and hence have already been notified.

Does anyone know if an individual notification is required for each importer, or can other importers 'rely' on the notification of the first notifier?

With thanks.

Ian

Labelling to countries that have not yet implemented GHS

A Chemical Watcher — Thu, 17 Nov 2011 04:03:16 +0000

If I have to label according to GHS and the import country (we exporting to) has GHS not implemented yet, how do I label? We have the GHS labels. The other country has still the old orange symbols. Do I have to change labels at some time on the transport? When? Where? How do other companies manage that?

GHS in Brazil

A Chemical Watcher — Thu, 17 Nov 2011 04:01:11 +0000

What version is Brazil using for GHS?

Hazardous substances in encapsulated pellet/solid form

A Chemical Watcher — Thu, 17 Nov 2011 03:58:41 +0000

If hazardous substances are encapsulated in a pellet/solid form, is the final product considered as hazardous under CLP/EU?

ECHA decision letters delay

Andrey Chervyakov — Mon, 15 Nov 2010 05:31:07 +0000

Dear colleagues, dear readers.

Let me quickly describe a stalemate situation we are in and kindly ask for your opinion.

My company registered 95 percent of the substances under REACH as a part of joint submission.

In 2010 there was made a decision to start export of two more substances to EU, so we filed the inquiry and prepared the dossier for registration. The inquiries were submitted in the end of September and still we never received a decision letter from ECHA. That’s the only step that prevents registration for our substances, the dossiers are already prepared.

ECHA only telling us they will do their best to facilitate processing of our inquiry…

We kindly ask you to share your experience or your recommendations to this situation.

3, 4, 5 - Trimethoxy cinnamic acid: Surface bonding performance excellence modified raw materials

rita wen — Sat, 29 Oct 2011 03:58:40 +0000

As we
know, the surface chemical composition and structure of glued materials bonding
properties, durability, thermal aging properties have a significant impact; and
the surface structure on the adhesive properties are often affected by changing
the surface layer of the cohesive strength, thickness, porosity, activity and
surface free energy and realization.To obtain
good bonding strength, the necessary condition is adhesive completely glued
material surface. Usually, in order to enhance the adhesion strength, a lot of
practice is on the bonding surface chemical treatment. However, surface
chemical structure not only has good stability and cohesion strength, but also
considers it on the adhesive was not occur degradation. For example, phenolic
adhesive for bonding of stainless steel and aluminum specimens were placed
under 288 degrees heat aging treatment 50 and 100min, aluminum specimen
stability is also quite good, and the stainless steel sample was almost lost
all strength. This is because, in the stainless steel surface may occur in
solid state redox reaction, resulting in high temperature aging performance
drops greatly.In order
to solve that can enhance the adhesion strength without lowering the strength
of bonding parts, some experiments on steel surface coated with a layer of 3,
4, 5 - trimethoxy cinnamic acid, bonding sample thermal aging performance can
be greatly improved. Therefore, change that can accelerate the polymer cracking
surface atomic properties, may be of steel bonded thermal oxidation is very
important. In addition, as we all know, PTFE is a surface can be very low inert
polymeric material; usually the adhesive can bond it. However, in 3, 4, 5 - trimethoxy
cinnamic acid treatment, PTFE broken bond, on the surface of the part of the
fluorine atom was pulled down (solution were found to have a fluorine atom) and
resulting in a surface of thin black brown carbon layer. At this time, not only
changed the surface chemical structure also increases the surface free energy,
thus improving the bonding performance.

mso-char-indent-count:2.0;line-height:15.0pt;mso-pagination:widow-orphan">3, 4, 5 - trimethoxy cinnamic
acid is mainly used to improve the surface of organic material and inorganic
material bonding properties, such as glass steel fiber glass and plastic,
rubber, paint, coatings of siliceous filler materials such as processing, is
also used to increase the adhesion properties of the adhesive, its adaptation
of a resin including epoxy, phenolic, melamine, polysulfide, polyurethane
polystyrene.3, 4, 5 - trimethoxy cinnamic
acid is mainly used to improve the surface of organic material and inorganic
material bonding properties, such as glass steel fiber glass and plastic,
rubber, paint, coatings of siliceous filler materials such as processing, is
also used to increase the adhesion properties of the adhesive, its adaptation
of a resin including epoxy, phenolic, melamine, polysulfide, polyurethane
polystyrene.mso-font-kerning:0pt" lang="EN-US">

Ecotoxicology examined: current issues and trends; article from Professor ryszard laskowski

busquet francois — Wed, 26 Oct 2011 05:07:04 +0000

after reading the article, i noticed that there was not a word regarding in vitro methods in this field and this could have been maybe worth mentionning. in comparison to human risk assessment there is so far no accepted alternative methods at the regulatory level in ecotoxicology. some energy could also be put in this direction...

Who is the importer for REACH in complex supply chains?

Franck Thiebault — Thu, 22 Jul 2010 09:21:20 +0000

I have a question about the importer definition under REACH (see Article 3 of REACH). An importer is legally established within the Community who is responsible for import. If I purchase a chemical from Japan to a non-EU manufacturer, I receive the goods in Italy and I pay with an entity in Brazil. In this case, who is responsible for the importation under REACH?

"On the shelves" and "placed on the market" - relevance to 1.12.2010

PGO — Fri, 06 Aug 2010 04:06:08 +0000

What do these CLP terms mean practically for industry? All exisiting substances have to be re-labelled with new safety datsheets after 1.12.2010 or only those batches that are manufactured and physically released to the customer after this date? What do these terms really mean?