Analysis of the efficiency of risk management measures in the exposure assessment under REACH - are the sector specific, non-substance related risk management measures appropriate or do they lead to underestimation of environmental risks? (FKZ: 3711 63 419)
German Federal Environment Agency, Dessau (DE)
Ökopol GmbH, Hamburg (DE)
2011 – 2015
Background and tasks
Substance manufacturers and importers identify the safe operational conditions (OCs) and risk management measures (RMMs) in the chemical safety assessment and communicate them along the supply chain with the safety data sheet.
Formulators develop respective information for mixtures based on the information they obtain. Frequently they have better knowledge of the actual practice at the end users’ than the manufacturers and importers, including the used risk management measures. They should develop concise and practical advice for the safe use to their customers.
RMMs can be divided into three distinct steps, which don’t necessarily are physically separated in the existing installations and devices:
- Capturing emissions (e.g. exhaust ventilation)
- Pre-treatment of emissions (e.g. concentration, separation) and
- Final treatment (e.g. incineration, landfilling)
The efficiency of each step may differ significantly depending on the type of treated substance, the composition of the mixtures or the physical-chemical properties of the emission. In addition, the efficiency of measures for capturing and pre-treatment of emissions may be different across sectors and used processes.
Manufactures, importers and formulators need support to develop useful information for their customers with regard to the selection of RMMs and estimation of their efficiency under realistic use conditions, which is currently not available in the ECHA guidance documents.
The aim of the project was to develop a concept for a support instrument for manufacturers, importers and particularly formulators to facilitate the selection of RMMs, including realistic assumptions on their emission reduction efficiency. The substance specificity and factors potentially disturbing the regular functioning of measures should be identified and described.
Results of the project are:
- Guidance for the modular description of RMMs, including a method for the derivation of the efficiency, assuming treatment of isolated substances and optimal conditions for the RMM functioning
- Examples for describing RMMs in 3 sectors (textile, electroplating and paints)
- Final report including suggestions for sharing responsibilities on the derivation of RMM efficacies and recommendations to the REACH actors