Denny,
I am going to correct my answer below. I am doing some work around the
prioritization for authorization, and have better information than
yesterday.
In the Authorization prioritization, the wide-dispersive use criteria
has two components: (1) number of sites where the substance is used, and
(2) the degree of control of exposure to the public and workers.
This appears to be a place where REACH links with worker exposure, but
it only occurs once you are at the prioritization stage for Annex XIV.
Sorry for the misinformation in my email yesterday.
Take care,
John Sharp | Corporate Product Compliance Manager | TriQuint
Semiconductor, Inc.
2300 NE Brookwood Parkway | Hillsboro, OR 97124 | *: 503-615-9712 |
Fax: 503-615-8902 | *: [log in to unmask]
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-----Original Message-----
From: Sharp, John
Sent: Wednesday, August 03, 2011 9:30 AM
To: Environmental Health and Safety Compliance
Subject: RE: [CN] EU linkage between REACh and Occupational Chemical
Exposure?
Denny,
I will give my opinion on the question, but others may be better
informed.
In short, I don't think there is any linkage. Chemical substances are
proposed for CLP Classification based on intrinsic health hazards. ECHA
continues to exist that risk assessment and exposure scenarios have no
place in CLP Classification.
For SVHC listing, again it is strictly intrinsic health hazards, and the
justification that the substance requires an EU Community-wide response.
For the Authorization listing, there are 3 criteria:
1. There needs to be a certain volume of the substance in the EU market
that is not exempted (although ECHA is very ingenious at getting around
this requirement).
2. The chemical substance needs to be in Wide-dispersive use, and
3. Intrinsic (or inherent) health hazard properties again.
At no point is worker exposure considered. Usually in the Annex XV
dossiers, there is an introductory section on industrial use, and how
many people are exposed. However, this is not considered in CLP
Classification, SVHC listing, or in Authorization listing. In fact, if
you bring up this type of data, ECHA will tell you that it doesn't
matter (as they did me, during the comment period for gallium arsenide
classification).
So there is no link that I can see in the processes of REACH. The only
possible link is that worker exposure might be one of the factors that
encourages a Member State Competent Authority (MSCA) to propose a
substance for classification or SVHC listing in the first place.
John Sharp | Corporate Product Compliance Manager | TriQuint
Semiconductor, Inc.
2300 NE Brookwood Parkway | Hillsboro, OR 97124 | *: 503-615-9712 |
Fax: 503-615-8902 | *: [log in to unmask]
***The information contained in this e-mail and any accompanying
attachment is confidential. If you are not the intended recipient or an
authorized agent of the intended recipient, and/or you have received
this e-mail through inadvertent error, then any disclosure,
dissemination, distribution, copying, further review or other use of the
contents of this e-mail and/or any attachment is prohibited. If you are
not the intended recipient or an authorized agent thereof, and/or you
have received this e-mail in error, please notify me immediately via
e-mail or by telephone at the phone number set forth above and destroy
this e-mail. Thank you.***
-----Original Message-----
From: ComplianceNet [mailto:[log in to unmask]] On Behalf Of Dennis
Fritz
Sent: Wednesday, August 03, 2011 9:16 AM
To: [log in to unmask]
Subject: [CN] EU linkage between REACh and Occupational Chemical
Exposure?
Can someone on this forum point out the linkage in Europe between REACh
regulations and worker occupational exposure?
I see that the EU has the European Agency for Safety and Health at Work.
That seem similar to NIOSH in the US, but what is the lnkage between
chemicals listed in REACh, and worker exposure in manufacture?
Denny Fritz
SAIC, Inc.
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