Introduction

Majority of substances in the table have been used as ingredients for pesticides or cosmetics. Can it be that due to more strict legislation in this area more knowledge on properties of ingredients of pesticides and cosmetics is accumulated? Does it mean that registration of all chemical substances placed on the market above 1 t/a could bring even more carcinogens?

In future the REACH foresees restrictions for use of substances classified as Carc.1 (known or presumed as carcinogen for humans) introducing authorization procedure for substances of very high concern (SVHC). In the EU CLP/GHS database there are 905 entries corresponding to Carc.1.

Carc.2 (suspected as carcinogen for humans, 165 entries in EU CLP/GHS data base) are not included in SVHC process. According to the current speed of development of the candidate list (31 carcinogens included till 01.05.2011), it will take more than 50 years, until all corresponding substances from the current list will path through the SVHC process.

No regular testing for 261 substances is feasible – other information sources shall be used: safety data sheets shall be forwarded downstream, if substance or mixture is

dangerous, or mixture contains substance dangerous for human health and environment 1% or more (exemption for polymers), or SVHC is contained more than 0,1%,

no obligation for article producers to inform about substances in articles more than 0,1% until not included in SVHC e.g. material declarations are voluntary.

 The new Toys directive [2009/48/EC], Cosmetics directive [76/768/EEC], EU Ecolabelling criteria include also Carc.2 what is not addressed by SVHC (thus: no information requirement downstream on articles even in future).  Characterization factors of two investigated life cycle impact assessment methods include only part of the substances investigated i.e. they can not be exclusive supporting tool for assessing the toxicological impacts in the life cycle.

Chemical risk communication from the ecodesign perspective: legislative preconditions and needs for more information

than required by lawJ.Simanovska, K. Valters, G. Bažbauers

Riga Technical University, Institute of Energy Systems and Environmentjana.simanovska@rtu.lv

This work has been supported by the European Social Fund within the project „Support for the implementation of doctoral studies at Riga Technical University”. Sole responsibility of the concept of this information lies with the authors and EC is not responsible for any use that may be made of the information contained therein.

Ecodesign is a systematic approach in product design to reduce environmental impacts in the whole life cycle of the product. The chemicals legislation of the EU is seen as one of the most advanced in the world regarding protection of human health and environment. REACH – Regulation concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals enhances risk communication on the supply chain and makes the ground for generation of chemicals safety information: feeds the information needed for communicating chemicals’ risks down the supply stream including classification, labeling, safety data sheets according to GHS (Globally Harmonized System of Chemicals). The main responsibility about chemicals’ safety is placed on the producer of the chemical; a downstream user is obliged to implement the indicated risk reduction measures and to report on new risks up-stream. The most dangerous chemicals are restricted and banned in a transparent and systematic way. Are the risk assessment and prevention measures upstream sufficient? Is there still a need for ecodesign to consider chemical risks of non-chemical products more than law requires for better protection of the environment and human health?

To identify undesired substances risk communication via safety data sheets and material declarations using GHS classification can be the main tool. The material declarations for substances in articles is a voluntary response, exempting for SVHC (substance of very high concern): supplier has to inform on request of customer if content of SVHC exceeds 0,1%.

Incorporation of a provision in the legislation to inform customers on their request if articles contain >0,1% substances meeting SVHC criteria (even not included in the candidates yet), and also CMR (carcinogen, mutagen, reprotoxic) category 2 would support implementation of the new Toys directive, as well as meeting of ecolabelling criteria.

For future development of characterization factors under life cycle impact assessment methods the chronic health effects (e.g. CMR, endocrine disruptors) and chronic aquatic toxicity could be helpful.

The REACH process is slow, authorization procedure does not include carcinogens category 2: it can be recommended for eco-designer to do more already now!

Method

Results and discussion

REACH regulation 1907/2006 Candidate List of Substances of Very High Concern for Authorisation:

http://echa.europa.eu/chem_data/authorisation_process/candidate_list_en.asp ESIS CLP/GHS: http://ecb.jrc.ec.europa.eu/esis/index.php?PGM=cla CosIng - http://ec.europa.eu/consumers/cosmetics/ cosing/ USEtoxTM model and characterization factors, www.usetox.org Ecoindicators 99 characterisation factors in SimaPro 7.2. data base

An imaginary eco-design task was defined: to avoid in chemicals and articles all substances that have both types of hazardous properties: carcinogen and chronic aquatic toxicity. Screening of EU CLP/GHS database revealed 261 entries with substances classified as carcinogen (Carc.1: H350, Carc.2: H351) and chronic toxic for the aquatic organisms (Aquatic Chronic 1,2,3,4: H410, H411, H412, H413). For further analysis every tenth was picked up (26 entries in total → see the table). The information availability on life cycle impacts (e.g. characterisation factors of undesired substances in the USEtox and Ecoindicators 99) and legislative support to identify and phase out such substances was explored. Cosmetics data base (CosIng) and simple internet search was used to find out whether selected substances have any records as pesticides or cosmetic ingredients.

Table: Information on 26 substances with carcinogen and aquatic chronic toxic properties

Conclusions

References

International Chemical Identification

CAS No Characterisation factors for carcinogen, ecotoxic effects

Any records as pesticide (via Google) or cosmetics (CosIng)

Ecoindi-cators 99

USEtox

beryllium compounds - no no pesticide, cosmetics

O-hexyl-N-ethoxy-carbonylthiocarbamate

- no no cosmetics

tris(2-chloroethyl)phosphate 115-96-8 no no cosmetics 

strontium chromate 7789-06-2 no no  

nickel powder; [particle diameter < 1 mm]

7440-02-0 yes no cosmetics

nickel dinitrate; nitric acid, nickel salt

13138-45-9;14216-75-2

other compound

no

nickel dibenzoate 553-71-9 other compound

no  

nickel dicyanide 557-19-7 other compound

no  

nickel dichromate 15586-38-6 other compound

no  

diarsenic trioxide; arsenic trioxide 1327-53-3 other compound

other compound

pesticide

cadmium sulphate 10124-36-4 other compound

other compound

pesticide

isoprene (stabilised) 78-79-5 no canc, no ecotox

yes pesticide

triethyl arsenate 15606-95-8 no other compound

pesticide

camphechlor (ISO); toxaphene 8001-35-2 no yes pesticide

dodecachloropentacyclodecane; mirex 2385-85-5 no yes pesticide, cosmetics

2,3 epoxypropyltrimethyl-ammonium chloride ..%

3033-77-0 no ecotox, no cancer

agent (cosmetics industry)

chlozolinate (ISO) 84332-86-5 no no pesticide

2,4-dinitrotoluene; dinitrotoluene 121-14-2; 25321-14-6

no cancer, no ecotox

cosmetics

2,2-dibromo-2-nitroethanol 69094-18-4 no no pesticide

methylenebis ... dihydrochloride* 118658-99-4

no no cosmetics

salts of benzidine 531-85-1 u.a.

no cancer, no ecotox

cosmetics

1,5-naphthylenediamine 2243-62-1 no yes  

o-phenylenediamine 95-54-5 no cancer, no ecotox

pesticide

C.I. Basic Violet 3 548-62-9 no yes In pesticide products

propazine (ISO) 139-40-2 no yes pesticide

iprodione (ISO) 36734-19-7 no yes pesticide

*(methylenebis(4,1-phenylenazo(1-(3-(dimethylamino)propyl)-1,2-dihydro-6-hydroxy-4-methyl-2-oxopyridine-5,3-diyl)))-1,1'-dipyridinium dichloride dihydrochloride Carc.2

Carc.1A, Carc.1B Carc.1A, Carc.1B & SVHC candidate