ATIEL, the technical association of the European lubricants industry, and ATC, the Technical Committee of Petroleum Additive Manufacturers in Europe, have jointly developed and published online a series of Generic Exposure Scenarios (GES) to assist companies in the lubricants supply chain with meeting the requirements of the European Union’s REACH chemicals regulation.
The development of the GES has been a major cross-industry effort, led and coordinated by an ATIEL/ATC working group on behalf of the lubricants, metal working fluids, greases and lubricant additives sectors. The availability of the GES is expected to significantly reduce the complexity and workload for lubricants industry players to comply with REACH* (Registration, Evaluation and Authorisation of Chemicals).
“The objective of the GES is to provide companies in all parts of the lubricants supply chain with a set of standardised exposure scenarios covering most lubricants uses, using familiar terminology and formats, they can use to meet their legal obligation to communicate information and guidance on the safe use of classified lubricant products,” says Howard Hayes (right), chairman of the ATIEL REACH working group.
“Because of the complexity of lubricant formulations, which may contain up to 20 different chemical components, taking a generic approach to the communication of safe use for ‘mixtures’ was the most practical way to promote consistent and widespread compliance with REACH across the lubricants sector and so ensure the continued availability of products.”
By consolidating all relevant exposure scenario information about classified (i.e. hazardous) constituent substances into one GES that reflects the whole mixture, the ATIEL/ATC approach allows safe use information to be passed up and down the supply chain in a consistent and efficient way.
The incorporation of a mixture GES into an extended Safety Data Sheet (ext-SDS) enables lubricant formulators to discharge their legal obligation under REACH and makes the information easily accessible to the customer/supplier in a familiar format. It also minimises the need for the mixture GES to change every time a new component substance exposure scenario is received by a formulator, thereby avoiding repeated updates of ext-SDS.
This approach has been recognised by the European Chemicals Agency (ECHA), which administers REACH, and has been shared widely with other industry sector groups and Member State representatives via the ECHA-sponsored European Network on Exposure Scenarios.
The development of the GES, which took almost three years, involved unprecedented engagement with companies up and down the lubricants supply chain, from raw material suppliers and formulators through to end-users. “This extensive consultation has been necessary to accumulate and validate the significant amount of data required to develop scientifically robust exposure scenarios,” says Hayes.
“As a result, the scope of the GES, which have been based on typical hazard classifications and components concentrations, should be sufficient to cover most of the known lubricant applications and end-uses.”
The ATIEL/ATC REACH working group conducted a series of confidential industry surveys to gather real-life data rather than relying on theoretical calculations. These surveys collated information on, among other things, the different lubricant applications in the market, the known hazardous components used in lubricant formulations, and the abatement measures employed to control environmental exposure.
One of the major outputs of this work was the consolidation of over 200 different lubricant applications into six categories or Use Groups, classed A to F. Components with common hazard profiles were mapped against the Use Groups to ensure the majority of combinations of hazards and applications were covered. Data from a survey of real-life environmental abatement techniques also allowed the inclusion of realistic environmental exposure calculations in the GES.
“The simplification of physical uses, grouping of components with common hazard profiles and the common language and terminology used in the ATIEL/ATC GES will facilitate clear and consistent communication with downstream users and/or upstream suppliers,” says Hayes. “It will help to ensure these companies receive safe use information for classified lubricant products in a format and using a set of terms they are already familiar with.”
For more information and to download the ATIEL/ATC GES please visit the REACH section of the ATIEL website at: www.atiel.org/reach/introduction
*Note for editors:
The European Union’s REACH regulation requires manufacturers and importers of chemical-based products, such as lubricants, to register the component substances with the European Chemicals Agency. Each registration must include a full toxicological assessment of the hazards and risks to human health and the environment, along with guidance on how they can be controlled or mitigated. Exposure scenarios describe the specific safe use conditions under which human health or the environment may be exposed to hazardous substances contained within a mixture such as a lubricant. Theycover the manufacturing process (if produced in the EU), each supported (identified) use, and must be communicated across the supply chain.