The role of the ATIEL Health Safey & Environment (HSE) Committee is to develop industry best practice around lubricant HSE and regulatory compliance and improve the communication of HSE information up and down the supply chain.
The HSE Committee monitors developments in regulatory frameworks and works in conjunction with other industry associations including ATC, the Technical Committee of Petroleum Additive Manufacturers in Europe, on issues of common interest.
A sub-group of the HSE Committee manages activities related to the European REACH regulation, including the production of Generic Exposure Scenarios (GES) which has helped to reduce the workload required to comply with the regulation for all industry players – for more information please see the REACH section of the website.
ATIEL is a member of DUCC, an active cross industry forum to exchange on REACH and CLP related matters.
The HSE Committee has also worked with ATC on developing guidance to improve the quality and efficiency of HSE information shared across lubricant supply chains.
This includes best practice recommendations for the preparation of Safety Data Sheets (SDS) for components or additives supplied to lubricant formulators, and a standardised Component Information Form (CIF) that makes it easier for suppliers to provide additional information that doesn’t typically appear in a component SDS but which is important for formulators and end users.
The SDS best practice recommendations address phrases and data formats in sections of a component SDS that commonly create issues for formulators in developing a finished lubricant SDS for passing down the supply chain.
They are designed to ensure that formulators receive a complete picture of the respective hazards of individual components via the SDS and so avoid the need for additional data requests.
The SDS guidance highlights where additional detail is required (or would be helpful) to develop a complete and comprehensive SDS, explains why this information is needed and provides recommendations for how to incorporate the information into the component SDS.
Component Information Form *New updated version*
The Component Information Form (CIF) is a standardised template that additive component or mixture suppliers can use to provide important information that may not normally form part of the SDS structure.
The information covered by the CIF is essential to enable formulators to develop detailed product composition data that complies with national product registration schemes, customs requirements and substance registration regulations such as REACH.
Capturing this information in a consistent and standardised format helps to ensure that finished lubricants supplied to customers have the correct classification and labelling and that all the HSE data needed to support the product in the market is available.
An updated version, V6.3, of the Component Information Form has been uploaded to the website and can be downloaded from the link below.
The new updated version omits the requirement to give the VOC content for US downstream users. The US legislation is very different from the EU and Swiss regulations and is, in any case, very low for lubricants.
ATIEL and ATC encourage all their members and other stakeholders to use the form to improve the consistency of information in the industry.
The SDS and CIF guidance is designed to ensure that everything needed for regulatory reporting requirements is passed from supplier to customer while also helping reduce the overall compliance workload for all industry stakeholders.