Cefic Cyanides Sector Group
Hydrocarbon Solvents Producers Assocation
Friday, 20 November 2009
Joint Feedback of the European Chemical Industry on the Universe of Chemicals (version October 2009) and on the Annex 1 – candidate list of substances – version 4
Cefic has distributed the information on the running prioritisation of substances and subsequent EQS setting through its network. Attached are the comments of Cefic sector groups and Cefic partners.
EDTA (CAS 60-00-4, EC 200-449-4)
The confederation of European paper industries (CEPI), the International Association for Soaps, Detergents and Maintenance Products (AISE) and the European AminoCarboxylates Cefic Sector Group (EAC) have commented that EDTA should not be selected as priority substances or priority hazardous substances. Reasons were explained in a position paper attached.
Background information on EDTA has been brought together in Factsheet template and this document is evenso attached.
CEPI, AISE and EAC noted differences between endpoints indicated in our EDTA WRRL fact sheet and the published EU RAR and between some end points (such as e.g. biodegradation and PNEC) presented in the excel sheet called the ‘Universe of Chemicals’. The information presented in the ‘Universe of Chemicals’ seems to be developed by using QSARs and EPIWIN type of programs in stead of actual test results. We feel that for EDTA the information from the enclosed EDTA WRRL fact sheet and the EU RAR should be used in the prioritization process in stead of the information presented in the ‘Universe of Chemicals’.
CEPI, AISE and EAC have no remarks on the EDTA information in the excel sheet called “Annex 1 – List of candidate substances: version 4”.
HHCB (CAS# 1222-05-5) and alpha-cedrene (CAS # 469-61-4)
The Research Institute for Fragrance Materials (RIFM) is providing the following information on certain chemicals identified in the Priority Substance Review. HHCB (CAS# 1222-05-5) and alpha-cedrene (CAS # 469-61-4) are ranked ‘high’ based on the modeling approach used by the JRC to help set these priorities.
In the Excel spreadsheet summarizing materials for Priority Substance Review, there appears to be some omissions for the fragrance materials HHCB (CAS# 1222-05-5) and alpha-cedrene (CAS # 469-61-4). Both these materials were assessed by the TC NES as potential PBTs and both were determined not to be PBT materials. The TC NES summaries are attached.
In addition, the European Chemicals Bureau has recently completed its risk assessment of HHCB (Risk Assessment Report attached). The risk quotients for all environmental compartments were found to be <1. The ECB has concluded for this material (p.vii):
Environment
Conclusion (ii) There is at present no need for further information and/or testing and no
need for risk reduction measures beyond those which are being applied
already.
Conclusion (ii) applies to all compartments and all scenarios.
Based on the information provided, RIFM believes it is appropriate to delete these materials from the Priority Substance Review.
As background information, following documents are attached:
· EU RAR for HHCB,
· PBT assessment HHCB,
· PBT assessment alpha cedrene.
Cyanides (CAS 57-12-5)
The Cyanides Sector group already replied after the WG-E meeting of 6 July 2009.
Supporting vigilance in monitoring for presence of cyanides in water and sediment systems, the Sector Group feels that monitoring efforts for cyanide are better and more efficiently served by concentrating on the detection of cyanide (metal) complexes in regions where these are most likely to be manufactured and thus emitted. We feel it is more appropriate to make a clear distinction between freely-soluble cyanides and cyanide complexes, so as to reflect their differing behaviors in the environment.
Therefore the Cyanides Sector Group proposes to alter the priority listing from the current generic description of the cyanide ion to make the distinction between free and complex cyanides. We believe that this will provide for a more realistic and focused monitoring programme for cyanides as they are likely to exist in natural water systems, and particularly in sediment systems.
The comments prepared by the Cyanides sector group, are inserted again for your convenience:
(Mono)chloro acetic acid (MCAA) (CAS 79-11-8)
This contribution regards the discussion around the reporting of monitoring data regarding selected substances, especially with regard to our product (mono)chloro acetic acid (MCAA, CAS number 79-11-8). We very much support the suggestion INERIS made to consider MCAA as candidate for de-selection , after it’s a posteriori check based on the review of EU representativeness and quality/reliability of monitoring data.
In the communication so far MCAA has been indicated as a substance with high final priority for Water resulting in a high overall priority as well. From the received reports it cannot be judged whether the monitoring data indeed reflect justifiably that MCAA should be proposed for the priority setting as indicated. It remains unclear whether and at what level MCAA is detected in any of the reported monitoring studies. Determining a classification on just its initial effect on organisms in lab studies seems disputable for such an important intermediate chemical. Although we know that MCAA is toxic in aquatic organisms we also know that the substance is readily biodegradable and that treatment in waste water treatment facilities as currently used at our facilities is most effective.
Monochloroacetic acid (MCAA) is a strong acid which is freely soluble in water. It is synthesised in a closed system, and produced either in molten form, as crystalline flakes, in solution (80%), or as the sodium salt (SMCA). MCAA and SMCA are used almost exclusively as intermediates for the synthesis of carboxymethylcellulose, herbicides, surfactants, thioglycolic acid and in other production processes where carboxymethylation is required.
Some release to the environmental compartments may occur during production, transport and downstream use. MCAA/SMCA is rapidly degraded in the atmosphere, although low concentrations of MCAA have been measured in areas remote from anthropogenic emissions (as exemplified by pre-industrial ice samples). This is thought to be due to natural occurrence in the environment. If released into soil MCAA/SMCA will initially partition into the aqueous phase. MCAA/SMCA exists in water in the ionised state as the monochloroacetate anion; its properties will therefore be those of the salt in solution.
Monochloroacetate is readily biodegradable. It is rapidly degraded aerobically and anaerobically in soil and in the aquatic environment and will not exist as such for more than a few days. Due to its low Koc MCAA will not absorb into sediment and the log Kow -3.47 indicates that bioaccumulation of SMCA in aquatic flora and fauna is unlikely to occur to any significant extent.
Tetradecane (CAS 629-59-4) and others
The Cefic sector group “Hydrocarbon Solvents Producers Association” (HSPA) investigated the Annex 1 – candidate list of substances as well as the Excel sheet “Universe of Chemicals”.
The Sector group estimates that the data used (e.g. data from IUCLID) and the modeling approaches taken (e.g. QSAR modeling to estimate PNEC for the case of tetradecane) can result in an overestimation of the risk. More precise data that are available with industry will be delivered to JRC in the near future.
This will be done in the format of the templates, agreed upon in the Expert Group on EQS, example started in file below.
Acetonitrile (CAS 75-05-8)
This substance is not (acute) toxic for the aquatic environment and it is fully biologically degradable and not bio-accumulating.
Metacrylic acid (CAS 79-11-8)
This substance is biologically degradable.
Ammonium Compounds (CAS 7664-41-7)
Although these substances are toxic for the aquatic environment, they are only acute toxic and both fully biologically degradable and not bio-accumulating.
Nitrite (CAS 79-11-8)
Although this substance is toxic for the aquatic environment, it is only acute toxic and both fully biologically degradable and not bio-accumulating.
For more information: please contact Ann Dierckx
091120 Cefic feedback on Annex 1 and Univers of chemicals 5/5