H

1
HSL Report to ATC Main Committee27th February
2007
Mick Wragg
2
HSL Project Plan 2007

• Preparation for REACH remains key industry
  activity
• 3 active projects
• GHS and PBTs are also considered medium priority
  but more of a surveillance activity during 2007
• Leaders have been identified
• Mainly internal company resources
• Life Cycle/Exposure Scenarios/Risk Assessment
  project may require funding for external
  consultant
• Restricted substance lists recognised as
  important to additive industry but no resources
  to do this at moment
• Synergy with PTS and others?
• Concern that no contribution was obtained from
  several companies including BASF, Uniquema/Croda,
  Chemtura, BakerPetrolite, and Rohmax.

3
Other HSL activities

• Document 49
• Other ATC documents under review
• Document 31
• Document 54
• Period of increased collaboration with ATIEL
• REACH project
• Document 31 (and archived Document 30)
• Restricted substance lists
• Discussion with PDC concerning desired web-site
  enhancements to increase HSL efficiency
• Shared storage space with upload facility
• E-conferences
• Paul Roberts (Innospec) elected as vice-chair

4
HSL successes

• Developed ATC Document 31 (Nomenclature)
• Widely used by industry and currently undergoing
  6th revision
• 2EHN Best Practices Manual for substances and
  mixtures
• provides a definitive review for the safe
  handling, storage and use of cetane improver and
  products containing this substance
• REACH position paper was published in 2004
  identifying several issues of greatest importance
  to additives industry
• Major success in persuading regulators to
  recognise importance of protecting product
  formulas information from public disclosure
• Risk assessment of lubricant additive chemistry
  by external consultants was commissioned by HSL
  and published in 1997
• Supported TAD by providing expertise in relation
  to draft Blue Angel Fuel Saving Ultra Light
  Running Oils for Cars
• Confidentiality concern about formulation
  disclosure accepted
• Scope limited to intentionally added ingredients
• De minimis level for intentionally added
  ingredients accepted
• Provided expert input to ATC Document 49 in 1993
  concerning legislative requirements and
  contributed to major update in 2007
• Zinc oxide risk assessment
• Worked with CEFIC and others to successfully
  avoid further restrictive measures in use of zinc
  chemistry in EU
• Danish fuel additives risk screen
• Worked collaboratively with external consultant
  to avoid damaging list of substances of concern
  from being published in Denmark

5
REACH project updates

• CBI
• Major success in establishing right to protect
  formulation information
• Completed (with possible opportunity to resurrect
  DPD anomaly due to GHS)
• Information in the supply chain
• Contact with CEFIC Standardisation
  Harmonisation WG continuing
• Chemical grouping
• Trial SIEF held 4Q06
• Some findings communicated to RIP 3.4 WG
• Awaiting follow up meeting of REACH WG to decide
  on next steps
• Life Cycle Analysis, Exposure Scenario and Risk
  Assessment
• Declined opportunity to contribute to RIP 3.2-2
  due to unrealistic deadlines and questionable
  direction
• Agreed further collaboration with ATIEL on
  identified uses and generic exposure scenarios
• Draft project plan submitted to ATIEL for
  approval
• Next meeting planned for 1st March