RIP 3'22 Industry testing of the draft cTGD

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RIP 3.2-2 Industry testing of the draft cTGD

• Use Identification, Chemical Safety Assessment
  and Exposure Scenarios for Arcosolv PM (PGME)

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Key messages

• Sense and Simplicity Simplify
• Exposure Scenario title (Use Descriptor)
• End Use communication (ES modifier)
• Exposure Scenario (Operational Conditions RMM)
• In such a way that it makes (more) Sense to the
  (end) users
• Highlight the need for having simple, flexible
  but not overly conservative TIER-1 models for CSA

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This presentation

• Approach
• Use identification simplify the ES title
• Communication downstream (simplify DU comm.)
• Exposure Scenario example (simplify ES)
• Cross model comparison (flexible and not to
  conservative models needed)
• Key experiences and conclusions

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RIP 3.2-2 Industry testing of cTGD Lyondell case

• Joint project by
• Lyondell (CSA), TNO Quality of Life (ES model
  comparison) FDLF (ES-modifier), Brenntag DU
  communication.
• Focused on uses of Arcosolv PM (PGME)
• A. Formulation of products (including loading)
• B. Use of PGME in paints (consumer brush
  application of paint indoor, professional spray
  application, outdoor and indoor.
• Process
• Draft RAR/EU RAR and decorative paint ES as main
  sources
• Cross model comparison for calculations in the
  CSA
• The relevant DNELs were derived from INRS RAR
• FDLF developed an ES modifyer (EUSES,
  Stoffenmanager)
• Tentative ES where shared with selected customers
  for feedback

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Arcosolv PM

• Low volatile glycol ether
• Variety of uses and applications paints,
  detergent, inks
• Vapour pressure 1640 Pa
• Current classification R10

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Simplify the ES title

• Abstract terminology
• Consumer brush application of paint containing
  PGME, indoor
• ARCOSOLV PM IS USED IN the PUBLIC DOMAIN (G
  46.75 Wholesale of chemical products) and IN the
  construction industry (NACE F) and IN activities
  of households as private persons (NACE T) AS
  Solvent BY Low energy spreading and BY Air
  dispersive techniques
• Professional spraying of paints containing PGME,
  outdoors
• PGME used in the construction industry (NACE F)
  AS solvent in Coatings and Paints, Fillers,
  Putties, Thinners BY air dispersive techniques
  outdoors.
• The technical function least relevance (at least
  for workers exposures)
• Limited use to evaluate exposures and limited
  added value for communication purposes and its
  often considered Confidential Business
  Information (Brenntag)
• Simplify descriptor Technical Function into
  consumers, professional, industrial use
• Change back to IC/UC codes for environmental risk
  assessment

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Simplify the use descriptor
Key experience and conclusions (including the
proposal to use TRA as starting point in exposure
assessment, and complement with Stoffenmanager
and/or RISKOFDERM when needed)
                                                  
                                                  
                                                  
                                                  
              
One exposure scenario Formulation of products
with max. 5 Arcosolv PM
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Simplify the DU communication The ES modifier
concept (CEPE/FDLF proposal)
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Multiplication
M/I
Tentative ES
FINAL ES
Iterations
Generic ES
ES Calculator
CBI Overflow
DU
100s substances
More information? Breakout session!
1000s preparations
Present TGD
Real life
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Simplify the DU communication The ES modifier
example more in breakout!

• g ES Spray application of (decorative) paint,
  indoor
• Use conditions relevant to worker exposure
• Solvent based paint (20 40 PGME) vs 5
• Indoor but now in ballast tank at ships, PPE used
  
• Environmental Risk Assessment
• Concentration solvent in product
• Production volumes
• Use (categories)

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Simplify Communication FDLF experiences with ES
modifier

• The ES probably cannot be understood by customers
  further down the supply chain (A professional
  painter would not be able to get the right
  information from the present ES - it is too
  complicated).
• The example ES do not sufficiently cover all
  actual uses required by the downstream users.
  There are several sets of operational conditions,
  which lie outside the boundaries for the specific
  ES
• The DU clearly saw the potential of the
  ES-modifier to make their communication much
  easier.

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Simplify the ES

• Format used as described in draft cTGD works
  however
• Difficult to automate (SAP MSDS output) as
  specific outcomes of exposure assessent are
  included?
• Msafe and ASafe where not used.
• Focus on Operational Conditions RMM.

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Flexible but not overly conservative models needed
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Cross model comparison input parameters

• ECETOC TRA
• Scenario (e.g. roller application/ brushing of
  surface coatings)
• Fugacity (three categories for VP)
• LEV (yes/no)
• Duration (four options)
• Stoffenmanager 3.5
• Partial vapor pressure VP divided by
  substance in preparation
• Type of activity (seven options)
• More than one source of exposure? (yes/no)
• Room size (four options)
• Mechanical/ natural ventilation (yes/no)
• Local control (four types of LEV combined with
  enclosure)
• Basic good occupational hygiene observed?
  (yes/no)

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Conclusions

• Simplify ES-titles understandable to DU (open
  text, Google)
• Simplify descriptor Technical Function into
  consumers, professional, industrial use
• Use IC/UC codes for environmental risk
  assessments (not in DU communication)?
• Simplify end use communication
• Allow DU to adjust ES to local conditions by
  using accepted exposure models (accepted by all
  stakeholders, at sector level).
• Explore the ES modifier.

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6. Key experiences and conclusions (2)

• Simplify ES
• Allow differentiation between ES in CSR and DU
  eSDS (include exposure assessment results out in
  CSR ES only)
• Limit DU ES to short title, conditions of use and
  RMM
• Standardize Exposure assessment
• Strive for broad industry consensus on the models
  used, develop gES at sector level

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Backup slides

• Stoffenmanager 3.5

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Stoffenmanager 3.5. Results regression
analysis (liquids)
gt 4000 measurements Correlation (rs)
0.81 Publication Oct 07
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Stoffenmanager 3.5Validity

Max