In 2023, Bureau REACH completed and submitted six Regulatory Management Option Analyses (RMOAs) to the European Chemicals Agency (ECHA). An RMOA is the first step to assess whether a risk-reducing measure is necessary and feasible. These six RMOAs are described below, along with an ongoing seventh RMOA concerning steel slag.
The completed and submitted RMOAs are:
1. Diacetyl
Further reading: https://echa.europa.eu/nl/assessment-regulatory-needs/-/dislist/details/0b0236e1821a6b4e
2. Prop-2-yn-1-ol
The industrial substance prop-2-yn-1-ol contains the harmful substance formaldehyde as an impurity in a concentration above 0.1%. Bureau REACH has prioritised formaldehyde to determine the best approach to address the issue of harmful impurities. Formaldehyde is classified as carcinogenic and may be identified as a Substance of Very High Concern (SVHC) for inclusion in the candidate list for authorisation.
Further readingk: https://echa.europa.eu/documents/10162/006f53c4-520c-b728-3359-03198e5df233
3. Artificial Stone
Artificial Stone (also known as engineered stone) arises from the New or Emerging Risks of Chemicals (NERC) due to observed occupational diseases. Workers involved in making or processing artificial stone countertops may inhale dust. Prolonged and frequent exposure can lead to irreversible lung damage. The current exposure limit may not provide adequate protection and is not achieved in all workplaces.
Further reading: https://echa.europa.eu/nl/assessment-regulatory-needs/-/dislist/details/0b0236e18801e16c
4. Beryllium oxide (BeO)
The Dutch Inspectorate for the Environment and Transport (ILT) identified the presence of beryllium oxide (BeO) in electronic waste processed or shredded at recycling companies. Beryllium is classified as Carc. 1B, but is not detected in workplace dust. Bureau REACH therefore sees no basis for further action at this time.
Further reading: https://echa.europa.eu/nl/assessment-regulatory-needs/-/dislist/details/0b0236e189cea089
5. Isothiazolinones
Isothiazolinones are a group of five chemical compounds derived from isothiazolone. They are commonly used as preservatives or antimicrobial agents. Due to their widespread use, an increasing number of people develop skin allergies. Bureau REACH conducted an analysis to determine the most appropriate control measures for this group of substances. Our current advice is to limit the total amount, taking into account the concentration of individual compounds or mixtures causing allergies. If this is not feasible, the alternative is to establish a concentration limit for each compound, combined with a ban on adding multiple isothiazolone compounds to one product.
Further reading: https://echa.europa.eu/nl/assessment-regulatory-needs/-/dislist/details/0b0236e18948d7ba
6. 6PPD
Bureau REACH identified a concern for 6PPD, which is used in tyres to reduce wear. The conversion product of this substance, a quinone compound, is highly toxic to certain salmon species. Particles of tyre wear, containing this substance, can wash off roads into surrounding waters. We discussed our findings with the tyre industry and published them on the European Chemicals Agency (ECHA) website. In our Regulatory Management Option Analysis (RMOA), we propose a ban on 6PPD and related substances.
Further reading: https://echa.europa.eu/nl/assessment-regulatory-needs/-/dislist/details/0b0236e188811f2b
7. Steel slag
In 2023, we began screening steel slag. Steel slag consists mainly of calcium oxide and is highly alkaline and corrosive. There is no (self)classification of steel slag for corrosivity or irritation. However, health complaints have been reported by the Dutch Inspectorate for the Environment and Transport (ILT) and the media (Zembla). The affected individuals were exposed to dust from steel slag used in the environment as foundation material. This includes skin and eye irritation, respiratory irritation, nosebleeds, and even skin burns. The Chemical Safety Report (CSR) indicates that classification based solely on pH value is not an option due to the low buffer capacity of steel slag. Various in vitro, in vivo, and ex vivo tests for eye and skin irritation show no effects. Based on this, it seems justified that there is no classification for corrosion or irritation. However, it is concerning that bystanders experience such complaints. Bureau REACH discussed the initial findings and decided to proceed with an RMOA to determine appropriate follow-up action(s).