JEC COMPOSITES MAGAZINE - Issue #87 - March 2014 Special JEC Europe - 79

Tab. 1: EU GHS hazard classes & categories

Hazard class
Carcinogen
Mutagen
Reprotoxicant

Hazard categories 1A

Hazard categories 1B

Hazard categories 2

Known human cancerinogen Presumed human cancerinogen
Known human mutagen

Presumed human mutagen

Suspected human mutagen

Known human reprotoxicant Presumed human reprotoxicant

Comment

in different categories. This classification
is done by the lead registrant. In general,
suppliers need to decide on the classification of a substance or mixture. This is called
self-classification.
In some cases, the decision on the classification of a chemical is taken at European
Community level (RAC, Risk Assessment
Committee). It is mandatory for the suppliers of the respective substance or mixture
to apply this harmonised classification and
labelling. This process is often followed for
the most hazardous substances. These are
usually carcinogenic, mutagenic, reprotoxic
(CMR) or are respiratory sensitizers.
The EU hazard categories are listed in the
table 1.

Impact on business
While the classification of hazardous
substances may seem abstract and far away
from our daily lives, they can have major implications for business. Immediately, a classification change requires investigating the
use of alternative raw materials (see below
for detail). Also, this may influence existing
operating permits, often leading to a permit
renegotiation with local authorities, and a
potential modification of factory layout and
environmental protection systems.
Besides the introduction of personal protective equipment (affecting plant working
conditions), CMR classifications do carry
increased administrative obligations for
monitoring employee exposure. Overall,
this is a financial burden and will take
away focus from where it is needed most:
maintaining your business and keeping your
customers happy!
In Europe, the basis for the CMR classification has been defined in the Carcinogens &

Suspected human
cancerinogen
Suspected human
reprotoxicant
Effect visible in animal
toxicity testing but not
yet possible to translate
metabolism from animals
to humans

Mutagens Directive (Directive 2004/37/
EC), Chemical Agents Directive (Directive
98/24/EC), and National Acts on Working
Conditions. There are differences between
carcinogenic/mutagenic substances and
reprotoxic substances, but across the board
the requirements for businesses are similar.
The table 2 describes in detail the provisions of the European Working Conditions
Act. The record keeping as referenced in
the EU Working Condition Act can be an
administrative burden. It includes descriptions of activities and industrial processes
carried out, reasons for which carcinogens/
mutagens are used, quantities of products manufactured and used that contain
carcinogens/mutagens, number of workers
exposed, preventive measures taken, type

of (personal) protective equipment used,
nature and degree of exposure, cases of
replacement, etc.

Sustainable alternatives
DSM requires its businesses not to use
substances classified CMR 1A or 1B. If
not technically possible, DSM businesses
can only use CMR 1A or 1B substances in
line with the stringent requirements set by
European and national legislation. Also for
CMR 2 substances, DSM requires its businesses to look for possible alternatives (in
line with national legislation). Meanwhile,
the use of CMR 2 substances is allowed
when technical substitution is not possible.
Following these corporate guidelines and
its commitment to "Bright Science. Brighter
Living.™", there are several good examples
where DSM has been eliminating hazardous substances from its composite resin formulations, and was able to introduce more
sustainable material solutions. In particular,
these include the launch of cobalt-free
resins (based on BluCure™ technology),
and the development of styrene-free resins
under the Atlac® Premium, Beyone™ and
Daron® product brands.

Cobalt-free curing
In August 2012, cobalt octoate was reclassified as CMR 2 by the Cobalt REACH

Tab. 2: EU working conditions act - Provisions

Hazard
class

Hazard categories 1A & 1B
- Mandatory application of occupational hygiene
strategy: Starting point is «zero exposure of
humans»

Carcinogen

1. Reduction of use by replacement,
if technically possible

Hazard categories 2

- Mandatory application of occupational
hygiene strategy: Starting point is «zero
exposure of humans»
1. Reduction of use by replacement

2. if step 1 not possible the manufacturing and 2. if step 1 not possible the manufacturing and
use in a closed system if technically possible use in a closed system
3. if step 2 not possible then implementation of 3. if step 2 not possible then implementation
collective protection measures (i.e. local
of collective protection measures (i.e. local
exhaust)
exhaust)
4. if step 3 not possible then application of
individual protection measures
(Personal Protective Equipment)

Mutagen

4. if step 3 not possible then application of
individual protection measures
(Personal Protective Equipment)

- Mandatory record keeping of decisions taken

- No mandatory record keeping of decisions
taken: yet it is strongly advised

- Mandatory record keeping in manufacturing
& use

- Health surveillance

No87 March 2014

/ jec composites magazine 79

JEC COMPOSITES MAGAZINE - Issue #87 - March 2014 Special JEC Europe

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