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ECFIA Representing the High Temperature Insulation Wool Industry

ECFIA

- promote hygiene and safety in the manufacturing and use of high temperature insulation materials - promote understanding and management of HSE matters - dissseminate information regarding HS and environmental benefits related to high temperature insulation wools - initiate research programmes to improve scientific knowledge on high temperature insulation wools

Lobbying Activity

Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

27 May 2021

ECFIA (representing the high temperature insulating wool manufacturers) welcomes a review of the REACH regulation and is encouraged to see that the commission recognises and wishes to resolve some weakness, especially in relation to authorisation and restriction. In our view the following points are considered of significant importance as this work proceeds: • Revision of registration requirements: we would request that this is proportional and risk, as well as absolute hazard, is considered as a factor. We would also like to see consideration for inorganic substances that behave differently to organics where properties such as lack of degradation can be a positive, rather than a negative, attribute. • When looking at new testing, appropriate steps should be taken to ensure new animal testing requirements are minimised wherever possible and that there is a clear need to address specific endpoints that are not covered elsewhere. • It is also important to consider the overall risk for certain endpoints, and not just the potential intrinsic hazard based on the composition of the substances, especially when considering UVCBs. • When reviewing potential for grouping substances for evaluation purposes, if read-across considerations are to be applied in the absence of any exposure then this becomes more of an academic exercise with no tangible relationship to actual situations and may lead to over-classification. • Mixture Assessment Factors: care should be taken to avoid oversimplification and generalised grouping based on certain characteristics/parameters which may inadvertently overstate the hazard potential, we would welcome additional information on how this is envisaged as working and being communicated particularly in combination with the proposed changes to SDS. • Communication in the supply chain: a lot of work has already been carried out by industry to provide information on RMM’s concisely within the current requirements of SDSs. Harmonised electronic formats could be of limited use unless sufficiently flexible to deal with both inorganic and organic substances. Highlighting information relevant to users separately from in depth toxicological information could be beneficial but should already be carried out as part of a risk assessment at the point of use. • Reforming the authorisation and restriction processes: we would welcome a simplification of these processes, the authorisation process as it currently stands is disadvantageous to EU manufacturers of substances whilst failing to handle subsequent imports of articles containing authorised material which may still be released or supplied to at risk groups. • One point of potential concern is the intention to treat professional users in the same category as consumers. We would ask that care be taken to fully quantify and explain who constitutes a “professional user” vs an industrial user and under what circumstances this may change. • REACH restrictions were not conceived to set exposure limit values by an alternative route, i.e. DNEL values instead of OSH directives. Restriction of particular uses may be a sensible measure to address risks that cannot be addressed by OSH (use falling outside the scope of OSH). The interface between Restrictions and OSH should be clarified. ECFIA supports greater consistency across member states in terms of enforcement.
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Meeting with Camilla Bursi (Cabinet of Commissioner Virginijus Sinkevičius) and Wirtschaftskammer Österreich and WirtschaftsVereinigung Metalle

15 Jun 2020 · VC meeting with Cross-Industry Initiative (CII) to discuss the REACH/OSH interface and Improving the RMOA process – a tool for achieving the Chemical Strategy objectives