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European Association of Industrial Silica Producers

EUROSIL

EUROSIL is a comprehensive source of information for all issues relevant to the industrial silica industry with the exception of issues that might affect the free competition amongst its members.

Lobbying Activity

Response to Co-formulants in pesticides

11 Feb 2020

EUROSIL was founded in May 1991 as the official body representing the European industrial silica producers. The association provides its members with a forum in which to tackle regulatory, technical, health and safety and environmental issues and assures the representation of industrial silica at national and EU authority levels. We hereby ask the removal of the following 4 naturally occurring minerals --which are crystalline silica polymorphs-- from the draft list of unacceptable co-formulants in Annex III of Regulation (EC) 1107/2009. These minerals are: 1. Cristobalite (crystalline silica polymorph) 2. Quartz sand (crystalline silica polymorph) 3. Silicium dioxide (kieselguhr) 4. Trydimite (crystalline silica polymorph). We understand that those substances are under consideration because of their content of respirable crystalline silica. However respirable crystalline silica does not have an EU harmonised classification and thus is not listed in the Annex VI of the CLP Regulation. Still respirable crystalline silica is strictly legislated at the workplace. In 2018, ‘works involving exposure to respirable crystalline silica (RCS) generated by a work process’ were included in the European Carcinogens and Mutagens at Work Directive [Directive (EU) 2017/2398] with a European Binding Occupational Exposure Limit Value of 0.1 mg/m³. A recent report on crystalline silica by ANSES (French Agency for Food, Environmental and Occupational Health & Safety) in France concludes that there is no consumer use leading to a significant exposure to crystalline silica by inhalation and the professional users are protected by the Carcinogens and Mutagens Directive and the maximum exposure limit which is set in it. Thanks to the provisions of the workplace legislation, the minerals in question have no harmful effect on human/animal health or environment through their use as co-formulants in PPP and certainly have no unacceptable effect on plants as any soil contains a high proportion of silica by nature. Indeed, the earth’s crust consists of 12% quartz (the most common form of crystalline silica), which makes it the second most abundant mineral on the earth’s surface. Finally, the draft Annex III specifies for the silicon dioxide substances a particle size cut-off of 50 µm to focus on the respirable particles of crystalline silica. This 50 µm threshold was included in the quartz sand authorisation back in 2008. In this respect, we wish to point out that there is a lack of consistency with the recent Commission proposal for the 14th ATP to the CLP Regulation where ‘respirable particle’ has been defined with a particle size cut-off of below or equal to 10 µm for the aerodynamic diameter. We would expect that this Commission’s position and adaptation to technical progress be transposed in Regulation (EC) 1107/2009. The relevance of a particle size cut-off of 10 µm for respirable particles is detailed in the enclosure 1. As the current PPP authorisation for the active substances Quartz sand and Kieselguhr shall be renewed by 31/08/2020, there is a timely opportunity to consistently modify this parameter in the conditions of uses of these two PPPs.
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Meeting with Marianne Thyssen (Commissioner) and

2 May 2016 · Revision of the carcinogens Directive

Meeting with Inge Bernaerts (Cabinet of Commissioner Marianne Thyssen)

8 Oct 2015 · Revision of OHS Legislation

Meeting with Inge Bernaerts (Cabinet of Commissioner Marianne Thyssen)

19 Mar 2015 · EU OHS legislation