PICON Limited
Picon
Picon Ltd is the UK's leading industry trade association representing manufacturers and suppliers to the Printing, Papermaking and Paper Converting sectors.
ID: 357603421316-91
Lobbying Activity
7 Feb 2019
We would like to thank the Commission for the opportunity of responding to the proposed amendment to the CLP Regulation which will classify titanium dioxide as a Category 2 carcinogen and introduce waning label requirements on products containing it. We would like to make the following points:
• The RAC apparently believe that the proposed classification is associated with a dust effect, i.e. the lung overload of solid particles of poor solubility, which clearly is a more generic effect than just being specifically associated with titanium dioxide. So, the effect observed in rats is not an intrinsic property of titanium dioxide and this should be out of scope of CLP.
• Lung overload can only occur under high air-borne dust concentrations over a long period. This has never been observed for titanium dioxide in humans. In the laboratory experiments described, the lung overload seen in rats was unnaturally forced and it was the presence of solid dust particles that caused the chronic inflammation and subsequent tumor development.
• Titanium dioxide has been used in industry for many years and no concern for human health has been specifically determined. The issue for protection against dusts of any type is recognized and that is why Occupational Exposure Levels are in place to control them in an industrial environment. There is no concern for professional or consumer use of products containing titanium dioxide.
• The problems of titanium dioxide dust (if any) have not been quantified, so any benefits in classifying it are dubious to say the least. However, there are a considerable number of disbenefits:
o The classification of TiO2 as a Cat.2 Carcinogen is too draconian and will have unforeseen impacts downstream. For example, it would make waste collection more onerous unless further legislation was passed confirming whether waste coatings/inks etc were hazardous or not.
o Classification as a Cat. 2 carcinogen would not convey the correct message for the actual hazard of the product.
o This would mean that CLP itself would lose its credibility as a hazard communication process.
• It is clear that the Commission itself has recognized these unintended disbenefits and in the draft amendment has attempted to mitigate some of them by providing a number of caveats in the proposed Annex VI entry and in the new labeling phrases. This is trying to “bend” CLP to a purpose to what it is not intended
• We are not complacent and recognize that reducing worker exposure to dust inhalation is a beneficial health measure. However, these measures are already in place in most countries as dust OELs and we firmly believe that a better way forward would be to develop and introduce an EU harmonized OEL.
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