A pragmatic approach is needed when selecting what use descriptor, sector of use and process category a particular area of polyurethane manufacturing falls into under the EU’s REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulation.
And this selection needs to be done by a whole sector, rather than by individual processors, emphasised REACH expert, Dr Jürgen Grönen of ISL Chemie.
Otherwise part makers could find themselves swamped by paperwork, because they feel their process(es) fall into several categories, he indicated.
As a result of this realisation, the REACH committee of the FSK (The German association for producers of foam plastics) has intensified its dealings with ISOPA (the European Diisocyanate and Polyol Manufacturers Association), Grönen said.
Since the start of 2009, there has been “constant contact with ISOPA, to find common ground,” he added, in a presentation at the 10-11 Nov meeting of the FSK.
Processors of materials do not have to prepare raw material dossiers within REACH.
But they have to describe and classify their processes, so that material suppliers can feed this evaluation into their data, for assessment of risk during processing of the materials.
Use descriptors needed for risk
Polyurethane processors must produce an exposure scenario, and define their production conditions in a standard way. Then they can evaluate hazard and risk in handling and so devise an environmental…