SAFEGUARDS | Consumer Products NO. 128/18
On September 4, 2018, European Chemical Agency (ECHA) opened its second public consultation of 2018 on six potential Substances of Very High Concern (SVHCs) . The Candidate List will expand to 197 if these proposals are accepted. Interested parties have until October 19, 2018 to submit comments and further information on use, exposure, alternatives and risks of the substances to ECHA.
The six potential SVHC proposals
The 2018 second SVHC consultation list includes six proposals, among which are four potential SVHCs – benzo[k]fluoranthene (BkFA), fluoranthene, phenanthrene and pyrene belonging to the family of polyaromatic hydrocarbons (PAHs). These PAHs are not produced intentionally but occur together with other PAHs as constituents of coal and petroleum stream UVCB substances.
One SVHC proposal is 2,2-bis(4'-hydroxyphenyl)-4-methylpentane, which is mainly used in polymer manufacturing. In addition, it is structurally similar to bisphenol A (BPA) and thus considered as an alternative to BPA in the manufacture of thermal paper. Other minor uses include surface coatings, inks and adhesives.
The remaining potential SVHC candidate is undecafluorohexanoic acid and its ammonium salt (PFHxA and APFHx) because of its probable serious effects to the environment, which gives rise to an equivalent level of concern to other SVHCs. According to the scientific assessment in the ECHA dossier, the substance is extremely persistent with high mobility in the aquatic environment and therefore can be distributed easily within and between aquatic environmental compartments. It also has the potential to enrich in plants and contaminate drinking water. PFHxA has no specified uses and is mainly present as an impurity in articles or occurs as a degradation product.
The potential uses of these potential SVHCs are summarized in Table 1.
Table 1. Possible uses of the potential SVHCs in the Consultation List published by ECHA on September 4, 2018.
|No.||Substance||CAS No./ EC No.||Classification||Potential uses|
|1||2,2-bis(4'-hydroxyphenyl)-4-methylpentane||6807-17-6/ 401-720-1||Repr. 1B||
|2||Benzo[k]fluoranthene||207-08-9/ 205-916-6||Carc. 1B, PBT, vPvB||
|3||Fluoranthene||206-44-0/ 205-912-4||PBT, vPvB||
|5||Pyrene||129-00-0/ 204-927-3||PBT, vPvB||
|6||Undecafluorohexanoic acid and its ammonium salt||307-24-4; 21615-47-4/ 206-196-6; 244-479-6||EQC||
Carc. 1B: Carcinogenic category 1B
EQC: Equivalent level of concern
PBT: Persistent, bioaccumulative and toxic
Repr. 1B: Toxic for reproduction category 1B
UVCBs: Substance of unknown or variable composition, complex reaction products or biological materials
vPvB: Very persistent and very bioaccumulative
Comments and further information on use, exposure, alternatives and risks of the substances shall be submitted by October 19, 2018.
SVHCs may be introduced into various consumer products due to the complexities of both the supply chain and production process. Identifying high risk products or materials, or having a test strategy, can also be a smart way to ensure compliance and save costs. If you would like to learn more about how SGS can support your REACH compliance activities please contact us at email@example.com or visit www.sgs.com/reach
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