REACH - Information from Suppliers
As a supplier of substances or mixtures used in lubricant products, you need to be confident that you have, or will, register your substances in way that properly covers their uses. To support a consistent approach to the registration of substances used in lubricant products, ATIEL/ATC have worked together to map all known applications of their products to relevant uses. These uses have been consolidated into five groups for finished products (Use Groups B-F) and one for formulation of the product (Use Group A).
This mapping is shown in the ‘ATIEL-ATC Lubricant Applications Table’. Each of these Use Groups has been mapped according to the REACH Use Descriptor system provided by the European Chemicals Agency (ECHA) [reference: Guidance on Information Requirements and Chemical Safety Assessment Chapter R12] and documented in the ‘ATIEL-ATC Lubricant DUCC* Table’, with the aim of describing the uses in a uniform way.
This information can be used by registrants to develop their chemical safety assessment (CSA) and dossier. ATIEL/ATC members have been encouraged to share this information with their suppliers in order to maximise the likelihood that their uses will be covered in the substance registrations without the need for time consuming and inefficient communication up and down the supply chain. If you have not already been asked by your
lubricant formulator customers to cover uses according to the ATIEL/ATC use groups, the following steps should help you to establish the Identified Uses which you may be asked to cover in the registration dossier for substances you manufacture or import (or pass up the supply chain to the manufacturer/importer if you are a formulator).
Step 1:
Identify the lubricant applications (family and specific application) in which your substance/product is used (e.g. metalworking, corrosion protection – water based) by referring to the ‘ATIEL-ATC Lubricants Application Table’. Make a note of the Use Group (A – F) that has been allocated to each application. For example:
| Lubricant Application | ATIEL/ATC Use Group | |
|---|---|---|
|
Family |
Specific application |
|
|
Metalworking |
Corrosion protection – water based – diluted |
C |
Step 2:
Refer to the worksheet titled ‘Lubricant Table (DUCC Format)’
of the ‘ATIEL-ATC Lubricant DUCC Table’ to identify the Use Groups and relevant supporting information to assist in the development of exposure scenarios.
Each Use Group (A-F) is divided into industrial (SU3), professional (SU22) and consumer (SU21), where relevant. For each of these sub-groups, the use is described by a short title, scope statement and list of related activities (Contributing Scenarios) which are mapped to the Use Descriptors (Sector of Use, Process Category, Product Category and Environmental Release Category). In addition, typical OCs (operational conditions) and RMMs (risk management measures) that are relevant for each contributing scenario are also identified to assist registrants in selecting appropriate controls when these are necessary to demonstrate safe use.
Step 3:
Confirm within your own organisation that you intend to develop exposure scenarios covering these Identified Uses in your registration dossier, or that this will be included by the substance manufacturer/importer if you are a formulator.
Step 4:
Communicate the Identified Uses and exposure scenarios you intend to support (or your supplier intends to support) to your downstream users as soon as possible.
Suppliers to the lubricants industry should note that all substances used in lubricant applications need to be registered for the Identified Uses allocated to Use Group A (formulation) and at least one other end use from Groups B-F.
NOTE: Before using any of the information on this website please read the disclaimer.
Environment
Under REACH, some lubricant products need to be registered for consumer use. This is covered by the Use Descriptor PC24 (Lubricants, greases, and release products). The ECETOC TRA tool (www.ecetoc.org/tra) provides the ability to estimate exposures for consumer lubricants in liquid, paste and spray forms. ATIEL is working with ATC and other lubricant suppliers to obtain habits and practices information that are representative of these Uses and that can be used, in conjunction with the TRA, to derive more accurate estimates of consumer exposure to lubricants.
The Environmental Release Categories (ERCs) described in ECHA’s Guidance on Information Requirements and Chemical Safety Assessment Chapter R12, are very conservative in their assumptions about environmental releases. ATIEL/ATC has therefore developed Specific Environmental Release Categories (SpERCs) to reflect actual conditions of use for applications of lubricants.
These SpERCs, which have been developed for Industrial, Professional and Consumer sectors of use can be used in place of ERCs when you develop a Chemical Safety Assessment for a substance. More information on the SpERCs are available.
ATIEL/ATC encourages their suppliers to utilise these SpERCs in the development of the environmental exposure scenarios for the use of substances in lubricants to help support the demonstration of safe use for the substances they are registering.
REACH: Specific Environmental Release Categories (SpERCs) Factsheets
The Environmental Release Categories (ERCs) described in ECHA’s Guidance on Information Requirements and Chemical Safety Assessment Chapter R12, are very conservative in their assumptions about environmental releases. ATIEL/ATC has therefore developed ‘Specific Environmental Release Categories’ (SpERCs) to reflect actual conditions of use for applications of lubricants.
These SpERCs, which have been developed for Industrial, Professional and Consumer sectors of use can be used in place of ERCs when you develop a CSA for a substance. ATIEL/ATC encourages their suppliers to utilise these SpERCs in the development of the environmental exposure scenarios for the use of substances in lubricants to help support the demonstration of safe use for the substances they are registering.
The facsheet are under review and will be available on the website soon.
Use Group A
• SPERC Factsheet Ai-add-pack (2012-10-05)
• SPERC Factsheet Ai-lubes (2012-10-05)
Use Group B
• SPERC Factsheet Bc (2012-10-05)
• SPERC Factsheet Bi (2012-10-05)
• SPERC Factsheet Bp (2012-10-05)
Use Group C
• SPERC Factsheet Cc (2013-02-07)
• SPERC Factsheet Ci (2012-10-05)
• SPERC Factsheet Cp (2013-02-07)
Use Group E-F
• SPERC Factsheet Ei (2012-10-05)
• SPERC Factsheet Fi (2012-10-05)
• SPERC Factsheet Fp (2012-10-05)
Disclaimer
The information in this website is provided for general information purposes only. No representations or warranties, express or implied, are made by ATIEL or any of its members concerning the applicability, suitability, accuracy or completeness of the information contained herein, and ATIEL and its members accept no responsibility whatsoever for the use of this information. Neither ATIEL nor any of its members shall be liable in any way for any liability, loss, cost or damage incurred as a result of the receipt or use of the information contained herein.
Legal representation
ATIEL is legally represented by the President and one member of the Executive Committee, acting jointly (art 25.2 of the ATIEL Aarticles
of association. Office address: Rue de la science 14B, B-1040 Brussels, Belgium, VAT BE 0750.488.604
