High Temperature Insulation Wool - HTIW and REACH

HTIW and REACH

Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) is a European Union Regulation of 18 December 2006. REACH addresses the production and use of chemical substances, and their potential impacts on both human health and the environment. A Substance Information Exchange Forum (SIEF) has been set up for each type of HITW. AES, ASW and PCW have been registered before the first deadline of 1 December 2010 and can therefore be used on the European market.

Regulation (EC) No 1907/2006 of the European Parliament and the Council of 18 December 2006 concerning the Registration, Evaluation, Authorization and Restriction of Chemicals (REACH) require manufacturers, importers and Only Representatives of non-European manufacturers to share data on potential health and environmental hazard and provide data to the European Chemicals Agency (ECHA) in a formalized registration process.

ASW/RCF, AES and PCW were registered using a joint registration dossier before the first deadline of 1 December 2010. They can therefore be used on the European market. The registration process required that manufacturers, importers of substances >1 t/year agreed on classification, labelling and uses of ASW/RCF, AES and PCW.

The REACH and the CLP Regulation being based on the principle of self-classification by industry; however prior harmonized classification of substances contained in Annex 1 of Directive 67/548 remains valid and has been transferred to Annex VI of CLP. Classification in Annex VI of the CLP Regulation is the mandatory classification; industry has to evaluate whether additional/stricter classification may apply.

• ASW/RCF is therefore classified as carcinogen category 1B
• AES is exempted from carcinogen classification based on short term in vitro study result
• PCW are not classified; self-classification led to the conclusion that PCW are not hazardous

On 13 January 2010 some of the Aluminosilicate Refractory Ceramic Fibres and Zirconia Aluminosilicate Refractory Ceramic Fibres have been included in the Candidate List of Substances of Very High Concern. In response to concerns raised with the definition and the dossier two additional dossiers were posted on the ECHA website for consultation and resulted in two additional entries on the Candidate List. - This actual (having four entries for one substance/group of substances) situation is contrary to the REACH procedure intended. Aside from this situation, concerns raised during the two consultation periods remain valid.

Regardless of the concerns raised the inclusion of a substance in the Candidate List triggers immediately the following legal obligations of manufacturers, importers and suppliers of articles containing that substance in a concentration above 0.1% (w/w):

• Notification to ECHA -REACH Regulation Art. 7
• Provision of Safety Data Sheet- REACH Regulation Art. 31.1
• Duty to communicate safe use information or responding to customer requests -REACH Regulation Art. 33