Trichloroethylene and Authorisation under REACH

In an EU Member State Committee meeting in November 2012, the exact entry into ANNEX XIV of the REACH (Registration, Evaluation and Authorisation of CHemicals) legislation, Trichloroethylene (TRI) was discussed and voting took place. The outcome is seen as a final proposal and will most likely be taken up as such into ANNEX XIV at the earliest in March 2013. However, even this does not mean TRI will be banned for all applications in industrial surface cleaning.

User are still required to take all possible efforts to substitute TRI where possible. If an end user can demonstrate this with data that proves that no suitable alternative is available, an application for authorisation of TRI is possible for their specific use. This requires information which lists all efforts to identify possible alternatives and reviews the technical and economical feasibility and availability of the substance. SAFECHEM and Dow support end users in finding an alternative with products such as DOWPER MC, MECTHENE MC and the DOWCLENE series, as well as in the authorisation process. The latter under the condition the solvent is handled safely and in 'closed' equipment.

The timeline for the authorisation process is:

• Application Date: date by which applications for authorisation must be submitted to allow continued use after the Sunset Date. The Application Date is likely to be September 2014 (date of inclusion into ANNEX IV plus 18 months).

• Sunset Date: date from which placing TRI on the market and the use of the substance is prohibited unless authorisation is granted. The Sunset Date is likely to be March 2016 (18 month after the application date, 36 month after inclusion into ANNEX SIV).

Authorisation of TRI for use in industrial surface leaning in closed systems.

SAFECHEM and Dow have started to prepare a dossier to apply for authorisation of TRI for applications in which the substance cannot be substituted or the substitution cannot be realised before the Sunset Date. The application will only include the industrial use in surface cleaning in Closed Systems defined by the European Chlorinated Solvent Association (ECSA). According to this definition there are three types of closed surface leaning machines:

• Closed single chamber machine with internal air cleaning prior to opening.

• Closed single chamber machine with closed loop air drying without vent.

• Closed single chamber machine without vent and operating under vacuum.

Open top machines and enclosed systems (vented directly to atmosphere or vented through external A-carbon filters) will not be included in the application for authorisation; this is because the equipment is not considered as Best Available Technology (BAT) or state of the art technology and therefore not seen as sustainable.

The authorisation dossier has to contain the identity of the substance, contact details, detailed information on the use and a handling description, a chemical safety report, analysis of alternatives, a substitution plan if a suitable alternative exists and socio-economic analysis.

Comprehensive offerings for substitution of TRI.

Although Dow and SAFECHEM are focused on the Authorisation right now, SAFECHEM and Dow recommend substituting TRI with other viable solvents wherever possible and to use TRI only in applications where it is indispensable. As a complete solution provider for customised cleaning processes with virgin solvents, SAFECHEM offers with DOWPER MC (perchloroethylene, tetrachloroethylene, PCE), MECTHENE MC (methylene chloride, dichloromethane, DCM), and the modified alcohol solvents from the DOWCLENE series, not only potential alternatives but also full services for substitution. This includes a close cooperation with end users for finding the appropriate cleaning technology.

Therefore extensive chemical and technical consulting plus comprehensive laboratory services are available, e.g. oil compatibility tests and other solvent analysis. Furthermore, SAFECHEM assists customers in the approval process of the alternative solvent with their clients. There offerings lead to successful, legislation-conforming and sustainable solutions. In addition, Dow and SAFECHEM products already obtain approvals within sectors such as aerospace and defence.

Innovative solutions for the sustainable and safe use of solvents

SAFECHEM works together with responsible distributors, leading cleaning equipment manufacturers (OEMs) and certified waste managers in a Service Alliance. To achieve sustainable and safe use of solvents the company provides innovative and complete solutions based on active risk management, its SAFE-TAINER system for supply and return in combination with closed cleaning systems enables virtually emission-free use of solvents. In order to decrease consumption a wide range of service elements for maintaining chlorinated solvents as well as solvent trainings have been developed. The effective on-site training programme gives the relevant staff, such as plant operators, operations managers, environmental, health and safety officers and technical and quality managers, the knowledge needed for safe, responsible and ecologically-minded use of solvents and for increasing efficiency. This solvent training is part of the CHEMAWARE knowledge services. The complementary online information platform provides extensive information about responsible and sustainable use of solvents for high-quality cleaning of industrial parts.

The company also offers the innovative COMPLEASE concept, which enables customers to lease the entire cleaning process and to confer the active management of produce specific risks upon SAFECHEM. The leasing package is customised to meet individual requirements. It includes high quality, virgin chlorinated or non-chlorinated solvents from Dow, comprehensive services from SAFECHEM, CHEMAWARE know-how as well as closed cleaning equipment from leading manufacturers upon request. This leads to high quality cleaning results, increased cleaning efficiency and minimised pollution emissions.


SAFECHEM Europe GmbH, Richard Starkey 44 (0)7976 531695

DOWPER™, SAFE-TAINER™, CHEMAWARE™ and COMPLEASE™ are trademarks of The Dow Chemical Company (Dow) or an affiliated company of Dow.

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