In light of the current discussions related to ECHA´s 5th and 6th recommendation of substances for inclusion on REACH Annex XIV ECFIA would like to draw attention to the specific details of the ASW/RCF case:
1) ASW/RCF is an industrial material - consumers or the general public are not at risk
ASW/RCF products are insulation materials designed to save energy and to reduce CO2 emissions in industrial high temperature processes at temperatures typically exceeding 800°C. Any potential risk associated with the inhalation of fibrous dust is limited to workplace situations.
2) Authorisation does not affect imported ASW/RCF based articles
Authorisation would not lead to an overall improvement of occupational safety since fibrous dust can be released during the handling (installation, maintenance, removal) of ASW/RCF based articles. The import of articles from outside the EU, however, is not affected by the Authorisation process.
3) Authorisation will not lead to accelerated substitution
More than 60% of the European ASW/RCF market volume has already been substituted over the last 25 years, driven by the successful development of alternative products and the existing obligations under occupational safety and health (OSH) Directives. The remaining uses cannot be substituted without an undesired impact on process security, worker safety, emission controls and competitiveness.
4) Authorisation will not improve occupational safety
Since about 20 years the HTIW industry has implemented a comprehensive Product Stewardship Program which has been acknowledged by several regulatory bodies. This program is fully in line with the ´hierarchy of controls´ principles embedded in European OSH Directives and has helped to control and reduce exposures at the workplace. There has been no human disease associated with ASW/RCF dust exposure during more than 60 years of industrial use. This is why ECFIA believes that any potential risk related to the industrial use of ASW/RCF products can be most effectively and efficiently addressed via OSH legislation.
In conclusion, the proposal to include ASW/RCF on Annex XIV would not lead to additional benefits, but is seen as a massive administrative burden for EU-based manufacturers. Furthermore it could lead to a number of undesired socio-economic and environmental implications. Strengthening the existing OSH Directives, i.e. via the implementation of an appropriate binding occupational exposure limit, would fully support the objective of improved worker protection – in line with the EU´s ´better regulation´ and REFIT program.
The following documents, including 3rd party reports on socio-economic impacts and limitations of substitution, provide more detailed information on all these aspects:
If you would like to have a copy of the following documents, send a mail to: firstname.lastname@example.org
- AMEC Foster Wheeler - socio-economic importance of ASW/RCF in the context of EU regulations
- BIPRO – overview on alternatives for ASW/RCF products