When handling any HTIW product, care should be taken to reduce exposure to fibrous dust as per recommendations in ECFIA’s CARE guidance documents. Users of ASW/RCF must also follow specific risk management obligations as laid out in the EC Directive 2004/37EC of 29 April 2004 (Carcinogens Directive) on the protection of workers from the risks related to exposure to carcinogens or mutagens at the workplace.
The obligations resulting from the application of the Carcinogens Directive apply only to ASW/RCF.
Substitution obligation (Art.4 Carcinogens Directive)
Replace as far as technically possible by a substance, preparation or process which under its conditions of use, is not dangerous or is less dangerous to workers‘ health or safety as the case may be Submit findings of investigations to relevant authorities.
Avoiding exposure (where technically feasible)
Substitution obligation (Art.4 Carcinogens Directive)
Using closed systems
Using dust collecting equipment (dust extraction at source etc.)
Using prefabricated products
Limiting access to authorised persons only
Using personal protective equipment
Please refer to our CARE Guidance documents that recommend specific measures to reduce exposure.
BOELV Implementation for ASW/RCF
1. Background & SCOEL Recommendation
- In 2011, the Scientific Committee on Occupational Exposure Limits (SCOEL) classified refractory ceramic fibres (RCF) as Carcinogen Group C (genotoxic carcinogens where a practical threshold can be identified).
- Based on this classification, SCOEL proposed an occupational exposure limit (OEL) of 0.3 f/ml for ASW/RCF.
2. EU Binding OEL under the Carcinogens Directive
- Mutagens Directive (2004/37/EC), introducing a Binding Occupational Exposure Limit Value (BOELV) of 0.3 f/ml for ASW/RCF.
- EU Member States had two years to implement this limit, culminating in January 2020. From that point onward, all Member States must comply with the 0.3 f/ml BOELVDirective (EU) 2017/2398 amended the Carcinogens and (some may adopt more stringent limits at national level).
3. Current Status
- The 0.3 f/ml limit is now in effect EU-wide for workplaces handling ASW/RCF.
- Employers must ensure workplace exposure does not exceed this limit and must implement appropriate engineering controls, monitoring, protective equipment, and training for workers.
4. Limits for LBF and PCW
- For Low Bio-Persistent Fibres (LBF) and Polycrystalline Wool (PCW), there is no EU-wide specific BOELV in the Carcinogens Directive.
- Member States typically apply general dust or Man-Made Vitreous Fibre (MMVF) limits, which can vary (e.g., 1 f/ml, 0.1 f/ml) depending on national legislation.
From February 2020 a BOELV of 0.3f/ml for ASW/RCF applies to all EU member states.
For LBF and PCW the general dust or MMVF limits will continue to apply.
Communication
- Information to be submitted to authorities
- Information to be provided to workers on: health risks, handling instructions (including transport, waste)
- Training
- Health surveillance
- Record keeping
Marketing Restrictions
Annex 17 N° 28 of the REACH Regulation on restriction on the manufacture, placing on the market and use of certain dangerous substances, preparations and articles prohibits substances which are classified as carcinogen category 1A or 1B in Part 3 of Annex VI to CLP Regulation (EC) No 1272/2008 and are listed in Appendix 1 or Appendix 2, respectively, to be sold to the general public.
Suppliers of ASW/RCF shall ensure before the placing on the market that the packaging of such substances and mixtures is marked visibly, legibly and indelibly as follows: ‘Restricted to professional users’.
No sales of ASW/RCF to consumers.Use that is advised against: Spraying.
Safety Data Sheets
Safety data sheets are mandatory for those substances meeting the criteria listed in Article 31 REACH Regulation (classification as hazardous, persistent/bioaccumlative or being considered an SVHC for other reasons).
SDS have been provided for a long time to customers for all products containing ASW/RCF, LBP and PCW.
SDS will be continued to be provided as per regulatory requirements for ASW/RCF and on a voluntary basis for LBP and PCW.
Reference documents
- TRGS 619: Technical Rule for Hazardous Substances – Substitute materials for alumino-silicate wool products, version May 2013; Download
- VDI-Guideline 3469 Emission control – Production and processing of fibrous material sheet 1 (HTIW), February 2007
- INRS several technical brochures on refractory ceramic fibres (in French: fibres céramique réfractaires); www.inrs.fr
- Les fibres céramiques réfractaires, fiche pratique de sécurité, ED 109 novembre 2017; FAS 9 fiche à l’aide de substitution: Substitution des fibres céramiques réfractaires (FCR) (2007)
- Fibres céramiques réfractaires. Isolation et protection thermique en milieu industriel; Guide de prévention (ED 6085, 2011)
- Exposition aux fibres céramiques réfractaires lors de travaux d’entretien et de maintenance (ED 6084, 2010)
- Captage de fibres céramiques réfractaires sur poste fixe; Guide de prévention (ED 6156, 2013)
- Fibres céramiques réfractaires: recommandations pour capter les poussières ; Notes techniques (NT4, 2013)
- COSHH Regulation 7: HSE Guidance booklet seven steps to successful substitution of hazardous substances