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REACH 

Coatings, inks & artists' colours manufacture and application

 

This page provides information on the following topics: 

Descriptors of use

One fundamental aim of the REACH Regulation is to ensure all uses are safe to man and to the environment. Within REACH, “use” is defined in a specific and unique way. Established means of describing use are no longer appropriate for communicating, up and down supply chains, information relating to use. A new ECHA system has to be employed to enable “use” to be described in accordance with the REACH definition. 

With the aim of helping manufacturers and importers of substances understand how substances typically are handled in the manufacture of coatings, printing inks and artists’ colours, and in their application in industrial processes, by professional users and by consumers, CEPE has compiled descriptors of use covering all these use situations.  

More information on the use descriptor scheme can be found in the attached Information NoteThis note also provides a useful overview of manufacturing and application processes, and describes how the descriptor of use tables can be used by upstream suppliers, by coatings and inks manufacturers, and by downstream users.  

CEPE has aimed to identify a set of standard descriptors of use that cover the majority of coatings, inks and artists' colours manufacturing and application processes. In the interests of harmonisation and consistency, manufacturers and importers are urged to adopt relevant uses from the CEPE tables as identified uses. CEPE communicated information on these tables to major raw material organisations on 2 June 2009. Both manufacturers and downstream users are encouraged to select use descriptors from the CEPE tables and to communicate these up and downstream, as required. 

Please note that, in addition to these standard descriptors of use, individual CEPE member companies may communicate, up their supply chains, any specific uses that are not included in the tables. 

Links to the tables can be found below. 

Operating conditions and risk management measures 

REACH requires manufacturers and importers to carry out a risk assessment for each use of a hazardous (dangerous) substance, which is manufactured in quantities of 10 tonnes or more per annum, and to identify the risk management measures to ensure each use is safe to man and/or the environment. 

In January 2010, CEPE established typical worst case operating conditions for each use identified in the descriptor of use tables. These are intended to help manufacturers and importers use, in occupational or consumer health risk assessments tools, those operating conditions that are applicable to the manufacture and application of coatings, inks and artists’ colours. 

To further help manufacturers and importers identify risk management measures appropriate to the manufacture and application of coatings, inks and artists’ colours, CEPE has identified best practice risk management measures for each use identified in the descriptor of use tables. 

Subsequent to the initial activities, in September 2010, the short descriptions of the process steps and activities, and the risk management measures were codified. This initiative reflects activities within sector supply chains to develop harmonised phrases for supply chain communications and use in IT systems.

Since then, minor updates or annotations have been made to the tables as required in light of subsequent developments and practical experience.

Links to the tables can be found below. 

Use mapping tables, comprising descriptors of use, operating conditions and risk management measures 

The extended use mapping tables can be accessed via following links:

* descriptors of use only

These tables are in line with the current ECHA guidance on the descriptions of use (R12, published March 2010).

Specific environmental release categories (SpERCs) for the manufacture and application of coatings, inks and artists’ colours - Overview 

CEPE has prepared SpERCs for

  • coatings, inks and artists’ colours manufacturing processes
  • a number of applications of coatings, inks and artists’ colours

(CEPE has adopted a basic principle that SpERCs for the application of coatings and inks are most appropriately developed by industry organisations representing users of coatings and inks. The only exception to this rule is that where there is no representative or active organisation for a particular user sector, CEPE will prepare relevant SpERCs).

These SpERCs are intended to help manufacturers and importers of substance apply, in environmental risk assessments tools, typical worst releases from manufacturing processes to the three environmental compartments.

The information in these SpERCs has been uploaded into the environmental section of the ECETOC TRA toolThey form part of the set of sector-specific emission factors, for use by manufacturers and importers of substances in the preparation of environmental risk assessments.

An Overview of the SpERCs for manufacture and application (including those from a number of user associations) can be accessed here. The Overview also is available on CEFIC’s REACH website, via either of the following links:

and, once accessed, by clicking on the “coatings and inks” tab.

The Overview table was revised in September 2010 to renumber SpERCs in line with the CEFIC coding system; to allocate systematic CEPE codes; to add additional SpERCs; and to codify the phrases and statements for more efficient upstream and downstream communications and use in IT systems.

CEFIC SpERC coding system

The CEFIC coding system consists of five components: e.g. CEPE SpERC 2.1.a.v1  

CEPE
Reference to the entity responsible for the SpERC
2
Relevant ERC
1
Rotational number within a specific ERC
a
Differentiates a specific set of default values within a SpERC
v1
Version number

 

Specific environmental release categories (SpERCs) for the manufacture and application of coatings, inks and artists’ colours - Fact Sheets 

Supporting the Overview table, CEPE has prepared a number of Fact Sheets, which provide more detailed information on the emission factors found in the Overview table. These Fact Sheets are based on the CEFIC model format, as issued in July 2010.

The following CEPE Fact Sheets are available:

Introduction 
See: ECHA Guidance on information requirements and chemical safety assessment Chapter R.12: use descriptor system. Revision, March 2010.
A chemical safety assessment (CSA) shall cover not only the uses of a substance, but also the subsequent life cycle stages of substances incorporated into or onto an article matrix. The manufacturer or importer of such substance may find it necessary to specify which types of articles are covered in the CSA and the Exposure Scenarios.
If a substance is not expected to be included into articles during use (e.g. solvents), no article category is to be assigned. 
The ECHA guidance referred to above provides guidance on different categories of ACs, and how and when they are to be allocated. 
Article categories for coated or printed articles 
NOTE: in practice, ACs will be of limited relevance to coating films or print on articles, which are produced by the application of coatings and inks to the article concerned.  ACs are only included in risk assessments where there is a release of a dangerous substance from the article.  Few dangerous substances will be found in applied films, and usually these are not intended to be released during the article use cycle.  Releases from films during service life, e.g. by erosion, are estimated at very low levels - typically 0-3% of the original solids (source: OECD Emission Scenario Document 22).
It is also highly unlikely that once incorporated in an article, any substances of very high concern will exceed the threshold of 0.1%.  
Coating films and print are found on very many articles, which are produced from a variety of materials with many different purposes, end uses and users. CEPE does not have a comprehensive understanding of all service life stages of coating films and print (and, by analogy, of substances present in the applied films). We therefore are unable to provide any detailed information on the ACs applicable to particular substances. The best we currently can advise is that all ACs potentially are applicable to the professional and industrial application of coatings or inks. 
As an aid to manufacturers and importers we have annotated here below the AC tables contained in the ECHA guide with information on which are applicable to CEPE members’ products:

- Appendix R. 12-5.1: Descriptor-list for substances in articles [AC]

- Appendix R. 12-5.2: Articles with intended release of substances

- Appendix R. 12-5.3: Consumer articles addressed in the TRA  

Review of earlier CEPE recommendation

The use descriptor tables published by CEPE do not contain any ACs. An article is produced from a number of components, of which the coating film or print is invariably a minor part. It would be presumptuous for suppliers of just one component to allocate an AC to an article. In CEPE’s view, only producers of articles can decide the ACs applicable to their products.
 
Accordingly, the CEPE tables covering industrial and professional application of coatings and inks, had indicated “DU applicators to complete” in relation to ACs. 

Only limited data on ACs has been received from the downstream use chain. In the light of this situation CEPE has reviewed its earlier decision and has annotated the AC tables contained in the ECHA draft guidance.

Update: 15 February 2013

Date Details
April 2009
Original webpage issued:
  • Descriptor of Use (DoU) tables
  • Information Note on manufacture and application of coatings and inks and CEPE process for preparation of DoU tables
January 2010
Page extended with information on:
  • Operating Conditions and Risk Management Tables
  • Guidance on Article Codes (ACs) for coated and printed materials
  • Statement on ACs in DoU tables
February 2010
Page extended with information on:
  • Statement on action CEPE members may take to  notify specific uses (uses not covered by the CEPE DoU tables)
  • Specific Emission Release Categories (SpERCs) for coatings and inks manufacturing processes
  • Updating of DoU-OC-RMM tables for manufacture of coatings and inks with SpERC references
  • Editorial corrections
April 2010
Page extended with information on:
·         DoU and DoU-OC-RMM tables amended to replace references to PC5 and PC9 by PC9a, 9b, 9c, as relevant (following publication of revision of ECHA guidance R12, March 2010).
·         Specific Emission Release Categories (SpERCs) for the application of coatings and inks.
Availability of manufacturing and application SpERCs on the CEFIC website and inclusion of industry emission factors in the ECETOC TRA tool.
October 2010
Page fully revised
  • DoU-OC-RMM tables updated with codified process steps/activities and risk management measures
  • Inclusion of information on an amended SpERC overview table in the manufacture and application sections. This contains a number of new “CEPE-owned” SpERCs compared with the April 2010 document. In addition, revised harmonised SpERC references have been added (in line with the scheme in the CEFIC guidance on SpERCs for downstream communication, July 2010); SpERC descriptions have been re-cast into a more consistent format, suitable for inclusion in harmonised phrase libraries; and SpERCs have been regrouped by use category (industrial, professional and consumer).
  • Update of the version reference to the ECHA guidance on the use descriptor scheme (R.12, March 2010) and reference to releases during article service life in the Articles Category section.
August 2012
  • Industrial and professional application only: explanatory note added regarding film formation – air drying (PROC 4).
  • All sheets: references to SpERCs inserted/updated, cover page explanation updated, reference tabs of use descriptors reinstated and updated.
February 2013
  • Updated description for use mapping tables
  • Explanatory note regarding ventilation efficiencies added to use mapping tables for manufacture and for application (industrial and professional)

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