Information describing the spERC’s scope

Criterion 5: the spERC’s coverage is unambiguous and understandable to all relevant actors;

main and auxiliary processes are identified, not covered processes are explicitly excluded.

Criterion 6: Information describing the spERCs coverage is clearly separated from justifications and background data.

Table 17: Descriptive sections; ESIG 4.6a.v2 spERC ‘‘Lubricants (industrial): solvent-borne ’’

Section New / changed content in ESIG 4.6a.v2 Assessment of changed / new content Possible improvement Scope Revised (last two sections added)

Covers the use of formulated lubricants in closed and open systems including transfer operations, operation of machinery/engines and similar articles, reworking on reject articles, equipment maintenance and disposal of wastes.

Substance Domain: Applicable to petroleum substances (e.g., aliphatic and aromatic hydrocarbons) and petrochemicals (e.g., ketones, alcohols, acetates, glycols, glycol ethers, and glycol ether acetates).

Size of installation: Assumed that 1000 tonnes/year of substance is used, based on a medium sized industrial operation

Processing conditions – dry process

Compared to the earlier version, the spERC’s scope is concretised by the addition of the processing conditions (dry processes) and the average installation size (use amount of the substance). As the use amount at site is normally scalable, downstream users should be aware that they may be covered even if the use amount is higher than specified in the scope.

The list of processes is easy to understand and compare.

It is unclear if the term “equipment maintenance” includes cleaning activities.

Clarify, if cleaning or equipment is covered by the spERC.

Main user

group No Main User Group specified The use descriptor sector of use (SU) is missing. As many

REACH actors use the codes, it is useful to include them; also to further clarify the scope.

Change the row title to “related use descriptors. Add SU Environmental

release

category No Environmental Release Category specified The use descriptor environmental release category (ERC) is missing. As many REACH actors use the codes, it is useful to include them; also to further clarify the scope.

Add ERC

Processing

category Same as V1

1 (use in closed process, no likelihood of exposure), 2 (use in closed, continuous process with occasional controlled exposure), 3 (use in closed batch process (synthesis or formulation)), 4 (use in batch and other process (synthesis) where opportunity for exposure arises), 7 (industrial spraying), 8a (transfer of substance or preparation (charging/discharging) from/to vessels/large containers at non-dedicated facilities), 8b (transfer of substance or preparation (charging/discharging) from/to vessels/large containers at dedicated facilities), 9 (Transfer of substance or preparation into small containers (dedicated filling line, including weighing)), 10 (roller application or brushing), 13 (treatment of articles by dipping and pouring), 17 (Lubrication at high energy conditions and in partly open process ), 18 (Greasing at high energy conditions)

As the scope of the spERC is fairly broad, no inconsistency is detected with regard to the use descriptors. However, there are some PROCs, such as “industrial spraying” or “treatment of articles by dipping and pouring”, where it is not obvious how and why a lubricant is used and in how far these processes are “dry” as specified in the scope.

Clarify (scope or narrative) how lubricants are used in some PROC (e.g. industrial spraying).

Product

category No Product Category specified The use descriptor product category (PC) is missing. As many

REACH actors use the codes, it is useful to include them; also to further clarify the scope.

Add PC

Section New / changed content in ESIG 4.6a.v2 Assessment of changed / new content Possible improvement

Narrative description

Same as V1

Industrial use of solvent-borne lubricants encompasses a wide range of activities such as transfers, operation and maintenance of industrial equipment and engines, and waste disposal. Substance losses are reduced through use of general and site-specific risk management measures to maintain workplace concentrations of airborne VOCs and particulates below respective OELs; and through use of closed or covered equipment/processes to minimize evaporative losses of VOCs. Substance properties and uses result in limited to no discharge to air, wastewater or soil from the industrial site. Emissions to wastewater through cleaning operations are not applicable

The description is quite general and no inconsistencies with the scope and use descriptors are identified. However, the narrative is abstract and raises questions.

The information on RMMs to maintain workplace exposure limits are not relevant for the environment (except that a high degree of emission capturing is implemented), as no information on the actual final treatment is provided.

If “no discharges” occur, then all release factors should be

“zero”

The last sentence is ambiguous; either cleaning operations are not covered by the spERC or no equipment cleaning involving water use takes place.

Describe how lubricants are used in different processes, e.g. those which are mentioned in the previous section.

Delete information on workers exposure.

Add information on where and how emissions could occur in general.

Delete statements on the size of emissions.

Clarify if equipment cleaning is covered if it is a condition that no water is used.

Scaling Same as V1 (c.f. factsheet)

Scaling is explained in general, the scalable parameters are specified (Msite, Temission,site, REtotal,site and local dilution)

Scaling equations are provided depending on the risk driving compartment.

It is noted that scaling the release rates is not useful and outside the scope of the spERC.

The scalable parameters are specified and the scaling of the

release factor is explicitly excluded. Delete all general explanation on scaling; refer to the CEFIC guidance instead.

Appendix New (relates to CHESAR implementation); spERC determinants:

Indoor/outdoor: indoor

Process efficiency: Process optimized for efficient use of raw materials On-site treatment of wastewater acclimated biological treatment; effectiveness water 70%

On-site treatment of off-air: air filtration – particle removal; effectiveness 70% (70-99%).

The spERC determinants don’t include the full information on the process.

The process efficiency is described with an undefined term (efficient use)

The information on the on-site treatment of wastewater and off-air is not consistent with the respective section on obligatory RMMs (but with the additional ones). For the obligatory RMMs no efficiency values are provided.

Provide complete determinants.

Specify “efficient use of raw materials”

Add efficiency to RMM section in factsheet or remove from CHESAR file (FS specifies it as additional / not obligatory).

The description of the spERC’s coverage is still not consistent and the user of the spERC may have difficulties understanding if it is relevant to him or not. In particular the narrative description, which should explain the coverage in easy words, is contradictory to the other information.