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 48: Descriptive sections; FEICA 5.1a.v2 spERC ‘‘Industrial use of non-solvents in various sectors’’

Section Content in FEICA 5.1.a.v2 Assessment Possible improvement

Scope Covers the application of adhesives for a wide range of purposes by industrial uses. Covers different adhesives application techniques for indoor use.

Substance Domain:

FEICA spERC 5.1a.v2, FEICA spERC 5.1b.v2, FEICA spERC 5.1c.v2 All substances which do not evaporate to a significant extent upon curing of the adhesives.

The scope description is very broad because several sub-spERCs (relating to many different sectors) are covered.

The section specifies that only indoor uses are covered by the spERC. This is inconsistent to the spERC determinants, where also outdoor uses are mentioned as covered.

Information on whether or not cleaning and maintenance processes are covered is missing.

The substance domain for the sub-spERC assessed here contains the undefined expression “evaporation to a significant extent upon curing”.

Consider separating factsheet for ERC 4 and ERC 5 or according to main use sectors to better clarify the scope.

Clarify if cleaning and maintenance is covered.

Clarify if outdoor uses are covered (either inclusion here or deletion in determinants).

Define “evaporation to a significant extent”, explain what stages of the adhesive use form the “curing phase” and if substances which significantly evaporate before curing (e.g.

during spray applications) are covered or not.

User Group Main User Group: SU 3 OK

Sector of use Sector of Use: SU 19 The sector of use “building and construction” is not consistent with

the scope description of most of the spERCs List SUs for all sectors mentioned in the scope of all sub-spERCs

Environmental Release

Category Environmental Release Class: ERC 4, ERC 5 OK

Process Category

Process Categories: PROC 2, PROC 3, PROC 4, PROC 5, PROC 7, PROC 8a, PROC 8b, PROC 9, PROC 10, PROC 11, PROC 12, PROC 13, PROC 14

The PROCs 2-5 are inconsistent with the scope (manufacture and formulation).

PROC 11 (non-industrial spraying) indicates a professional (or consumer) use of adhesives, which is not consistent with the scope description.

PROC 12 (use of blowing agents) is not a use of an adhesives and hence inconsistent.

Delete PROCs 2, 3, 4, 5, 11, 12

Product category

Product categories: PC 1, PC 9a, PC 9b, PC10

PC 9a and 9b are not consistent with the spERC title and scope descriptions, which limit the substance use to adhesives

PC 10 is not part of the current use descriptor guidance, considering the title and scope, the use in adhesives (PC1) should be sufficient (no “other”) needed.

Delete all PCs except PC1

Narrative

description Three times:

“Industrial applications of Paper, Board and related Products / Woodworking and joinery / Footwear and Leather, Textile and

The narrative description consists of 3 repetitions of the same text block (slightly different in the last paragraph). It is unclear why the text blocks are repeated, in particular as there are 5 sub-spERCs but

Revise the narrative description in order to provide the spERC users of an easily understandable general process description.

Section Content in FEICA 5.1.a.v2 Assessment Possible improvement others adhesives

Adhesives used in the above mentioned products; others include products like electricity, electronics, optics, hygienics, food, toys medical technics, sportswear etc. are normally rolled, sprayed or directly used from the cartridge due to the

application purposes.”

One time:

Industrial applications of Transportation

(Automotive/aircraft/rail vehicles) / industrial Building Construction/Adhesives

Adhesives used in the above mentioned products; are normally brushed, rolled, sprayed or directly used from the cartridge due to the application purposes.

only 3 repetitions and one slightly changed text.

The content of the text block explains the term “other” in the list of applications but is not comprehensive, hence no narrowing of scope occurs. It also gives examples of application techniques, which repeat parts of the listed PROCs.

The original intention of the narrative description to provide a short flow text to facilitate the understanding of which processes are covered by the spERC is not fulfilled. No details are given on the processing techniques, relevant exposure determinants or waste management.

For reasons of conciseness and clarity, it may be considered to separate the factsheet either according to ERCs or to sectors of use (c.f.

above).

Scaling

Guidance is based on assumed operating conditions which may not be applicable to all sites; thus, scaling may be necessary to define appropriate site-specific risk management measures.

The scaling refers to operational conditions; however the respective descriptions (c.f. below) don’t allow comparison of the conditions and deciding on whether or not they apply to “all sites”.

It is not specified which parameters could be scaled under which condition and whether or not the standard equation is applicable.

Revise the scaling section in relation to the description of the operational conditions.

Either provide more specific information on scalable parameters and scaling equations or include only general reference to CEFIC guidance.

Appendix Specified determinants:

Type of Process: Dry process (no water used in process) Indoor/outdoor use: Covers Indoor and Outdoor Use Equipment cleaning: Equipment cleaned with organic solvent, washings are collected and disposed of as solvent waste.

Process efficiency: Process with efficient use of raw materials.

The appendix contains information which is not included in the factsheet but important for the scope description and the operational conditions such as dry process, indoor and outdoor⁴⁵ use, inclusion of equipment cleaning with organic solvents and waste disposal information as well as process efficiency; however the later contains the undefined term “efficient use of raw materials”

Include information from determinants in factsheet.

Define “efficient use”.

Clarify whether or not outdoor used is covered (either deletion here or inclusion in scope).

The description of the spERC’s coverage is not consistent. Some use descriptors apply to PROCs which don’t occur in other sections (synthesis and formulation, professional spraying). The enumeration of sectors and examples of processes in the spERC code and the scope description don’t

45 In the section „scope“, only indoor uses are mentioned

improve the understanding of the coverage. The narrative is repetitive without providing a picture of how the processes are carried out and what is relevant regarding environmental emissions. More clarity could be achieved by separating the factsheet either according to spERCs specifying ERC 4 and ERC 5 or according to the use sectors (this would also lead to a reduction of the number of possible application techniques per spERC).

In the “dummy CSR” developed and provided by ECHA (c.f. Section 0), it is specified in the section on technical and organisational measures that typical measures to reduce water emissions may include closed batch processing. This is confusing as many of the processes and uses specified in the scope cannot be conducted in this manner. It also slightly contradicts the specification that the process is dry (no waste water expected at all).