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Implementation of the Detergent Regulation and market control of

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Implementation of the Detergent
Regulation and market control of
detergents in Finland
- tools and experiences
Jukka Ahtiainen and Birgit Kemiläinen
Finnish Environment Institute
Helsinki, Finland
Implementation of the Detergent Regulation and market control of detergents in Finland
Content
framework
 What to control?
 Tools for the control e.g. product registers
 Interface with REACH and other regulations
 Case study and experiences
24.9.2014
 Introduction to the Finnish regulatory
Implementation of the Detergent Regulation and market control of detergents in Finland
Introduction to the Finnish regulatory
framework
(CAs) for the enforcement of Detergent Regulation
• Finnish Environment Institute (SYKE) for environmental safety
under the Ministry of the Environment
• National Supervisory Authority for Welfare and Health (Valvira)
for the human health issues under the Ministry of Social Affairs
and Health
 2011 one CA at new “National Chemicals Agency”
24.9.2014
 Currently two separate competent authorities
Implementation of the Detergent Regulation and market control of detergents in Finland
What to control?
national legislation
 The main issues:
• Adequate mineralization of all the surfactants in detergent
products in the market (and possible derogations for
industrial use)
• What products are detergents?
• Proper packaging and labelling according to chemicals
legislation and the specific rules for the detergent
products (biocides, allergic irritants, INCI-names)
24.9.2014
 The regulation is implemented directly as
Implementation of the Detergent Regulation and market control of detergents in Finland
Surfactant mineralization criteria- reference
method OECD 310 or ISO 14593
 CO2-production measured and

compared toThCO2
Criteria: in 28 days 60%ThCO2
24.9.2014
 mineral media
 test substance only DOC
 inoculum (degraders)
Incubated in constant room
temperature in a shaker
Implementation of the Detergent Regulation and market control of detergents in Finland
Tools for the control
• There is an obligation on the companies to submit information
on dangerous chemicals in products (all uses)
• Information is submitted on chemicals that are classified as
dangerous to health or the environment or as causing fire and
explosion hazards.
• Information is also submitted on chemicals that are not
classified as dangerous but contain one or more substances
posing human health or environmental hazards, or a substance
for which there is a workplace exposure limit.
24.9.2014
 National Product Register of Chemicals
Implementation of the Detergent Regulation and market control of detergents in Finland
Tools for the control
• The information to be submitted is based on the safety
data sheet. The information in it is supplemented with the
CAS or EC numbers of the hazardous ingredients,
together with the classification of economic activities
(NACE) and the use category of the chemical.
• Information on the total quantities of hazardous chemicals
manufactured in and imported to Finland is annually
submitted to the Product Register.
24.9.2014
 What kind of information is submitted?
Implementation of the Detergent Regulation and market control of detergents in Finland
Tools for the control
• If there is a significant change in the information on the
chemical, revised information must be submitted to the
Product Register. Such changes may concern the trade
name, manufacturer/importer, composition and
information on ingredients, as well as new or revised
information on the hazards of the chemical.
24.9.2014
 Updating the registered data
Implementation of the Detergent Regulation and market control of detergents in Finland
Interface with REACH and other
regulations
data-no market) through registrations
 National guidance on the REACH enforcement
• The compliance with Detergent Regulation is included in the
guidance
• In practise the supervisory work has to be prioritized
towards certain product groups – specific products
 The local supervision is on the responsibility of
municipal environment authorities
24.9.2014
 Generally REACH will provide more data (no
Implementation of the Detergent Regulation and market control of detergents in Finland
Case study and experiences

products containing substances classified as R50/53, R51/53
or R52/53 indicating possible poor degradation
• Too many hits as all the ingredients were included (not just
detergents
Letter to the companies through The Finnish Cosmetic, Toiletry
and Detergent Association in order to remind them on the
deadline for the derogations (8th October 2007)
24.9.2014
 In August 2007 search from the product register for cleaning
Implementation of the Detergent Regulation and market control of detergents in Finland
Case study and experiences


more sell them “Berol 563” (quaternary coco alkylamine
ethoxylate) but according to them the same substance CAS
68989-03-7 was in one other product produced by the other
company Z
At the time Germany had submitted application for derogation
for “Berol 563”
New search for this substance in the detergents from the
product register
пѓ� 18 companies and 36 products were found
24.9.2014
 In 2008 one company X reported that their supplier would no
Implementation of the Detergent Regulation and market control of detergents in Finland
Case study and experiences
пѓ� The register contained old information and this was to be
updated
пѓ� 24 out of 36 products were OK
пѓ� 1 company claimed that the substance was not used as a
detergent in the product
пѓ� 2 companies claimed that the substance complied with the
regulation including degradation (no data was submitted)
пѓ� 2 companies did not respond at all
24.9.2014
 Direct letters with detailed questionnaire to these companies
Implementation of the Detergent Regulation and market control of detergents in Finland
 Germany withdraw the derogation for Berol 536
 Company Z updated their register data claiming that the
products did not contain the substance any more
пѓ� Hopefully the companies got more educated on the new
detergent regulation, and this also affected to the product
composition and updating the product register
24.9.2014
Case study and experiences
Implementation of the Detergent Regulation and market control of detergents in Finland
Case study and experiences
• The Products Register information is based on the self
classification by manufacturers
• The claims for biodegradability should be supported by
hard data (e.g. robust study summary)
• The CA resources (total 5 months work/year) for the
supervision are very limited
24.9.2014
 Conclusions on difficulties
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