During recent meetings in June, the Committee for Risk Assessment (RAC), which analyses the risk of substances to both human and environmental health, developed opinions on two different restriction proposals.


The first proposal concerned nonylphenol (NP) and nonylphenol ethoxylates (NPE) and the second 1-methyl-2-pyrrolidone commonly known as NMP. The Committee for Socioeconomic analysis (SEAC) however, has only come to an agreement concerning NPE and NP, with their comments on NMP due to be issued in September of this year.Both RAC and SEAC agreed with the Swedish proposal to restrict NPE if the total concentration of these substances is equal to or higher than 0.01% by weight in textile articles, or parts of articles, that can be washed in water. RAC determined that in order to minimise aquatic related risks from NPE as well as their degradation products, this afore mentioned restriction is a necessary EU-wide action that must be implemented. SEAC also agreed with this restriction and that it is both valid and proportionate. Both committees agreed that restriction of NPE in textile articles or parts of articles that are washed in water is essential, but that a restriction on NP in the same textile articles is neither necessary nor justified. This was based on results indicating that while NPE is intentionally added to textiles, the NP is not and is simply a residual product of NPE degradation. As a result a restriction on NPE will in itself eliminate any NP by-product from being produced. It is also interesting to note that in a recent EU directive, an EU Ecolabel is now being recognized for eco-friendly textile products. One important principle, however, in order for a textile to receive this label, is that is cannot be composed of any hazardous substances from the Annex XVII. This is particularly of interest as companies should be consciously substituting NPE in order to produce more eco-friendly textiles.
The second restriction proposal agreed upon by RAC was the Dutch proposal to limit both the manufacturing and use of NMP, a chemical commonly used as a solvent and cleaning agent in many different industries such as petrochemical, agricultural, and pharmaceutical. NMP is a known eye, skin, and possible respiratory irritant as well as harmful to prenatal development when present in high concentrations. RAC advised that manufacturers, importers, and downstream users who utilize NMP by itself or in a mixture with a concentration equal to or greater than 0.3% should adhere to a long-term Derived No Effect Level (DNEL) of 10 mg/m3 for inhalation and 4.8 mg/kg/day for dermal exposure in their chemical safety reports as well as noted on SDS for employee protection. By doing this they are establishing a restriction based around “exposure control” for inhalation and dermal, in essence proposing a community wide Occupational Exposure Level as the most effective EU-wide action to reduce the risks posed by the chemical.

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