Limitation of use as a result of receiving this ES:

 

The following points set limits that an on-site health and safety assessor could use to determine safe working practices and environmental control if receiving this example ES.

 

 

If any of these conditions are not met, re-calculations are needed.  For example, if only 100 kg/day used, the waste water pre-treatment may not be necessary if the concentration is re-calculated to be lower that concentrations causing concern.  If workers are only handling for 1 hour maximum per shift, or at less than 40 C, less effective LEV may be suitable. 

 

These local decisions need to be made by the local management at the point of use; the supplier cannot be expected to know every last detail of the user’s factory.

This is for a generic, moderately volatile and biodegradable substance that is severely irritating

to skin and eyes, but limited systemic toxicity.

 

ES1 Use of [substance] in formulation activities

 

 

Exposure Scenario Format - Industrial

(Identified use 1)

Formulation of personal care products

Processes involving dilution of the substance in water, with other auxiliary components.  The process is typically under ambient temperatures and in closed containers, with exposure only likely during charging of mixing vessels, sampling for laboratory quality control testing and for discharge of completed mixture to containers for onward supply.

Cleaning and servicing activities are considered in ES 2

 

2. Operational conditions and risk management measures

Human Health

Involved PROCs

Description

Involved tasks

PROC 5

Mixing or blending in a batch process

Raw material handling, including discharge from containers [specify types of container]

PROC 8a, 8b

Transfer of chemicals

Raw material handling, including discharge from containers and transfer of products.  Open, closed, dedicated or non-dedicated facilities. Cleaning and maintenance operations.  

Environment (industrial)

 

Name

Description

Level of containment

Indoor/outdoor

ERC 2

Industrial use of substance, including formulating activities

Use in open/closed systems.

 

Indoor  use

Default 2% loss to waste water

Table R.16-23

2.1 Control of workers exposure

Product characteristic

Received as technical grade substance

Mixed with water and other substances to make liquid or cream products.

Note: characteristics of other components may influence exposure.

Covers percentage substance in the final product up to 25 %

Amounts used

Daily use maximum 1000 kg, total 100 t per annum, 100 days  

 

Frequency and duration of use/exposure

Raw material handling limited to 4 hours per day per person

Maximum shift duration on any other process up to 8 hours

Operational conditions affecting workers exposure

Indoor  handling in confined spaces 

Use at temperatures up to 40oC during handling, mixing and bottling process

Technical conditions and measures at process level (source) to prevent release

Storage of substance is in closed containers kept in dedicated areas, including iso-tanks and plastic chemical drums 25 - 200 litres.

Stored cool at < 30 C to avoid volatilisation, using air conditioning if required, with forced ventilation to prevent build up of fumes indoors.

 

Technical conditions and measures to control dispersion from source towards the worker

Local exhaust ventilation with 90% effectiveness  should be used at points of breaching of containers.  For indoor handling and use, provide good ventilation or forces extraction, providing up to 1 air exchange per hour.  

Organisational measures to prevent /limit releases, dispersion and exposure

Established management systems would include general industrial hygiene practice e.g.:

·         information and training of workers on prevention of exposure/accidents,

  • procedures for control of personal exposure (hygiene measures)

  • regular cleaning of equipment and floors, extended workers instruction-manuals

  • procedures for process control and maintenance,

·         personal protection measures (see below)

Conditions and measures related to personal protection, hygiene and health evaluation

Controls will provide 90% minimum reduction in exposure to workers, when handling raw materials and involved in mixing operations.   These will include gloves and coveralls:

·          [check gloves for type of substance, break-through times etc]

·         Following materials are unsuitable for protective gloves:
Natural rubber/Natural latex – NR

 

For handling a solution containing maximum 25% solution of  [product]

·         [check gloves for type of substance, break-through times etc]

·         Following materials are unsuitable for protective gloves:
Natural rubber/Natural latex – NR

 

Note, under certain working conditions, the physical properties of the glove may be necessary to consider to prevent excessive wear on the glove.  Coveralls need to be changed and washed at the end of each shift, or after significant contamination.

 

With normal handling, no respiratory personal protection (breathing apparatus) is necessary. If risk vapour generation, use respiratory protection: Gas filter A, Colour code brown. [check for specific types for substance]

Eye protection should be worn by workers handling the product.

 

 

 

2.2 Control of environmental exposure

 

Product characteristics

Substance is [describe] under ambient temperatures

Formulated products are non-viscous / slightly viscous liquids, containing water with maximum concentration of 25% of the substance.

 

Amounts used

The scenarios are based on maximum 100 t use of the substance, with formulation and packaging activity 100 days per annum; 1000 kg/day maximum

Environment factors not influenced by risk management 

Aqueous waste, from cleaning activities

 

 

Technical onsite conditions and measures to reduce or limit discharges, air emissions and releases to  soil  

Any drainage or washings, including collection of spilled material must be collected for disposal either as hazardous waste or as waste water after checking in relation to local discharge consents.  Assumed maximum loss to waste water based on ERC 2 2% [table R.16-23]

20 kg/day to waste water maximum

 

No specific controls for extract ventilation required.

Atmospheric loss from extract ventilation default 2.5% [table R.16-23]

25 kg/day to air maximum

 

 

Conditions and measures related to external treatment of waste for disposal

Ensure that waste water is conditioned for at least 30 minutes before discharge to waste water treatment.  Ideally, pre-treatment should be at least 3 hours.

Defaults used based on EUSES 2.1 :

Maximum permitted 20 kg discharge per day to waste water treatment

Water discharge 100 m3 / day

Local treatment works 2000 m3/day

Degradation 87% (SimpleTreat for readily biodegradable/degradable)

Partition to water 13% (SimpleTreat, water soluble, low vapour pressure)

Final dilution factor 10 (default surface water)

 

No assumptions or controls on ventilation loss to air

3 Exposure estimation 

Workers: [Table R14-5 and 14.6TRA]

Estimated atmospheric concentration for low volatile, with LEV [17 mg/m3product]

Reduction required by > 92% through use of respirator to <  1.4 mg/m3for full 8 hour shift.

 

Atmospheric concentration maximum exposure 3 mg/m3 1- 4 hour working period

Atmospheric concentration maximum exposure 1.4 mg/m3 over 8 hour working period

 

 Long term DNEL inhalation local 1.4 mg/m3

Short term DNEL inhalation local 3 mg/m3

 

Estimate dermal contact, hands and face, low volatile liquid with LEV 0.07 mg/kg/day

 

Dermal exposure must not exceed 0.17 mg/kg/day

Long term DNEL dermal estimated to be 0.17 mg/kg/day, assuming 100% dermal penetration

Environment:

Default scenario of 2% to waste water, 20 kg/day discharge to STP, in 100 m3 / day waste water (20 g/l)

3 hour minimum biological pre-treatment at 20 g/l in waste water, loss of 90% concentration, 2 g/l remaining

Local STP volume 2000 m3/day

Local PEC STP 1 mg/l

PNECs STP 10 mg/l (after at least 30 minutes pre-conditioning exposure)

 

Loss in STP 87% and final dilution to surface water, factor 10

Local freshwater PEC estimated to be 0.013 mg/l

PNEC freshwater determined to be 0.013 mg/l

4. Guidance to DU to evaluate whether boundaries set by the ES are being met

The DU works inside the boundaries set by the ES if either the proposed risk management measures as described above are met or the downstream user can demonstrate on his own that his implemented risk management measures are adequate.

 

 

Denehurst Chemical Safety Ltd

Example Exposure Scenario format

It is important to note that the precise format and content of the Exposure Scenario (ES) is not mandated in any legal text.  Guidance provides examples and the format for use in industrial or non-industrial settings or for us by the consumer may need to vary to best suit communication requirements.  The example below is based on ECHA guidance, but can be adapted to best suit individual needs.

 

The quality of the content is much more important than the format

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