Health & safety / Respirable Crystalline Silica :

Respirable Crystalline Silica

In brief

Crystalline silica is an essential component in a multitude of materials used in industrial production and life. Respirable crystalline silica (RCS) is the respirable dust fraction of crystalline silica which enters the body by inhalation. Although crystalline silica is ubiquitous in nature, the inhalation of RCS may constitute a hazard to workers. Currently, there is no harmonized European binding Occupational Exposure Limit (BOEL) for RCS exposure. However, most European Member States have already set national RCS OEL values. The European Commission issued a proposal on 13 May 2016 to include work related exposure to RCS dust under the Carcinogens and Mutagens Directive. It recommends the establishment of a binding OEL of 0.1 mg/m³. The European Parliament's Employment Committee has voted the Ulvskog draft report which proposes a RCS BOELV of 0.05 mg/m3, with a transition value of 0.1 mg/m3 until 10 years after entry into force - to be reviewed 5 years after entry into force. The trilogue between the European Parliament, the Council and Commission is expected to start mid-March 2017.

Our view

CEMBUREAU is a NEPSI Social Dialogue Agreement (SDA) partner, and continues to advocate strongly in favour of formal recognition of the work undertaken by NEPSI under the CMD. The reason for this is that, through the NEPSI Social Dialogue Agreement (SDA), a comprehensive set of guidance and assessments that address the minimisation obligations have been developed, taking into account the wide diversity of industrial circumstances and the best ways to address them with specific sectoral expertise. As such, the SDA is complementary to the general requirements of the Directive and, by following the NEPSI Guidance, the signatories implement these requirements in an informed and tailored way. 

The latest NEPSI reporting year was 2016. CEMBUREAU is proud to report that, thanks to the efforts of its members, 100% reporting of the identified sites has been achieved, and 97.4% of employees potentially exposed to Respirable Crystalline Silica (RCS) are covered by a risk assessment and an improvement was seen in relation to all Key Performance Indicators (KPI).

Health & safety / REACH & CLP :

REACH & CLP

In brief

When it comes to health and safety and communicating with downstream users, the most relevant legislative texts are as follows:

  • REACH (Registration, Evaluation, Authorisation and Restrictions of Chemical substances), the role of which is to improve the protection of human health and the environment from the risks that can be posed by chemicals.  Under REACH, every substance manufactured or imported in the EU above 1 tonne must be registered by the entity that imports or manufactures it, unless it is exempt from registration. Furthermore, there is an obligation to communicate upstream (towards suppliers) and downstream (to customers) on substances by means of Safety Data Sheets (SDS) and chemical safety reports as the case may be. As defined by REACH, SDS are the key tool for hazard and risk management communication in the supply chain.
  • Classification, Labelling & Packaging (CLP) Regulation, which harmonises requirements concerning the classification, labelling and packaging of chemical substances and mixtures in line with the Globally Harmonized System of Classification and Labelling of Chemicals (GHS) approved by the United Nations.

Our view

Clinker is a substance and is thus exempt from REACH registration. Nevertheless, it must be classified and labelled and a Safety Data Sheet (SDS) must be provided, if it is placed on the market, and this C&L has been notified to the European Chemicals Agency.   Cement is a preparation and is therefore also not subject to REACH registration, although it must also be classified and labelled. Nevertheless, because it is a preparation, no C&L notification to ECHA is necessary. An SDS, possibly with an exposure scenario, must be provided.  In terms of CLP, please refer to image for classification used by all CEMBUREAU members, for Portland cement clinker and common cements. 

Furthermore, CEMBUREAU has prepared safety data sheet templates for its Members (covering both “Portland cement clinker” and “Common cements”) which take into account the REACH requirements.