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Refractory Ceramic Fibres - Inclusion on REACH Annex XIV?

December 02, 2014

RCF products are indispensable in modern industrial high temperature processes due to their unique combination of thermal and physical characteristics. Any potential human health risk related to RCF use is limited to occupational
settings and no excess of respiratory disease has been observed in exposed workers after more than 60 years of production and use. There is no consumer exposure. RCF has been successfully substituted where technically and economically feasible. There are no viable substitutes for the remaining applications. The “non-use” of RCF could lead to a wide range of undesired socio-economic implications; negative impacts are expected in terms of environmental sustainability, competitiveness, employment, process safety and legal compliance with plant emission regulations.

Rather than causing environmental concerns, the use of RCF products is environmentally beneficial. Authorisation would fail to improve worker protection in down-stream operations as it can be circumvented via article imports. Detailed assessments of alternatives and socio-economic implications are essential elements of an application for authorisation and can only be done on a case-by-case basis. This would lead to an insurmountable number of applications for authorisation, effectively blocking ECHA´s committees for an extended period of time. Even if authorisations could be granted following a more generic approach, the uncertainty for long-term planning driven by short review periods (compared to the service life of the affected industrial installations; typically > 25 years) will have a negative impact on industrial investments in the EU.

In light of the fact that exposure to RCF occurs only in industrial environments, following the principle of regulatory effectiveness, the implementation of a sufficiently protective binding occupational exposure limit value (BOELV) is seen as a much more appropriate regulatory approach. This is fully in line with the 2020 SVHC roadmap process which, besides authorisation and restriction, supports “other regulation” where appropriate.

CECOF - together with all other relevant stakeholder associations - has worked on a joint industry position paper on the socio-economic implications.

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