CHEMICAL SAFETY REPORT - Europa

CHEMICAL SAFETY REPORT

Substance Name: trichloroethylene

EC Number: 201-167-4

CAS Number: 79-01-6

Applicants´ Identities: RAG Aktiengesellschaft, RAG Anthrazit Ibbenbüren GmbH

Use number: 1

EC number:

201-167-4

Trichloroethylene CAS number:

79-01-6

CHEMICAL SAFETY REPORT ii

Table of Contents

9. EXPOSURE ASSESSMENT (and related risk characterisation) ................................................................... 3 9.0. Introduction ............................................................................................................................................. 3

9.0.1. Overview of uses and Exposure Scenarios ....................................................................................... 3 9.0.2. Introduction to the assessment .......................................................................................................... 5

9.0.2.1. Environment .............................................................................................................................. 5 9.0.2.2. Man via environment ................................................................................................................. 6 9.0.2.3. Workers...................................................................................................................................... 6 9.0.2.4. Consumers ................................................................................................................................. 8

9.1. Exposure scenario 1: Use at industrial site – RAG – conveyor belt splicing and repair .......................... 8 9.1.1. Environmental contributing scenario 1: RAG – conveyor belt splicing and repair .......................... 8

9.1.1.1. Conditions of use ....................................................................................................................... 8 9.1.1.2. Releases ..................................................................................................................................... 9 9.1.1.3. Exposure and risks for the environment and man via the environment ..................................... 9

9.1.2. Worker contributing scenario 1: Hot vulcanization (PROC 10) ..................................................... 10 9.1.2.1. Conditions of use ..................................................................................................................... 10 9.1.2.2. Exposure and risks for workers ................................................................................................ 12

9.1.3. Worker contributing scenario 2: Cold vulcanistaion (PROC 10).................................................... 15 9.1.3.1. Conditions of use ..................................................................................................................... 15 9.1.3.2. Exposure and risks for workers ................................................................................................ 16

10. RISK CHARACTERISATION RELATED TO COMBINED EXPOSURE ............................................. 17 10.1. Human health ....................................................................................................................................... 17

10.1.1. Workers ........................................................................................................................................ 17 10.1.2. Consumer ...................................................................................................................................... 17

10.2. Environment (combined for all emission sources) .............................................................................. 17 10.2.1. All uses (regional scale) ................................................................................................................ 17

10.2.1.1. Total releases ......................................................................................................................... 17 10.2.1.2. Regional exposure .................................................................................................................. 17

10.2.2. Local exposure due to all wide dispersive uses ............................................................................ 18 10.2.3. Local exposure due to combined uses at a site ............................................................................. 18

REFERENCES ..................................................................................................................................................... 19

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CHEMICAL SAFETY REPORT 3

9. EXPOSURE ASSESSMENT (and related risk

characterisation)

9.0. Introduction

9.0.1. Overview of uses and Exposure Scenarios

General methodology of ES for RAG

RAG runs two hard coal mines in Germany: Prosper-Haniel (PH) and Auguste Victoria (AV). RAG Anthranzit

Ibbenbüren GmbH (an affiliate of RAG, own legal entity) runs the mine in Ibbenbüren (IB). At these mines,

different volumes of TRI are consumed per activity. The exposure assessment for workers and the local

environment is based on worst-case assumptions, utilising data from the mine with highest usage volume per

activity. For the regional exposure assessment all point sources of TRI, the three mines together, are taken into

account.

Process description

Splicing and repairing of endless belts in hard coal mines are conducted using vulcanising agents containing

trichloroethylene. Hot vulcanisation is done for splicing the belts. Cold “vulcanisation” is more precisely

described as a gluing process instead of being a vulcanisation. The activities are performed underground. The TRI

based products used are purchased from suppliers in sealed metal containers, which are stored in either

aboveground on site (never underground) or in a central storage which delivers the products to the sites upon

request. Containers which have been opened once are disposed of in compliance with European and national

waste regulations. Material and equipment (PPE or tools) used during handling of trichloroethylene containing

products is packed and sealed in plastic bags immediately after use and is also disposed of in compliance with

European and national waste regulations. As exposure of workers or releases to the environment during storage of

sealed containers can be excluded, no contributing scenario for storage is required. There are also no maintenance

activities resulting in releases of TRI.

The whole splicing activity for hot vulcanisation (contributing scenario 1) can be divided into the following steps:

Tailoring of the belt: Depending on the type of the belt and the type of joint to be made, the endings of the

belt are tailored. For instance, the cover is removed until the steel cords appear (steel cord belt) or finger

splices are cut (textile belts, see Figure 1). Subsequently, the parts to be spliced, e.g. the finger splices or

steel cords, are roughened by a handheld grinder. The parts are cleaned mechanically using a vacuum

cleaner.

Preparing for vulcanisation: The TRI-product is spread over the parts to be spliced (steel cords, finger

endings) in thin layers and left for drying purposes for 15 minutes (heating solution) or 30 min for

assembly solution, respectively. After drying, an unvulcanised rubber piece is placed properly when

necessary, e.g. for splicing steel cord belts. During the drying time, employees leave the working area.

Vulcanisation: Afterwards, the parts to be jointed are put together and vulcanised by a heating press at

150 °C and 12 bar. The temperature is held constant for one hour before a cooling period of 2 hours

follows.

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Figure 1: Finger splices of two endings of a ContiTan two ply textile belt.

Cold bonding (contributing scenario 2) is conducted in the following manner:

The damaged part of the belt is pre-cleaned with a broom before it is brushed and roughened with an

angle grinder. The TRI-product plus a hardener is spread on the roughened part using a brush and dried

for 30 minutes. This procedure is repeated one time. Afterwards, the glue is spread on a rubber stripe and

the roughened part of the belt, and pressed together with a tape roller. Drying for 15 minutes follows. The

repaired part is then polished to a smooth surface with an angle grinder with grinding attachment.

General operation conditions

The following good basic standard of occupational hygiene is implemented for all contributing scenarios:

Avoid direct contact with the substance or product;

Wear gloves (tested to EN374, WNR 4043261 or 4043359) if direct hand contact with the substance is

likely; wash off skin contamination immediately;

Wear protective gloves, impervious suits and suitable eye protection at all times when handling the

substance or product;

Avoid splashes and spills;

Avoid contact with contaminated tools and objects;

Clean up contamination/spills as soon as they occur;

Ensure suitable management/supervision is in place to check that the RMMs OCs are followed correctly;

Train staff on good practice to prevent/minimise exposures and to report any problems that may develop;

Adopt good standards of personal hygiene.

Qualitative assessment of risk from eye irritation

Protection against the risks of eye irritation is adequately ensured by the following RMMs:

Use suitable eye protection.

Avoid direct eye contact with product, also via contamination on hands.

Qualitative assessment of risk from skin irritation and sensitization

Protection against the risks of skin irritation and sensitisation (weak sensitizer) is adequately ensured by the

following RMMs:

Avoid direct skin contact with product

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Identify potential areas for indirect skin contact

Wear gloves (tested to EN374) if direct hand contact with substance likely

Clean up contamination/spills as soon as they occur

Wash off skin contamination immediately

Provide basic employee training to prevent/minimise exposures and to report any skin effects that may

develop.

Tonnage information:

Assessed tonnage: 1.4 tonnes/year based on: Applicant’s information on the product volume used.

The following table list all the exposure scenarios (ES) assessed in this CSR.

Table 1. Overview of exposure scenarios and contributing scenarios

Identifiers Market

Sector

Titles of exposure scenarios and the related contributing

scenarios

Tonnage

(tonnes

per year)

ES1 - IW1 Use at industrial site - RAG - conveyor belt splicing and repair

- RAG - conveyor belt splicing and repair (ERC 4)

- Hot vulcanisation (PROC 10)

- Cold bonding (PROC 10)

1.4

Manufacture: M-#, Formulation: F-#, Industrial end use at site: IW-#, Professional end use: PW-#,

Consumer end use: C-#, Service life (by workers in industrial site): SL-IW-#, Service life (by professional

workers): SL-PW-#, Service life (by consumers): SL-C-#.)

9.0.2. Introduction to the assessment

9.0.2.1. Environment

Scope and type of assessment

The scope of exposure assessment and type of risk characterisation required for the environment are described in

the following table based on the hazard conclusions presented in section 7.

Table 2. Type of risk characterisation required for the environment

Protection target Type of risk characterisation Hazard conclusion (see section 7)

Freshwater Not needed Not needed

Sediment (freshwater) Not needed Not needed

Marine water Not needed Not needed

Sediment (marine water) Not needed Not needed

Sewage treatment plant Not needed Not needed

Air Not needed Not needed

Agricultural soil Not needed Not needed

Predator Not needed Not needed

Comments on assessment approach:

The regional concentrations are reported in section 10.2.1.2 (see Table 11, “Predicted regional exposure

concentrations (Regional PEC)”). The local Predicted Exposure Concentrations (PECs) reported for each

contributing scenario correspond to the sum of the local concentrations (Clocal) and the regional concentrations

(PEC regional).

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The current CSR and the associated exposure scenario are tailored to supporting the application for authorisation

of TRI for its use in vulcanisation agents in underground mining at RAG AG and RAG Antharazit Ibbenbührebn

GmbH. TRI has been proposed for inclusion into Annex XIV of the REACH Regulation (the list of substances

subject to authorisation) due to its intrinsic properties as being carcinogenic (classification as carc 1B). Following

Regulation (EC) No 1907/2006, Article 62(4)(d) the CSR supporting an application for authorisation needs to

cover only those risks arising from the intrinsic properties specified in Annex XIV. Accordingly, only the human

health risks related to the classification of TRI as a carcinogenic substance are considered in the current CSR. The

dominating health effect resulting from the intrinsic hazardous properties of TRI is renal cancer following

inhalation of gaseous airborne residues and systemic uptake. Evaluation of any potential hazards to the

environment is not required within the framework of this authorisation application. Health hazards, however, may

potentially also arise due to exposure of the general population via the environment. For the assessment of the

risks to the general population emissions to the environment are modelled using standard assessment tools

(Chesar/EUSES).

9.0.2.2. Man via environment


The scope of exposure assessment and type of risk characterisation required for man via the environment are

described in the following table based on the hazard conclusions reported and justified in section 5.11.

Table 3. Type of risk characterisation required for man via the environment

Route of exposure and type

of effects

Type of risk

characterisation

Hazard conclusion (see RAC/28/2014/07 rev 2)

Inhalation: Systemic Long

Term

Semi-quantitative Renal cancer:

At 6.2 mg/m³ and above:

Excess risk = 6.9 × 10−4

(mg/m³)−1

× concentration

(mg/m³) − 0.0039

Below 6.2 mg/m³:


(mg/m³)−1

× concentration

(mg/m³)

Oral: Systemic Long Term Semi-quantitative Renal cancer:

At 0.92 mg/kg bw/d and above:


(mg/kg bw/d)−1

× dose

(mg/kg bw/d) – 0.0039

Below 0.92 mg/kg bw/d:


(mg/kg bw/d)−1

× dose

(mg/kg bw/d)

Comments on assessment approach:

With reference to section 9.0.2.1 above humans may potentially be exposed to TRI via the environment. Due to

the use in underground mines only, concentrations in aboveground air are considered to be negligible. Releases to

water, are also insignificant due to use in underground mines niot resulting in wastewater. Nevertheless,

distribution in the environment and concentrations relevant for secondary exposure of humans were calculated

using conventional algorithms (Chesar/EUSES).

9.0.2.3. Workers


The scope of exposure assessment and type of risk characterisation required for workers are described in the

following table based on the hazard conclusions presented document RAC/28/2014/07 rev 2.

Detailed information on the approach taken for the exposure assessment and justifications for tools used as well as

PROCs chosen for the single worker contributing scenarios is provided in the introduction chapter of the ES.

The exposure levels provided in the worker contributing scenarios are given as task-specific exposure durations,

most of which cover a significantly shorter period than a full shift (8 hours) or are performed less frequently than

every working day. Dose response curves published by ECHA, however, are calculated for 8 h exposure 5 days a

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week (240 days a year) (RAC/28/2014/07 rev 2).

When calculating the excess risk due to inhalation or dermal exposure for the contributing scenarios correction

factors have been used to account for the duration of activities (contributing scenarios) during an 8 hour working

day. In the following, this factor is named factor A. As the ECETOC TRA tool calculates an 8 h TWA exposure,

taking into account that the respective activity is carried out a certain time, e.g. 15 minutes, factor A is always 8 h

TWA/ 8 h = 1.

Secondly, the excess risk has been calculated, accounting for the frequency of an activity, e.g. for an activity with

a frequency of once per month an additional correction factor of 0.05 has been used (12 days/ 240 days per year).

In the following, this factor is named factor B.

No other correction factors were used to account for yearly exposure to life time exposure duration for each of the

contributing scenarios. Therefore this approach represents a worst-case of the excess risk on kidney cancer due to

exposure to trichloroethylene at RAG AG and RAG Anthrazit Ibbenbüren GmbH..

The scope of exposure assessment and type of risk characterisation required for workers are described in the

following table based on the hazard conclusions presented in section 5.11.

Table 4. Type of risk characterisation required for workers

Route Type of effect Type of risk

characterisation

Hazard conclusion (see RAC/28/2014/07 rev 2)

Inhalation

Systemic Long

Term


At 33 mg/m³ and above:


(mg/m³)−1

× concentration

(mg/m³) − 0.0039

Below 33 mg/m³:


(mg/m³)−1

× concentration

(mg/m³)

Systemic Acute Not needed –

Local Long

Term

Not needed –

Local Acute Not needed –

Dermal

Systemic Long

Term


At 4.72 mg/kg bw/d and above:


(mg/kg bw/d)−1

× dose

(mg/kg bw/d) – 0.0039

Below 4.72 mg/kg bw/d:


(mg/kg bw/d)−1

× dose (mg/kg

bw/d)

Systemic Acute Not needed –

Local Long

Term

Not needed –

Local Acute Not needed –

Eye Local Not needed –

Comments on assessment approach related to toxicological hazard:

TRI has been included into Annex XIV of the REACH Regulation (the list of substances subject to authorisation)

due to its intrinsic properties as being carcinogenic (classification as carc 1B). As a semi-volatile solvent,

exposure via inhalation and by dermal contact to liquid residues may be relevant and are therefore considered in

this CSR.

Comments on assessment approach related to physicochemical hazard:

Not relevant – physicochemical hazards are not subject of this chemical safety report.

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General information on risk management related to toxicological hazard:

Skin protection and respiratory protective equipment (RPE) may be necessary depending on the level of contact.

Details are given in the respective contributing scenarios.

General information on risk management related to physicochemical hazard:

Not relevant.

9.0.2.4. Consumers

Exposure assessment is not applicable as there are no consumer-related uses for the substance.

9.1. Exposure scenario 1: Use at industrial site – RAG – conveyor belt

splicing and repair

Sector of use: SU 2a, Mining, (without offshore industries)

Environment contributing scenario(s):

RAG - conveyor belt splicing and repair ERC 4

Worker contributing scenario(s):

Hot vulcanisation PROC 10

Cold bonding PROC 10

Description of the activities and technical processes covered in the exposure scenario:

The activities entailing handling of trichloroethylene-containing products are described in detail in section 9.0

above.

9.1.1. Environmental contributing scenario 1: RAG – conveyor belt splicing and repair

9.1.1.1. Conditions of use

The cumulative quantity of TRI consumed for conveyor belt splicing (hot vulcanisation) and repair (cold bonding)

at all affected RAG sites is assumed to be at maximum 1.37 tonnes per year. RAG has forecasted the number of

splicing operations (hot vulcanisation) in 2014 to be 23 in total (21 in IB, 2 in PH and 0 in AV), i.e. approximately

twice per month. Repair operations (cold bondings) are performed approximately 6 times a week, so 312 days per

year at each site (equal to 936 repair activities in all three sites in total). The quantity of trichloroethylene

containing adhesive used per event is 1 kg or at maximum 2.5 kg (due to the size of product containers). At the

three assessed sites different quantities of vulcanisation agents are used annually: At Prosper-Haniel 503 kg are

used (expressed as trichloroethylene), at Auguste Victoria 61 kg, and in Ibbenbüren 806 kg per year (figures from

2013, decreasing in the future for the reasons explained in section 9.0). The total amount for the assessed use at

RAG sites is hence 1.37 t/a (assessed tonnage). The maximum figure from the three sites (806 kg) is adopted as the

worst case for the local environmental assessment (0.81 t, rounded).

Amount used, frequency and duration of use (or from service life)

• Daily use at site: <= 0.002 tonnes/day

The maximim annual tonnage (worst-case) for a given site is 0.81 t/a (rounded, see above). The number of

working days is 333. Accordingly, the amount used per day is calculated to be 0.0025 tonnes (rounded). This is

consistent with the aforementioned statement that the amount used per day varies between 1.0 and 2.5 kg.

• Annual use at a site: <= 0.81 tonnes/year

• Percentage of EU tonnage used at regional scale: = 100 %

Conditions and measures related to sewage treatment plant

• Municipal STP: Yes [Effectiveness Water: 100%]

• Discharge rate of STP: >= 2E3 m3/d

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• Application of the STP sludge on agricultural soil: Yes

Conditions and measures related to treatment of waste (including article waste)

• Particular considerations on the waste treatment operations: No (low risk) (ERC based assessment

demonstrating control of risk with default conditions. Low risk assumed for waste life stage. Waste disposal

according to national/local legislation is sufficient.)

Other conditions affecting environmental exposure

• Receiving surface water flow rate: >= 1.8E4 m3/d

9.1.1.2. Releases

The local releases to the environment are reported in the following table.

Table 5. Local releases to the environment

Release Release factor estimation

method

Explanation / Justification

Water Release factor Initial release factor: 0%

Final release factor: 0%

Local release rate: 0 kg/day

Explanation / Justification: For obvious reasons there are no

releases to wastewater from the assessed use: The cleaners and

adhesive agents used in splicing and repair of conveyor belts are

applied directly to the material to be treated. TRI evaporates from

the rubber surfaces within the process-specific drying time of

15-30 minutes. The repair facilities are located underground in coal

mines. The evaporated TRI is emitted via the natural ventilation of

the mining shafts. Accordingly, releases to water bodies (including

wastewater) are zero, whereas 100 % of the applied TRI is released

to air.

Air ERC based Initial release factor: 100%

Final release factor: 100%

Local release rate: 2 kg/day

Soil ERC based Final release factor: 5%

9.1.1.3. Exposure and risks for the environment and man via the environment

The exposure concentrations and risk characterisation ratios are reported in the following table.

Table 6. Exposure concentrations and risks for the environment

Protection target Exposure concentration Risk characterisation

Freshwater Local PEC: 6.148E-9 mg/L Not required

Sediment (freshwater) Local PEC: 1.088E-7 mg/kg dw Not required

Marine water Local PEC: 5.381E-10 mg/L Not required

Sediment (marine water) Local PEC: 9.525E-9 mg/kg dw Not required

Predator (freshwater) Local PEC: 1.045E-7 mg/kg ww Not required

Predator (marine water) Local PEC: 9.148E-9 mg/kg ww Not required

Top predator (marine water) Local PEC: 9.148E-9 mg/kg ww Not required

Sewage treatment plant Local PEC: 0 mg/L Not required

Agricultural soil Local PEC: 7.286E-5 mg/kg dw Not required

Predator (terrestrial) Local PEC: 5.697E-5 mg/kg ww Not required

Man via Environment -

Inhalation

Local PEC: 6.17E-4 mg/m³ Excess risk: 3.95E-08

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Protection target Exposure concentration Risk characterisation

Man via Environment - oral Local PEC: 1.493E-06 mg/kg bw Excess risk: 6.45E-10

Man via environment -

combined routes

Excess risk: 4.01E-08

Table 7. Contribution to oral intake for man via the environment from local contribution

Type of food Estimated daily dose Concentration in food

Drinking water 6.963E-7 mg/kg bw/day 2.437E-5 mg/L

Fish 1.717E-10 mg/kg bw/day 1.045E-7 mg/kg ww

Leaf crops 1.814E-7 mg/kg bw/day 1.058E-5 mg/kg ww

Root crops 6.078E-7 mg/kg bw/day 1.108E-4 mg/kg ww

Meat 2.831E-9 mg/kg bw/day 6.585E-7 mg/kg ww

Milk 4.925E-9 mg/kg bw/day 6.145E-7 mg/kg ww

Conclusion on risk characterisation

The emission estimation is based on an worst case site-related maximum tonnage of 0.8 t/a (see above) consumed

for conveyor belt splicing and repair operations at RAG coal mines. Exposure of the general population via the

oral route is insignificant since there are no releases of TRI to water or soil from the assessed use hence any

relevant exposure via the food chain can be safely excluded.

Taking into account the operational conditions under which TRI is used, the RMMs implemented, and the volume

of TRI used, it can be concluded that risks resulting from exposure of man via the environment are minimized and

no additional measures are required.

9.1.2. Worker contributing scenario 1: Hot vulcanization (PROC 10)


The adhesives (termed "heating solution" at the site PH, and "assembly solution" at the site IB) are spread on the

conveyor belt joints to be spliced (steel cords, finger endings) as a thin layer and left to dry for 15 minutes (heating

solution) or 30 min (assembly solution), respectively. After drying, an unvulcanised rubber piece is placed on the

bond if necessary, e.g. for splicing steel cord belts. During drying time, the employees leave the working area

hence exposure is restricted to the short period of applying the adhesive solution by brushing. After drying, the

parts to be joined are assembled and vulcanised in a heating press at 150 °C and 12 bar. However, there is no

potential for exposure to TRI during the joining and heating process since TRI is completely removed from the

treated surfaces during drying. Therefore, the entire hot vulcanisation task and the associated exposure potential

are adequately described by PROC 10. During the whole procedure, no workers are allowed to enter the safety

area closer than 40 m to the operating location (in wind direction). For general safety reasons air streams are

continuously monitored, ensuring that the ventilation rate is on average > 3000 m³/min.

Ventilation underground

The following air streams were measured at each mine:

Table 8: Ventilation in mines

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Ventilation rate [m³/min]

Mine (year) Prosper-Haniel (2013) Auguste Victoria (2014) Ibbenbüren (2013)

1170 3342 3174

2604 3702 3174

684 5376

5982

1782

1254

7716

690

3282

4038

3666

Average 3227

In the case that a splicing activity cannot be conducted on the air supply side, additional venting systems need to

be installed. Air supply is continuously measured and air streams are monitored centrally. Masks (filter type A)

are used at any time during TRI handling. The length of the place where TRI is used the tunnels must not exceed

10 meters.

Method

Product (article) characteristics

• Concentration of substance in mixture: Substance as such

According to the manufacturers of the used adhesive agents contain TRI in a range

between 70 and 90 % hence exposure to the "substance as such" needs to be

assumed in the exposure scenario.

TRA Worker v3

Amount used (or contained in articles), frequency and duration of use/exposure

• Duration of activity: < 4 hour

Preparing the tail ends of conveyor belts with "heating solution" or "assembly

solution" is limited to a surface area of approximately 1-2 m² and is done within less

than 1 hour.

TRA Worker v3

Technical and organisational conditions and measures

• General ventilation: Enhanced general ventilation (5-10 air changes per hour)

Conveyor belt splicing takes place in coal mines (underground), which are

characterised by forced ventilation. Air change rates in reality are substantially

higher than the maximum ventilation rate provided by ECETOC TRA. Therefore, the

model still represents a worst case.

TRA Worker v3

• Containment: No TRA Worker v3

• Local exhaust ventilation: no [Effectiveness Inhal: 0%] TRA Worker v3

• Occupational Health and Safety Management System: Advanced TRA Worker v3

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

• Dermal Protection: Yes (chemically resistant gloves conforming to EN374 with

basic employee training) [Effectiveness Dermal: 90%]

Protective gloves resistant to TRI (WNR 4043261 or 4043359) are prescribed for

workers performing splicing and repair tasks. Personnel are specifically trained for

this type of work, including adequate use of protective gloves.

TRA Worker v3

• Respiratory Protection: Yes (Respirator with APF of 20) [Effectiveness Inhal:

95%]

TRA Worker v3

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Method

With the default maximum ventilation rate permitted by the ECETOC TRA model the

use of an appropriate filter mask (ABEK, type A) is required.

Other conditions affecting workers exposure

• Place of use: Indoor TRA Worker v3

• Process temperature (for liquid): <= 40 °C TRA Worker v3

• Skin surface potentially exposed: Two hands (960 cm2) TRA Worker v3

9.1.2.2. Exposure and risks for workers

The exposure concentrations and risk characterisation are reported in the following table.

Table 9. Exposure concentrations and risks for workers

Route of exposure

and type of effects

Exposure concentration Factor A to adjust

time of exposure to

8 h

Factor B to adjust

work days (240

days to xy days of

exposure)

Excess risk

Inhalation,

systemic, long-term

2.464 mg/m³ (TRA

Worker v3)

Additional data not used

for risk characterisation:

4.78 mg/m³ (Measured

HH)

1* 4.58E-02**

9.03E-07

Dermal, systemic,

long-term

0.549 mg/kg bw/day (TRA

Worker v3)

1* 4.58E-02**

2.11E-06

Combined routes,

systemic, long-term

3.02E-06

* Calculated concentration for 8 h taking an exposure of 15 minutes as basis (Factor A=8 h/ 8 h) ** Activity takes place maximum 11 days a

year (Factor B = 11 days/240 days)

Remarks on exposure data

Measured HH

Inhalation, systemic, long-term:

Number of measured data points: 5

Prosper-Haniel

The latest exposure measurements for this mining site are from 2005. One from 26–27th March 2005

reported 30.48 mg/m³ (5.64 ppm, i.e. slightly below the break point of ~ 6 ppm for the dose-response

function) of TRI in 25 downstreams (air exchange of 1200 m³/min) when applying 1 kg of HCR-1 and 2 kg

of STL-RF (product not in use anymore) for splicing activity. Personal exposure measurements were also

conducted, but due to the high humidity the detection method failed hence no measurement of TRI was

possible. Only one measurement was done per sampling site.

The plan (topview) of the measurements during the hot vulcanisation is shown in Figure 2.

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Figure 2: Plan view of the working unit tape measure in Prosper-Haniel; Source: (Institut für

Gefahrstoff-Forschung der Bergbau-Berufsgenossenschaft an der Ruhr-Universität Bochum, 2005)

These results are roughly consistent with an older study of Dahmann et al. (1996); they have examined the

relationship between measurements and calculations of exposures underground, as well as the additional

influence of parameters such as mass of adhesive emission, the height above the floor level and the speed of

mine aeration. In this source of the year 1996, in specific constellations even much higher concentrations

have both been measured and calculated. However, the site characteristics of the experimental mine are not

completely comparable with Prosper-Haniel, and Dahmann et al. have measured at points where in the case

of the Ruhrkohle mines workers are not allowed to stay during the emission and therefore cannot be

exposed. We do not regard the results of this study as contradictory to the measurements in Prosper-Haniel.

Also, in general the concordance of exposure scenario values and measured values is confirmed, apart from

some local effects on a small scale due to the higher weight of TRI emissions compared to the air and

therefore the vertical formation of layers.

Another measurement from the 8th of March 2005 was conducted during hot vulcanisation of finger splices

of a textile belt using 400 mL of a TRI product that are no longer in use (reported by AG, 2005). Air supply

was 2040 m³/min. Exposure measurements were conducted for three people during (1) applying the

trichloroethylene-product, (2) applying the TRI-product and heating phase, and (3) heating phase.

Additionally, one stationary measurement was done in 50 m distance downwind. The following

measurement results were obtained based on 7 hours of work per day:

Table 10: Exposure measurement results; source: (Deutsche Steinkohle AG, 2005)

Spot of measurement TRI-concentration in mg/m³ TRI-concentration in ppm

Blind sample < 0.003 < 0.0005

50 m away from activity in

downwind side

0.004 0.0007

Worker 1, applying TRI-product 0.4 0.073

Worker 2, applying TRI-product

plus heating phase

0.82 0.150

Worker 3, heating phase 0.82 0.150

As demonstrated by Table 10, the highest personal exposure concentrations were 0.82 mg/m³ (= 0.15 ppm).

This is considerably lower than the previously described measurements at the same site.

EC number:

201-167-4


79-01-6


RAG Anthrazit Ibbenbüren

In RAG Anthrazit Ibbenbüren, a measurement trial was undertaken on 30th of October 2010 for the

conveyor belt assembly, i.e. the connecting of conveyer belts underground. This was documented by

Continental, the producer of ContiTech conveyor belt systems (Continental Aktiengesellschaft, 2011).

3 kg of the assembly solution V was used - nowadays, the maximum usage mass is 2.5 kg. The respective air

ventilation was 0.85 m/s which is equal to 918 m³/s.

Since the respective activities are only executed for a maximum of two hours per shift, the measured values

have been converted to the shift average (8 hours), i.e. divided by the factor of 4.

Table 11: Exposure measurement results; source: (Continental Aktiengesellschaft, 2011)

Spot of measurement TRI-concentration

measured [mg/m³]

TRI-concentration, shift

mean [mg/m³]

TRI-concentration,

shift mean [ppm]

(1) Coating of belts 95.50 23.88 4.42

(2) Coating of belts 73.60 18.40 3.41

(3) 40 meters distance,

stationary in a height of

160 cm

< 4.89 *) < 4.89 *) < 0.91 *)

(4) Behind the fresh pit

air, stationary in a height

of 160 cm

< 4.89 *) < 4.89 *) < 0.91 *)

(5) 20 meters distance,

stationary in a height of

160 cm

< 4.89 *) < 4.89 *) < 0.91 *)

*) below detection limit

The reported values are much higher than at Prosper-Haniel, see above. Reasons for that are the rather low

ventilation (far below the average ventilation, see Table 8) and the higher usage mass. Moreover, the values

from RAG Anthrazit Ibbenbüren for the coating of belts are in the same order of magnitude as those

measured on 26-27th of March 2005; the values for coating need to be corrected for the protective effect of

RPE (filter masks as described above, protection factor 95 % in accordance with defaults specified in the

ECHA guidance). Accordingly, the maximum corrected inhalation exposure (derived from coating of belts

1) is 4.78 mg/m³. Therefore, none of the measured values exceeds the break point of 6 ppm where the

dose-response function changes its slope.


For any activities requiring the handling of products containing TRI the use of the following personal protective

equipment (PPE) is mandatory:

- Masks, ABEK, type A or äquivalent

- Protective gloves resistant to TRI (WNR 4043261 or 4043359) or äquivalent

- Goggles

Use of PPE ensures a level of protection sufficient for adequately controlling the skin and eye irritation hazards,

and skin sensitisation hazards, of TRI.

RAG is constantly decreasing its activities due to the closure of all mines in 2020. New belts are no longer

manufactured hence splicing is only done when a belt ruptures. No more recent exposure measurements are

available for the following reasons: Splicing and repair activities are impossible to plan since e.g. a rupture of a

belt cannot be foreseen. When this nevertheless happens, it has to be immediately fixed onsite in underground

using TRI-products. To perform TRI exposure measurements, an external company has to be hired and needs to be

informed in advance. Against the background that production is stopped until a belt is repaired, duration of repair

activities has to be limited as far as possible and for organization of exposure monitoring more time than for repair

itself is needed. This is why planned TRI-exposure measurements were not possible in recent years.

EC number:

201-167-4


79-01-6


However, as the number of samples analysed during the monitoring activities in 2005 and 2010 (n = 5, related to

the assessed activities) is not sufficient to comply with the requirements laid down in the ECHA guidance on

information requirements and chemical safety assessment the exposure estimation cannot be based on monitoring

data. Performance of new monitoring measurements was not possible for the reasons described above. Modelled

exposure levels will therefore be used for the risk evaluation, and monitoring results are used for confirmatory

purposes only.

Taking into account the the implemented RMMs, the very low duration of exposure of workers handling TRI

containing mixtures and the low amount of substance used per activity, it can be concluded that the risk for

workers is minimised as far as reasonably possible and further RMMs are not necessary.

9.1.3. Worker contributing scenario 2: Cold bonding (PROC 10)


Repair of damaged belts is done by "cold bonding", which is rather an adhesive bonding instead of true

vulcanisation. The process is described as follows: The damaged sectors of the belts are pre-cleaned with a broom

before being brushed and roughened using an angle grinder. TRI containing glue (TIP TOP Cement SC 2000) plus

hardener (TRI-free) is spread with a brush on the roughened area and left to dry for 30 minutes. This procedure is

repeated once. Afterwards, the glue is spread onto both a rubber patch and again on the roughened part of the belt.

The patch is pressed on the belt using a tape roller, followed by 15 minutes drying, resulting in complete removal

of TRI from the material. The repaired part is polished using an angle grinder, to obtain a smooth surface (no

potential for exposure to TRI).

Method

Product (article) characteristics

• Concentration of substance in mixture: Substance as such

According to the manufacturer of the used adhesive agent (TIP TOP Cement SC

2000) contains TRI at approximately 90 % hence exposure to the "substance as

such" needs to be assumed in the exposure scenario.

TRA Worker v3

Amount used (or contained in articles), frequency and duration of use/exposure

• Duration of activity: < 4 hours

The repeated preparation of the damaged sectors of conveyor belts and repair

patches as described above takes at maximum three hours (including drying times).

Therefore, according to ECETOC TRA categories an exposure period of "< 4 h" can

be adopted.

TRA Worker v3

Technical and organisational conditions and measures

• General ventilation: Enhanced general ventilation (5-10 air changes per hour)

Conveyor belt repair takes place in coal mines (predominantly underground), which

are characterised by forced ventilation. Air change rates in reality are substantially

higher than the maximum ventilation rate provided by ECETOC TRA. Therefore, the

model still represents a worst case.

TRA Worker v3

• Containment: No TRA Worker v3

• Local exhaust ventilation: no [Effectiveness Inhal: 0%] TRA Worker v3

• Occupational Health and Safety Management System: Basic TRA Worker v3

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

• Dermal Protection: Yes (chemically resistant gloves conforming to EN374 with

basic employee training) [Effectiveness Dermal: 90%]

Protective gloves resistant to TRI (WNR 4043261 or 4043359) are prescribed for

workers performing splicing and repair tasks. Personnel are specifically trained for

this type of work, including adequate use of protective gloves.

TRA Worker v3

• Respiratory Protection: Yes (Respirator with APF of 20) [Effectiveness Inhal:

95%]

With the default maximum ventilation rate permitted by the ECETOC TRA model the

use of an appropriate filter mask (ABEK, type A) is required.

TRA Worker v3

Other conditions affecting workers exposure

EC number:

201-167-4


79-01-6


Method

• Place of use: Indoor TRA Worker v3

• Process temperature (for liquid): <= 40 °C TRA Worker v3

• Skin surface potentially exposed: Two hands (960 cm2) TRA Worker v3

9.1.3.2. Exposure and risks for workers

The exposure concentrations and excess risks are reported in the following table. The worker exposure estimates

for the activities associated with this use of TRI have been assessed using ECETOC TRA v3.The ECETOC TRA

v3 estimates shown are representative for an activity duration of 4 h. Direct exposure of workers is limited to the

use of glue and hardener (3 times approximately 10 minutes) as during the drying (2 times 30 minutes and one

time 15 minutes) the workers leave the working area and other workers are not allowed to work in areas in wind

direction during the whole process. As a worst-case, 4 hours of exposure have nevertheless been assumed.

Table 12. Exposure concentrations and risks for workers

Route of exposure

and type of effects

Exposure concentration Factor A to adjust

time of exposure to

8 h

Factor B to adjust

work days (240

days to xy days of

exposure)

Excess risk

Inhalation,

systemic, long-term 4.927 mg/m³ (TRA

Worker v3)

1* 1** 5.91E-05

Dermal, systemic,

long-term

1.646 mg/kg bw/day (TRA

Worker v3)

1* 1** 1.38E-04

Combined routes,

systemic, long-term

1.97E-04

* Calculated concentration for 8 h taking an exposure of 15 minutes as basis (Factor A=8 h/ 8 h) ** Activity takes place maximum every day

(Factor B = 1)


For any activities requiring the handling of products containing TRI the use of the following personal protective

equipment (PPE) is mandatory:

- Masks, ABEK, type A or äquivalent

- Protective gloves resistant to TRI (WNR 4043261 or 4043359) or äquivalent

- Goggles

Use of PPE ensures a level of protection sufficient for adequately controlling the skin and eye irritation hazards,

and skin sensitisation hazards, of TRI.

Taking into account the the implemented RMMs, the very low duration of exposure of workers handling TRI

containing mixtures and the low amount of substance used per activity, it can be concluded that the risk for

workers is minimised as far as reasonably possible and further RMMs are not necessary.

EC number:

201-167-4


79-01-6


10. RISK CHARACTERISATION RELATED TO

COMBINED EXPOSURE

10.1. Human health

10.1.1. Workers

Not relevant as activities described in sub scenarios are not performed in parallel at the same workplace.

Simultaneous exposure of humans can be excluded.

10.1.2. Consumer

Not relevant as no consumer uses are covered by this application.

10.2. Environment (combined for all emission sources)

10.2.1. All uses (regional scale)

10.2.1.1. Total releases

The total releases to the environment from all the exposure scenarios covered are presented in the table below.

This is the sum of the releases to the environments from all exposure scenarios addressed.

Table 13. Total releases to the environment per year from all life cycle stages:

Release route Total releases per year

Water 0 kg/year

Air 1.37E3 kg/year

Soil 68.5 kg/year

10.2.1.2. Regional exposure

Environment

The regional predicted environmental concentration (PEC regional) and the related risk characterisation ratios

when a PNEC is available are presented in the table below.

The PEC regional have been estimated with EUSES.

Table 14. Predicted regional exposure concentrations (Regional PEC)

Protection target Regional PEC RCR

Freshwater 6.148E-9 mg/L Not needed

Sediment (freshwater) 1.126E-7 mg/kg dw Not needed

Marine water 5.381E-10 mg/L Not needed

Sediment (marine water) 9.399E-9 mg/kg dw Not needed

Air 6.78E-8 mg/m³ Not needed

Agricultural soil 8.829E-10 mg/kg dw Not needed

Man via environment

The exposure to man via the environment from regional exposure and the related risk characterisation ratios are

presented in the table below. The exposure concentration via inhalation is equal to the PEC air.

Table 15. Regional exposure to man via the environment

EC number:

201-167-4


79-01-6


Route Regional exposure Excess risk

Inhalation 6.78E-8 mg/m³ Excess risk = 4.34E-12

Oral 2.866E-10 mg/kg bw/day Excess risk = 1.24E-13

Combined routes Excess risk = 4.46E-12


The risk management measures in place at RAG AG are considered to represent state of the art technology.

Therefore, the excess risk related to exposure of humans to the environment is regarded to be minimised to the

greatest possible extent.

For the risk characterisation itself the reader is referred to the socio-economic analysis (SEA) where health

impacts are monetized.

10.2.2. Local exposure due to all wide dispersive uses

Not relevant as there are not several wide dispersive uses covered in this CSR.

10.2.3. Local exposure due to combined uses at a site

Not relevant as exactly one use at one site is described in this CSR.

EC number:

201-167-4


79-01-6


REFERENCES Sections 9 – 10

(AGS), C. o. H. S., 2013. Exposure-risk relationship for trichloroethylene in BekGS 910. [Online], available at:

http://www.baua.de/en/Topics-from-A-to-Z/Hazardous-Substances/TRGS/pdf/910/910-trichloroethylene.pdf?__

blob=publicationFile&v=2 [Accessed 18 September 2013].

AG, D. S., 2005. Bericht - Nr. 45/05 über eine Arbeitsbereichsanalyse in Anlehnung an TRGS 402, Bergwerk

Prosper-Haniel: s.n.

Aktiengesellschaft, C., 2011. Gefahrstoffmessungen (Trichlorethylen) am 30.10.2010, ContiTech

Transportbandsysteme GmbH, Kst. 30211, Hannover: s.n.

Dahmann, D. et al., 1996. Rechnerische Ermittlung von Gefahrstoffkonzentrationen in untertägigen

Arbeitsbereichen. Gefahrstoffe - Reinhaltung der Luft.

Deutsche Steinkohle AG, 2005. Bericht Nr. 45/05 über eine Arebitsbereichsanalyse in Anlehnung an TRGS 402.

Betrieb: Bergwerk Prosper-Haniel, s.l.: Deutsche Steinkohle AG.

ECHA, 2014. Application for Authorisation: Establishing a reference dose response relationship for

carcinogenicity oftrichloroethylene., Helsinki: European Chemicals Agency.

ECHA, n.d. ECHA Guidance: Guidance on Information Requirements and Chemical Safety Assessment.

[Online], available at:

http://echa.europa.eu/web/guest/guidance-documents/guidance-on-information-requirements-and-chemical-safet

y-assessment [Accessed 27th May 2014].

Institut für Gefahrstoff-Forschung der Bergbau-Berufsgenossenschaft an der Ruhr-Universität Bochum, 2005.

Bericht über die Durchführung von Gefahrstoffmessungen (Trichlorethylen und N-Nitrosamine) beim

untertägigen Heißvulkanisieren am 26. und 27.03.2005 auf dem Bergwerk Prosper-Haniel der DSK Deutsche

Steinkohle AG in Bottrop, Bochum: s.n.

http://www.baua.de/en/Topics-from-A-to-Z/Hazardous-Substances/TRGS/pdf/910/910-trichloroethylene.pdf?__blob=publicationFile&v=2

http://www.baua.de/en/Topics-from-A-to-Z/Hazardous-Substances/TRGS/pdf/910/910-trichloroethylene.pdf?__blob=publicationFile&v=2

http://echa.europa.eu/web/guest/guidance-documents/guidance-on-information-requirements-and-chemical-safety-assessment

http://echa.europa.eu/web/guest/guidance-documents/guidance-on-information-requirements-and-chemical-safety-assessment

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