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Table of Contents

SECTION 1. Identification of the substance/mixture and of the company/undertaking .....2

SECTION 2. Hazards identification ..................................................................................3

SECTION 3. Composition / information on ingredients ....................................................4

SECTION 4. First aid measures .......................................................................................5

SECTION 5. Fire fighting measures .................................................................................5

SECTION 6. Accidental release measures ......................................................................6

SECTION 7. Handling and storage ..................................................................................6

SECTION 8. Exposure controls / personal protection ......................................................6

SECTION 9. Physical and chemical properties ................................................................7

SECTION 10. Stability and reactivity................................................................................8

SECTION 11. Toxicological information ...........................................................................8

SECTION 12. Ecological information ...............................................................................9

SECTION 13. Disposal considerations .......................................................................... 11

SECTION 14. Transport information .............................................................................. 11

SECTION 15. Regulatory information ............................................................................ 12

SECTION 16. Other information .................................................................................... 13

ES1: Manufacture of aluminium dihydrogen triphosphate .............................................. 14

ES2: Formulation with aluminium dihydrogen triphosphate ............................................ 18

ES3: Industrial use as processing aid and/or pH regulator in the synthesis of other chemicals and use as a laboratory reagent at large scale laboratories. ............ 22

ES4: Industrial end use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks, etc ....................................................................................... 26

ES5: Industrial end use in building / construction materials and in ceramics. ................. 30

ES6: Professional use as an intermediate in synthesis of other chemicals and use as a laboratory reagent. ................................................................................... 34

ES7: Professional use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks ............................................................................................. 38

ES8: Professional use in construction materials and ceramics: in coating systems, as a binding agent and as a silicate hardener .................................................. 41

ES9: Consumer use of paints, coatings and varnishes containing aluminium dihydrogen triphosphate ................................................................................... 45

ES10: Consumer use of inks and toners containing aluminium dihydrogen triphosphate ..................................................................................................... 48

ES11: Consumer use of construction materials containing aluminium dihydrogen triphosphate ..................................................................................................... 50

ES12: Service life of paper articles where industrial and consumer use of the finished article is possible................................................................................. 52

ES13: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when handled by industrial and professional users ......... 54

ES14: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service

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life of coated articles when consumer contact with the finished article is possible ............................................................................................................ 57

ES15: Service life of building and construction materials and ceramic articles when handled by industrial and professional users .................................................... 59

ES16: Service life of building and construction materials and ceramic articles when consumer contact with the finished article is possible ....................................... 62

NOTICE : Important information

Please note that this generic exposure scenario is by no means intended to be mandatory, prescriptive or exhaustive. The content of this document is intended for guidance only and whilst the information on uses covered is provided in utmost good faith and has been based on the best information currently available, is to be relied upon at the user’s own risk. Ultimately, it is for each company to assess the appropriateness and completeness of the information on a case-by case basis and decide what elements they wish to adopt or to add. In particular, the preparation and content of the e-SDS is the legal responsibility of each company for its own products placed on the market, and the user should verify, complete, correct or adapt this generic document appropriately. No representations or warranties are made with regards to its completeness or accuracy, in particular regarding the list of uses that are covered, and no liability will be accepted by [the consortium members] for damages of any nature whatsoever resulting from the use of or reliance on the information. The consortium members acknowledge that any activities carried out under REACH have to be carried out in full compliance with EU competition law, in particular but not limited to Articles 101 and 102 of the Treaty on the Functioning of the European Union (TFEU) as well as any applicable national laws.

SECTION 1. Identification of the substance/mixture and of the company/undertaking

1.1 Product identifier:

Aluminium dihydrogen triphosphate EINECS Number: 237-714-9 CAS Number: 13939-25-8 REACH Registration number: [to be filled in by company] Other identifiers: Aluminium tripolyphosphate, AlTPP

1.2 Relevant identified uses of the substance or mixture and uses advised against:

Industrial / professional uses:

- Manufacture of aluminium dihydrogen triphosphate (exposure scenario 1) - Formulation with aluminium dihydrogen triphosphate (exposure scenario 2) - Industrial use as processing aid and/or pH regulator in the synthesis of other chemicals and use as a

laboratory reagent at large scale laboratories (exposure scenario 3) - Industrial end use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks, etc

(exposure scenario 4) - Industrial end use in building / construction materials and in ceramics (exposure scenario 5) - Professional use as an intermediate in synthesis of other chemicals and use as a laboratory reagent.

(exposure scenario 6) - Professional use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks

(exposure scenario 7)

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- Professional use in construction materials and ceramics: in coating systems, as a binding agent and as a silicate hardener (exposure scenario 8)

Consumer uses:

- Consumer use of paints, coatings and varnishes containing aluminium dihydrogen triphosphate (exposure scenario 9)

- Consumer use of inks and toners containing aluminium dihydrogen triphosphate (exposure scenario 10)

- Consumer use of construction materials containing aluminium dihydrogen triphosphate (exposure scenario 11)

Service life:

- Service life of paper articles where industrial and consumer use of the finished article is possible (exposure scenario 12)

- Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when handled by industrial and professional users (exposure scenario 13)

- Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when consumer contact with the finished article is possible (exposure scenario 14)

- Service life of building and construction materials and ceramic articles when handled by industrial and professional users (exposure scenario 15)

- Service life of building and construction materials and ceramic articles when consumer contact with the finished article is possible (exposure scenario 16)

No known uses advised against.

1.3 Details of the supplier of the safety data sheet:

[Insert relevant details including contact name, address, phone number, email here]

1.4 Emergency telephone number:

[Insert suitable emergency number and hours of operation]

SECTION 2. Hazards identification

2.1 Classification of the substance

2.1.1 According to Regulation (EC) No. 1272/2008 (EU CLP):

Eye Irritation 2. H319: Causes serious eye damage

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2.2 Label elements

2.2.1 According to Regulation (EC) No. 1272/2008 (EU CLP):

Name: aluminium dihydrogen triphosphate Index Number: Not applicable CAS Number: 13939-25-8

Signal word: Warning Hazard Statements: H319: Causes serious eye irritation Precautionary Statements: Prevention: P264: Wash hands thoroughly after handling. P280: Wear protective gloves, eye protection and face protection. Response: P305 + P351 + P338: IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing. P337 + P313: If eye irritation persists: Get medical advice/attention. NOTE: Information in Section 2.2 MUST be consistent with the information provided on the supplier’s labels.

2.3 Other hazards

The material is not considered to be PBT or vPvB.

SECTION 3. Composition / information on ingredients

3.1 Substance:

Name EC Number CAS Number Typical

concentration Concentration Range

Aluminium dihydrogen triphosphate

237-714-9 13939-25-8 99.5% [Taken from SIP - specific company to update where necessary]

[to be provided by company]

Registration Number (if available): [specific to each registrant – insert number here]

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EC name: aluminium dihydrogen triphosphate Identification of hazardous impurities (where applicable):

All impurities > 1% are other inorganic phosphates or other related inorganic substances, similar to the Registered substance, and which do not significantly affect its toxicological and ecotoxicological properties

All hazardous impurities are < 0.1% NOTE: The above information on impurities is company specific therefore suppliers to update where necessary and in line with the data that is provided in their joint registration dossier Section 1.2.

SECTION 4. First aid measures

4.1 Description of first aid measures

Inhalation In case of exposure by inhalation, provide fresh air, seek medical advice in case of symptoms. Ingestion Rinse out mouth and then drink plenty of water. Do not induce vomiting. In case of symptoms consult doctor. Skin Contact In case of contact with skin, rinse with plenty of soap and water. Take off contaminated clothing and shoes immediately. Eye Contact IF IN EYES: Rinse cautiously with water for several minutes. Remove contact lenses, if present and easy to do. Continue rinsing.

If eye irritation persists, seek medical advice/attention.

4.2 Most important symptoms and effects, both acute and delayed

Aluminium dihydrogen triphosphate is irritating to the eyes. No delayed effects are noted.

4.3 Indication of any immediate medical attention and special treatment needed

In case of contact with eyes, flush with water immediately.

SECTION 5. Fire fighting measures

5.1 Extinguishing media

Suitable extinguishing media: Aluminium dihydrogen triphosphate is not flammable. Use water spray, alcohol-resistant foam, dry chemical or carbon dioxide. Use extinguishing measures that are appropriate to local circumstances and the surrounding environment. Inappropriate extinguishing media: None identified.

5.2 Special hazards arising from the substance or mixture

None identified.

5.3 Advice for fire-fighters

In cases where dust particles of aluminium dihydrogen triphosphate may be present respiratory ventilation is recommended. Wear appropriate eye protection. See Section 8.2.

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SECTION 6. Accidental release measures

6.1 Personal precautions, protective equipment and emergency procedures

Avoid contact with eyes. Use personal protection equipment.

6.2 Environmental precautions

Do not allow concentrated solutions to enter drainage system, surface or ground water.

6.3 Methods and material for containment and cleaning up

Shovel up material and recycle if possible. Dispose of contaminated material according to the waste disposal recommendations.

6.4 Reference to other sections

Refer to Section 8 for suitable PPE. Refer to Section 13 for disposal considerations.

SECTION 7. Handling and storage

7.1 Precautions for safe handling

Technical measures: sufficient ventilation and local suction is required in accordance with the details in the annex to the SDS. Do not eat, smoke or drink.

7.2 Conditions for safe storage, including any incompatibilities

Keep container tightly closed in a dry and well-ventilated place. No special requirements. No known incompatibilities.

7.3 Specific end use(s)

See annex for details of end uses covered in the exposure scenarios and CSR. The exposure scenarios detailed in the annex represent a worst case for exposure to humans and the environment.

SECTION 8. Exposure controls / personal protection

8.1 Control parameters

Workplace exposure limits: Workplace exposure limits: General dust exposure limit: 10 mg/m3 (inhalable fraction), 3 mg/m3 (alveolic fraction). German TRGS 900 (2006). [please check occupational limits for the country you supply to and insert limit here if available] DNELS (worker, general population): No DNELs can be derived for local effects as no dose-response relationship can be identified in any of the studies available. Substance is considered to be of low hazard. No DNELS derived for systemic effects as no indication of effects via any route of exposure have been identified. PNECs:

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The ECHA guidance on Information Requirements and Chemical Safety Assessment Part B: Hazard Assessment (December 2011, pg 48) states that ‘if no adverse effects have been observed in studies at the highest recommended concentrations/doses tested, this would normally indicate that no hazard has been identified and no PNEC can be derived and exposure assessment would not be needed’. As the substance is not considered to be toxic PNECs have not been derived.

8.2 Exposure controls

Appropriate engineering controls: Ensure work area is well ventilated or exhausted (where appropriate and in line with the exposure scenarios). Provide eye wash station. Respiratory protection: See annex for details of processes requiring respiratory protection. In case of insufficient ventilation, wear suitable respiratory device such as EN141 or EN405, Type A. Skin protection: Laboratory coat or overalls and plastic or rubber boots. Store protective clothing separately. Eye protection: Tightly sealed chemical safety goggles (compliant with EN 166:2001) Hand protection: It is advisable to wear suitable gloves that are compliant with EN 374. Environmental controls: Refer to Sections 6, 7, 12 and 13 of the SDS.

SECTION 9. Physical and chemical properties

9.1 Information on basic physical and chemical properties

Property Value Method

Appearance; including colour and physical state

Solid, white powder

Observed during melting point study under conditions of GLP

Odour Odourless Observed during melting point study under conditions of GLP

Odour threshold Not available

pH pH 4.0 As measured in the water solubility study (EU Method A.6) under conditions of GLP

Melting point/freezing point >450°C EU Method A.1, under conditions of GLP, Klimisch 1

Initial boiling point and boiling range Not determined According to Regulation No. 1907/2006, a study for boiling point is not required for solids which melt above 300°C

Flash point Not determined According to Regulation No. 1907/2006, the flash point does not need to be assessed for inorganic chemicals.

Evaporation rate Not available

Flammability (Solid, gas) Not flammable Based on prediction and use based observations

Upper/lower flammability or explosive limits

Not applicable

Vapour pressure Not determined According to Regulation No. 1907/2006, a study for the vapour pressure need not be conducted if the melting point is above 300°C.

Vapour density (Air = 1) Not applicable

Relative density Mean density: ca. 378.3 g/L at 20°C.

OECD Method 109, Klimisch 2

Solubility(ies) Water: 0.00034 g/L EU Method A.6, under GLP conditions, Klimisch 1

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at 20 ± 0.5°C (very soluble)

Effect of temperature could not be determined due to low solubility.

Partition coefficient: N-octanol/water Not determined According to Regulation No. 1907/2006, the partition coefficient n-octanol/water does not need to be assessed for inorganic chemicals.

Auto-ignition temperature No auto-ignition anticipated

Based on prediction

Decomposition temperature Not applicable

Viscosity Not determined Testing not technically possible: According to the relevant OECD guideline (OECD 114) a study cannot be conducted on a substance that is a solid at room temperature.

Explosive properties Not considered to be explosive

Prediction – in accordance with EU Method A14

Oxidising properties No oxidising properties

Prediction – in accordance with EU Method A17

9.2 Other information

Testing has been performed on aluminium dihydrogen triphosphate, in accordance with Annex IX of REACH.

SECTION 10. Stability and reactivity

10.1 Reactivity

Non-reactive under recommended storage and handling conditions.

10.2 Chemical stability

Stable under recommended storage and handling conditions.

10.3 Possibility of hazardous reactions

Hazardous reactions are considered unlikely.

10.4 Conditions to avoid

None identified.

10.5 Incompatible materials

None identified.

10.6 Hazardous decomposition products

None. [Companies to ensure the above is correct according to the form and nature of the substance supplied]

SECTION 11. Toxicological information

11.1 Information on toxicological effects

Toxicological endpoint Value (including relevance to CLP

criteria) Method

Acute toxicity

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Oral

Oral; LD50(rat) = >2000 mg/kg bw/day. Not classified.

OECD 420, Conducted under GLP, Klimisch 1

Dermal No data available. Study not considered necessary as

sufficient information available to characterise acute systemic toxicity profile.

Inhalation LC50 (rat) = > 3.46 mg/L Rat, OECD 436, Conducted under GLP,

Klimisch reliability 1

Skin corrosion/irritation Not irritating OECD Guideline 439 / EU Method B.46, under conditions of GLP, Klimisch 1.

Supported by in vitro corrosivity study (OECD 431). Result = not corrosive.

Serious eye/damage/irritation Irritating to eyes – category 2

Rabbit, OECD 405 / EU Method B.5. Under conditions of GLP, Klimisch reliability 1. Supported by ex vivo BCOP study (OECD 437). Result = not corrosive.

Respiratory or skin sensitisation Non - sensitiser Mouse, OECD 429, EU Method B.42. Klimisch reliability 2; read-across from similar substance (aluminium orthophosphate). No data to suggest substance is a respiratory sensitiser.

Germ cell mutagenicity Not considered to be mutagenic.

Key studies are submitted for the following REACH endpoints on an analogous substance (aluminium orthophosphate): - in vitro gene mutation in bacteria (OECD 471, Klimisch 2 as read-across) - in vitro cytogenicity study in mammalian cells (OECD 476, Klimisch 2 as read-across ) - in vitro gene mutation study in mammalian cells (OECD 473, Klimisch 2 as read-across)

Carcinogenicity Not considered to be a carcinogen.

Not required for REACH. No data to suggest likelihood of carcinogenicity.

Reproductive toxicity Not considered to be a reproductive toxicant

No structural alerts to suggest substance is a reproductive toxicant.

STOT-single exposure – all routes

No STOT SE observed via the oral, dermal or inhalation route.

Not applicable.

STOT-Repeated exposure - all routes

Not considered to induce specific organ toxicity after repeated exposure via oral route.

No structural alerts to suggest substance is a repeated dose toxicant.

Aspiration hazard No aspiration hazard identified

Not applicable.

The substance has been assessed with regards to the data requirements of Annex IX of REACH.

SECTION 12. Ecological information

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12.1 Toxicity

Toxicological endpoint Value (including relevance to CLP

criteria) Species, Method

Acute fish toxicity

No data available

Aluminium dihydrogen triphosphate is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. Further investigation of bioavailability (i.e. via a TDp protocol) is outside of the scope of REACH and is not considered to be appropriate as the metal ion of interest (aluminium) is not considered to pose a hazard to the aquatic environment.

Acute Daphnia toxicity No data available

Aluminium dihydrogen triphosphate is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. Further investigation of bioavailability (i.e. via a TDp protocol) is outside of the scope of REACH and is not considered to be appropriate as the metal ion of interest (aluminium) is not considered to pose a hazard to the aquatic environment.

Algal growth inhibition No data available

Aluminium dihydrogen triphosphate is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. Further investigation of bioavailability (i.e. via a TDp protocol) is outside of the scope of REACH and is not considered to be appropriate as the metal ion of interest (aluminium) is not considered to pose a hazard to the aquatic environment.

Activated Sludge Respiration No data available

Aluminium dihydrogen triphosphate is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. Further investigation of bioavailability (i.e. via a TDp protocol) is outside of the scope of REACH and is not considered to be appropriate as the metal ion of interest (aluminium) is not considered to pose a hazard to the aquatic environment.

The substance has been assessed with regards to the data requirements of Annex IX of REACH

12.2 Persistence and degradability

Aluminium dihydrogen triphosphate is an inorganic substance, biodegradation studies are not applicable. No further testing is deemed to be necessary.

12.3 Bioaccumulative potential

No data available: The potential for bioaccumulation is considered to be minimal.

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12.4 Mobility in soil

A batch equilibrium study according to OECD Guideline 106 was deemed to be not applicable to aluminium dihydrogen triphosphate for the following reasons:

According to Annex XI, Section 2 of Regulation (EC) No 1907/2006 (REACH) testing for a specific endpoint may be omitted if it is technically not possible to conduct the study as a consequence of the properties of the substance itself. A study to investigate the adsorption / desorption characteristics of aluminium dihydrogen triphosphate has not been conducted. The justifications for not providing these data are as follows: - A screening study according to OECD Guideline 121 is not technically possible as the test method is not validated for inorganic substances. - A batch equilibrium study according to OECD Guideline 106 was deemed to be not applicable to aluminium dihydrogen triphosphate for the following reasons: Firstly, analysis of the test material may not be possible due to interference from the soil extracts that may leach into the aqueous media during the test (phosphate is ubiquitous in natural soils and aluminium is the most abundant element in the earth's crust). This would prevent quantification of the test material. In addition, the mobility of the test item would be dependent on the anion exchange capacity of the soils as the main component of the test material is an anion. This absorption relationship would not be anticipated to correlate with the organic carbon content of the soils and is considered to be beyond the scope of the OECD 106 method.

12.5 Results of PBT and vPvB assessment

According to the Guidance on Information Requirements and Chemical Safety Assessment, Chapter R.11: PBT Assessment, the PBT and vPvB criteria of Annex XIII to the regulation do not apply to inorganic substances. Therefore aluminium dihydrogen triphosphate is not considered to require any further assessment of PBT properties.

12.6 Other adverse effects

No sediment or terrestrial toxicity data exists. Substance is not considered to be hazardous to sediment dwelling or terrestrial organisms. According to the criteria of the European classification and labelling system, the substance does not require classification as hazardous for the environment

SECTION 13. Disposal considerations

13.1 Waste treatment methods

Disposal recommendations are made based on the material as supplied. Disposal must be in accordance with current applicable laws and regulations. Disposal of substance: Dispose of in accordance with national and local regulations for special waste via an appropriately licensed waste contractor. Do not discharge to drains or STP. Disposal of packaging: Empty containers and clean out appropriately before reuse or disposal. Packaging may be recycled if thoroughly cleaned. Packaging that cannot be cleaned should be disposed of according to national and local regulations for special waste via an appropriately licensed waste contractor. Regulatory disposal information: European waste codes: Waste producers need to asses the process used when generating the waste and its contaminants in order to assign the most appropriate waste disposal code(s). Recommended code: European waste catalogue 16 03 03 inorganic wastes containing dangerous substances

SECTION 14. Transport information

Transport classifications (ADR/RID/IMDG/IATA) are not defined in the REACH Registration Dossier for the substance. The information provided here is therefore not derived from this Dossier and is based on other

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information available to the Consortium Members. The Transport classifications (ADR/RID/IMDG/IATA) provided here are indicative and based on the data in the REACH dossier for the pure substance only and may not be applicable for solutions or other preparations. Please seek advice from your Dangerous Good Safety Advisor.

According to information available: UN transport classification: Not Classified (for pure substance as solid and solution in water

14.1 UN number

LAND (ADR/RID) SEA (IMDG) AIR (IATA)

14.2 UN proper shipping name

14.3 Transport hazard class(es)

Labels

14.4 Packing group

14.5 Environmental hazards

14.6 Special precautions for user

14.7 Transport in bulk according to Annex II of MARPOL 73/78 and the IBC code

Other Information:

SECTION 15. Regulatory information

15.1 Safety, health and environmental regulations/legislation specific for the substance or mixture.

[COMPANY TO INCLUDE ANY INFORMATION RELEVANT TO THE COUNTRY OF PRODUCT AND/OR SUPPLY] This safety data sheet is compliant with Regulation (EC) No 1907/2006 (REACH) (including the amendment, Regulation (EU) No 453/2010 and Regulation (EC) No. 1272/2008 (EU CLP).

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15.2 Chemical Safety Assessment.

A Chemical Safety Assessment is available for aluminium dihydrogen triphosphate.

SECTION 16. Other information

This SDS supersedes the SDS dated [TO BE COMPLETED BY COMPANY SUPPLYING SDS] The following amendments have been made:

- SDS has been fully revised and re-written in accordance with Regulation (EU) No 453/2010 and Regulation (EC) No. 1272/2008 (EU CLP).

- Any further amendments to be detailed by supplier of SDS - Section 2.1: Classification according to Council Directive 67/548/EEC removed in accordance with

Regulation (EU) No. 453/2010

Sources of Key data used: - Registration dossier submitted to ECHA in accordance with Regulation (EC) No. 1907/2006 and therefore a full reference list can be found in the corresponding CSR.

Abbreviations and acronyms used: AF = Assessment factor DNEL = Derived no effect level EC50 = Median effect concentration LC50 = Median lethal concentration LD50 = Median lethal dose LEV = Local Exhaust Ventilation NOAEL = No observed adverse effect level NOEC = No observed effect concentration PBT Persistent bioaccumulative toxic PEC = Predicted effect level PNEC = Predicted no effect level PRE = Personal Respiratory Equipment OEL = Occupational Exposure Limit SDS = Safety data sheet STOT–SE = Specific target organ toxicity – single exposure STOT–RE = Specific target organ toxicity – repeated exposure STP = Sewage treatment plant vPvB = Very persistent very bioaccumulative

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Annex: summary of relevant exposure scenarios

ES1: Manufacture of aluminium dihydrogen triphosphate .............................................. 14

ES2: Formulation with aluminium dihydrogen triphosphate ............................................ 18

ES3: Industrial use as processing aid and/or pH regulator in the synthesis of other chemicals and use as a laboratory reagent at large scale laboratories. ............ 22

ES4: Industrial end use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks, etc ....................................................................................... 26

ES5: Industrial end use in building / construction materials and in ceramics. ................. 30

ES6: Professional use as an intermediate in synthesis of other chemicals and use as a laboratory reagent. ................................................................................... 34

ES7: Professional use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks ............................................................................................. 38

ES8: Professional use in construction materials and ceramics: in coating systems, as a binding agent and as a silicate hardener .................................................. 41

ES9: Consumer use of paints, coatings and varnishes containing aluminium dihydrogen triphosphate ................................................................................... 45

ES10: Consumer use of inks and toners containing aluminium dihydrogen triphosphate ..................................................................................................... 48

ES11: Consumer use of construction materials containing aluminium dihydrogen triphosphate ..................................................................................................... 50

ES12: Service life of paper articles where industrial and consumer use of the finished article is possible................................................................................. 52

ES13: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when handled by industrial and professional users ......... 54

ES14: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when consumer contact with the finished article is possible ............................................................................................................ 57

ES15: Service life of building and construction materials and ceramic articles when handled by industrial and professional users .................................................... 59

ES16: Service life of building and construction materials and ceramic articles when consumer contact with the finished article is possible ....................................... 62

ES1: Manufacture of aluminium dihydrogen triphosphate

Exposure Scenario 1: Manufacture of aluminium dihydrogen triphosphate

List of applicable use descriptors: ERC 1, PROC 1, 2, 3 , 4, 8a,8b, 9, 26

Contributing environmental scenario: Manufacture of substances ERC 1

Contributing worker scenario 1: Use in closed process, no likelihood of exposure

PROC 1

Contributing worker scenario 2: Use in closed, continuous process with occasional controlled exposure

PROC 2

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Contributing worker scenario 3: Use in closed batch process (synthesis or formulation)

PROC 3

Contributing worker scenario 4: Use in batch and other process (synthesis) where opportunity for exposure arises

PROC 4

Contributing worker scenario 5: Transfer of substance or preparation (charging/discharging) from/to vessels/large containers at non-dedicated facilities

PROC 8a

Contributing worker scenario 6: Transfer of chemicals from/to vessels/ large containers at dedicated facilities

PROC 8b

Contributing worker scenario 7: Transfer of chemicals into small containers (dedicated filling line)

PROC 9

Contributing worker scenario 8: Handling of solid inorganic substances at ambient temperature

PROC 26

Manufacture of aluminium dihydrogen triphosphate

Explanation of technical processes and activities covered: Aluminium dihydrogen triphosphate, CAS 13939-25-8, is produced by neutralization of phosphoric acid with aluminium hydroxide in the following reaction: 3 H3PO4 + Al(OH)3 => AlH2(P3O10) + 5 H2O

Depending on the use of the final product, purity of phosphoric acid and aluminium hydroxide are selected to ensure the quality of the final product. The neutralization is carried out in a vessel by means of agitators or in continuously operating mixers, yielding concentrated slurry with partial precipitation of the salt. The slurry is further processed by drying in a rotary kiln. After cooling the product may be milled or screened to obtain various particle sizes. The milled and screened Aluminium dihydrogen triphosphate product is transported either pneumatically or by a belt conveyor to the storage silos and then into suitable containers or packaged in bags.

Control of environmental exposure during manufacture of substances (ERC 1)

Further specifications

Product characteristics

Physical state of the substance when manufactured: Manufactured as a solid at 20°C and 1013hPa.

Amounts used

The annual amount of aluminium dihydrogen triphosphate produced has been set between 100-1000 tpa

Frequency and duration of use

Continuous exposure is assumed. Manufacturing processes may be operated on 365 days a year for 24 hours a day. It is assumed that workers will work 8-hr working shifts. A single worker may be exposed on 220 days per year.

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value).

Other given operational conditions affecting environmental exposure

Cyclones, scrubbers and filters are used to retain particles and ensure dust emission requirements are met. See below.

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

RMMs are employed, see below.

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

Emissions to waste water are reduced by on-site waste-water treatment. Procedures for water treatment are detailed in the SIC BREF Best Available Techniques for the Production of Speciality Inorganic Chemicals, EC 2006.

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 16/64

NB. Please read the NOTICE on the front page.

Treatment measures are dependent on the specific processes and metals involved but direct water emissions are reduced by implementing one or more of the following: - precipitation/ sedimentation/ filtration - crystallisation - chemical oxidation - chemical reduction - nanofiltration/reverse osmosis - adsorption - ion exchange - evaporation - stripping - incineration. The Eurometaux spERC for the manufacture of metal compounds (1.2 v. 2.1) states that removal efficiency using one or more of the above techniques is 99% (50

th percentile).

Further, phosphate removal using physical-chemical treatment methods. Emissions of particles into the atmosphere are generally considered to be low as the vapour pressure for this material is assumed to be 1x10

-06 Pa at 20°C in accordance with Guidance on information requirements and

chemical safety assessment Appendix R.7.13-2: Environmental risk assessment for metals and metal compounds, June 2008. To prevent the release of dust into the atmosphere, a cyclone and bag filter system is used to retain any particles and ensure that dust emission requirements are met. Other options for reducing emissions are: - Electrostatic precipitators using wide electrode spacing: 5-15 mg/Nm

3

- Wet electrostatic precipitators: 5-15 mg/Nm3

- Cyclones, but as primary collector: < 50 mg/Nm3

- Fabric or bag filters: highly efficient for controlling fine particulate : 10-15 mg/Nm3 . High Efficiency Particule

Arrestation (HEPA) filter or Two-stage dust filter techniques can achieve < 1 mg/Nm3.

The Eurometaux spERC for the manufacture of metal compounds (1.2 v. 2.1) states that removal efficiency using one or more of the above techniques is 90 – 99.98%. Filtration residues from the production are recycled and used for other products.

Organisational measures to prevent/limit release from site

Good working practice and prevention of releases of waste to floor, water and soil. Process efficiency is maximised to ensure minimal emission to wastewater.

Conditions and measures related to municipal sewage treatment plant

Default conditions are assumed.

Conditions and measures related to external treatment of waste for disposal

The manufacturing process is designed in a way that waste is not expected. Most processes are performed under controlled conditions and sampling is considered to be minimal. In addition filtration products are retained and recycled.

Conditions and measures related to external recovery of waste

Phosphates can be precipitated from wastewater by addition of metal ions and solid/liquid waste incinerated by a licenced contractor.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

If a site does not comply with the conditions detailed above it is recommended to monitor air and water releases. Phosphate emissions to surface water via industrial wastewater are regulated by Council Directive 96/61/EC concerning integrated pollution prevention and control. The Directive states that phosphates must be taken into account when fixing emission limit values for industrial wastewater.

Control of worker exposure during the manufacture of aluminium dihydrogen triphosphate

Further specifications:

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 17/64

NB. Please read the NOTICE on the front page.

Product characteristics

Aluminium dihydrogen triphosphate is produced as a solid material.

Amounts used

The annual amount of aluminium dihydrogen triphosphate produced has been set between 100-1000 tpa

Frequency and duration of use

Continuous exposure is assumed. Manufacturing processes may be operated on 365 days a year for 24 hours a day. It is assumed that workers will work 8-hr working shifts. A single worker may be exposed on 220 days per year.

Human factors not influenced by risk management

Not applicable.

Other given operational conditions affecting worker exposure

Manufacturing processes are performed indoors in large volume rooms. Exposure is minimised via appropriate risk management measures.

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

The manufacturing process is designed so that exposure is minimised to sampling times and transfer only.

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

Exhaust ventilation may be used for processes where aluminium dihydrogen triphosphate is handled. The efficiency and RMMs should be sufficient to ensure that exposure to dusts is in line with national dust exposure levels. No specific hazards from aluminium dihydrogen triphosphate are identified.

Organisational measures to prevent/limit releases, dispersion and exposure

No specific organisational measures are undertaken, however the following working practices may be used to reduce exposure: - Use of automated or closed processes and minimisation of manual tasks - Minimisation of splashes and spills - Training of staff on good practice - Management measures to ensure RMMs are used correctly and remain effective - Good standards of personal hygiene

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

Aluminium dihydrogen triphosphate is considered to fall under the hazard band: LOW in accordance with ECHA’s practical guide 15. The following are considered to be appropriate RMMs: - Eye protection: wearing of eye protection is required. Goggles should be consistent with EN166 or equivalent.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

See above.

Environmental exposure estimation: Aluminium dihydrogen triphosphate

No direct acute or long-term adverse effects on aqueous or terrestrial organisms are anticipated with aluminium dihydrogen triphosphate in the environment. Aluminium dihydrogen triphosphate is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. Further investigation of bioavailability (i.e. via a TDp protocol) is outside of the scope of REACH and is not considered to be appropriate as the metal ion of interest (aluminium) is not considered to pose a hazard to the aquatic environment. Aluminium dihydrogen triphosphate is not anticipated to contribute to eutrophication as it is insoluble in water and as such the bioavailability of phosphorus (as phosphate) is significantly reduced. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 18/64

NB. Please read the NOTICE on the front page.

1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Worker exposure estimation: aluminium dihydrogen triphosphate

It is not considered to be appropriate to use modelling tools to calculate exposure. It is assumed that workplaces adhere to country-specific guidelines with regards to dust exposure. In addition, no specific systemic hazards are present for aluminium dihydrogen triphosphate. Concurrent exposure via various routes of exposure only needs to be accounted for when characterising overall systemic health risks. As the leading health effect of aluminium dihydrogen triphosphate is eye irritation, a local effect, concurrent exposure via various routes of exposure is considered not relevant and no risk characterisation has been performed. Risks relating to the eye irritancy of aluminium dihydrogen phosphate cannot be quantified but can be controlled by the use of protective face shield or goggles. Details of the RMMs are given in the exposure scenarios. Under these use conditions, no local eye effects are expected. Therefore, the identified uses are considered to be safe.

ES2: Formulation with aluminium dihydrogen triphosphate

Exposure Scenario 2: Formulation with aluminium dihydrogen triphosphate

List of applicable use descriptors: ERC 2, 3, PROC 1, 2, 3 , 4, 5, 8a,8b, 9, 26, PC 1, 2, 3, 9a, 9b, 14, 15, 18, 19, 20, 21

Contributing environmental scenario 1: Formulation of preparations ERC 2

Contributing environmental scenario 2: Formulation of mixtures ERC 3

Contributing worker scenario 1: Use in closed process, no likelihood of exposure

PROC 1

Contributing worker scenario 2: Use in closed, continuous process with occasional controlled exposure

PROC 2

Contributing worker scenario 3: Use in closed batch process (synthesis or formulation)

PROC 3

Contributing worker scenario 4: Use in batch and other process (synthesis) where opportunity for exposure arises

PROC 4

Contributing worker scenario 5: Mixing or blending in batch processes for formulation of preparations and articles (multistage and/or significant con-tact)

PROC 5

Contributing worker scenario 6: Transfer of substance or preparation (charging/discharging) from/to vessels/large containers at non-dedicated facilities

PROC 8a

Contributing worker scenario 7: Transfer of chemicals from/to vessels/ large containers at dedicated facilities

PROC 8b

Contributing worker scenario 8: Transfer of chemicals into small containers (dedicated filling line)

PROC 9

Contributing worker scenario 9: Handling of solid inorganic substances at ambient temperature

PROC 26

Formulation with aluminium dihydrogen triphosphate (industrial setting)

Explanation of technical processes and activities covered: Aluminium dihydrogen triphosphate is an ingredient used in the formulation of preparations and materials. It is also a processing aid in chemical synthesis and fulfils a number of functions. The substance is delivered to formulators or chemical plants by road trucks or rail tanks, unloaded from transport containers, transferred and stored in special storage containers at appropriate facilities. Samples of

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 19/64

NB. Please read the NOTICE on the front page.

the substance may be taken after delivery and analysed for quality assurance in an on-site laboratory. Under industrial conditions, the substance is transferred on demand to the mixing vessel or reactors at dedicated indoor facilities. Formulation and chemical synthesis may be performed in closed continuous or batch processes and may involve extensive blending and mixing steps. Workers operate the processes by remote control carry out regular inspection rounds at each shift. In case of defects, such as leakage of pipes or gaskets, repair and maintenance work is done after the affected part of the system has been separated from the process, completely emptied and flushed with water where possible. Cleaning tasks such as wiping of floors or equipment are performed regularly.

Control of environmental exposure during formulation (ERC2 and ERC 3)

Further specifications

Product characteristics

Physical state of the substance: Aluminium dihydrogen triphosphate is a solid at 20°C and 1013 hPa. The substance may be mixed into solid or liquid formulations. Concentrations of solid aluminium dihydrogen triphosphate are assumed to be 100% w/w, as a worst-case. Concentrations in suspension are assumed to be 50% w/w (max) as a worst-case.

Amounts used

The annual amount of aluminium dihydrogen triphosphate produced has been set between 100-1000 tpa for any single manufacturer / formulator.

Frequency and duration of use

The use of aluminium dihydrogen triphosphate in formulation and synthesis may take place on 365 days a year for 24 hours a day divided into three working shifts. No information about frequency and duration of the various tasks is available.

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value)

Other given operational conditions affecting environmental exposure

Cyclones, scrubbers and filters are used to retain particles and ensure dust emission requirements are met. See below.

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

RMMs are employed as standard in industrial settings, see below.

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

Emissions to waste water are reduced by on-site waste-water treatment. Procedures for water treatment are detailed in the SIC BREF Best Available Techniques for the Production of Speciality Inorganic Chemicals, EC 2006. Treatment measures are dependent on the specific processes and metals involved but direct water emissions are reduced by implementing one or more of the following: - precipitation/ sedimentation/ filtration - crystallisation - chemical oxidation - chemical reduction - nanofiltration/reverse osmosis - adsorption - ion exchange - evaporation - stripping - incineration. The Eurometaux spERC for the manufacture of metal compounds (1.2 v. 2.1) states that removal efficiency using one or more of the above techniques is 99% (50

th percentile).

Further, phosphate removal using physical-chemical treatment methods.

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 20/64

NB. Please read the NOTICE on the front page.

Emissions of particles into the atmosphere are generally considered to be low as the vapour pressure for this material is assumed to be 1x10

-06 Pa at 20°C in accordance with Guidance on information requirements and

chemical safety assessment Appendix R.7.13-2: Environmental risk assessment for metals and metal compounds, June 2008. To prevent the release of dust into the atmosphere, a cyclone and bag filter system is used to retain any particles and ensure that dust emission requirements are met. Other options for reducing emissions are: - Electrostatic precipitators using wide electrode spacing: 5-15 mg/Nm

3

- Wet electrostatic precipitators: 5-15 mg/Nm3

- Cyclones, but as primary collector: < 50 mg/Nm3

- Fabric or bag filters: highly efficient for controlling fine particulate : 10-15 mg/Nm3 . High Efficiency Particule

Arrestation (HEPA) filter or Two-stage dust filter techniques can achieve < 1 mg/Nm3.

Organisational measures to prevent/limit release from site

Good working practice and prevention of releases of waste to floor, water and soil.

Conditions and measures related to municipal sewage treatment plant

Default conditions are assumed.

Conditions and measures related to external treatment of waste for disposal

Most processes are performed under controlled conditions and sampling is considered to be minimal. In addition filtration products are retained and recycled.

Conditions and measures related to external recovery of waste

Not applicable

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

If a site does not comply with the conditions detailed above it is recommended to monitor air and water releases. Phosphate emissions to surface water via industrial wastewater are regulated by Council Directive 96/61/EC concerning integrated pollution prevention and control. The Directive states that phosphates must be taken into account when fixing emission limit values for industrial wastewater.

Control of worker exposure during formulation with aluminium dihydrogen triphosphate

Further specifications:

Product characteristics

Aluminium dihydrogen triphosphate is produced as a solid material.

Amounts used

The annual amount of aluminium dihydrogen triphosphate produced has been set between 100-1000 tpa.

Frequency and duration of use

Continuous exposure is assumed. Formulation processes may be operated on 365 days a year for 24 hours a day. It is assumed that workers will work 8-hr working shifts. A single worker may be exposed on 220 days per year.

Human factors not influenced by risk management

Not applicable.

Other given operational conditions affecting worker exposure

Manufacturing processes are performed indoors in large volume rooms. Exposure is minimised via appropriate risk management measures.

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

The manufacturing process is designed so that exposure is minimised to sampling times and transfer only.

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

Exhaust ventilation may be used for processes where aluminium dihydrogen triphosphate is handled. The efficiency and RMMs should be sufficient to ensure that exposure to dusts is in line with national dust exposure levels. No specific hazards from aluminium dihydrogen triphosphate are identified.

Organisational measures to prevent/limit releases, dispersion and exposure

No specific organisational measures are undertaken, however the following working practices may be used to reduce exposure:

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 21/64

NB. Please read the NOTICE on the front page.

- Use of automated or closed processes and minimisation of manual tasks - Minimisation of splashes and spills - Training of staff on good practice - Management measures to ensure RMMs are used correctly and remain effective - Good standards of personal hygiene

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

Aluminium dihydrogen triphosphate is considered to fall under the hazard band: LOW in accordance with ECHA’s practical guide 15. The following are considered to be appropriate RMMs: - Eye protection: wearing of eye protection is required. Goggles should be consistent with EN166 or equivalent. When mixtures and preparations containing aluminium dihydrogen triphosphate are handled it may be necessary to consider the hazard potential of the additional substances within those mixtures and apply RMMs accordingly.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

See above.

Environmental exposure estimation: Aluminium dihydrogen triphosphate

No direct acute or long-term adverse effects on aqueous or terrestrial organisms are anticipated with aluminium dihydrogen triphosphate in the environment. Aluminium dihydrogen triphosphate is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. Further investigation of bioavailability (i.e. via a TDp protocol) is outside of the scope of REACH and is not considered to be appropriate as the metal ion of interest (aluminium) is not considered to pose a hazard to the aquatic environment. Aluminium dihydrogen triphosphate is not anticipated to contribute to eutrophication as it is insoluble in water and as such the bioavailability of phosphorus (as phosphate) is significantly reduced. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Worker exposure estimation: aluminium dihydrogen triphosphate

It is not considered to be appropriate to use modelling tools to calculate exposure. It is assumed that workplaces adhere to country-specific guidelines with regards to dust exposure. In addition, no specific systemic hazards are present for aluminium dihydrogen triphosphate. Concurrent exposure via various routes of exposure only needs to be accounted for when characterising overall systemic health risks. As the leading health effect of aluminium dihydrogen triphosphate is eye irritation, a local effect, concurrent exposure via various routes of exposure is considered not relevant and no risk characterisation has been performed. Risks relating to the eye irritancy of aluminium dihydrogen phosphate cannot be quantified but can be controlled by the use of protective face shield or goggles. Details of the RMMs are given in the exposure scenarios. Under these use conditions, no local eye effects are expected. Therefore, the identified uses are considered to be safe.

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 22/64

NB. Please read the NOTICE on the front page.

ES3: Industrial use as processing aid and/or pH regulator in the synthesis of other chemicals and use as a laboratory reagent at large scale laboratories.

Exposure Scenario 3: Industrial use as processing aid and/or pH regulator in the synthesis of other chemicals and use as a laboratory reagent at large scale laboratories.

List of applicable use descriptors: ERC 6a, 6b, PROC 1, 2, 3 , 4, 5,

8a,8b, 9, 15, 19, 26, PC 19, 20,

21, SU 8, 9, 24

Contributing environmental scenario 1: Industrial use resulting in manufacture of another substance (use of intermediates)

ERC 6a

Contributing environmental scenario 2: Industrial use of reactive processing aids

ERC 6b

Contributing worker scenario 1: Use in closed process, no likelihood of exposure

PROC 1

Contributing worker scenario 2: Use in closed, continuous process with occasional controlled exposure

PROC 2

Contributing worker scenario 3: Use in closed batch process (synthesis or formulation)

PROC 3

Contributing worker scenario 4: Use in batch and other process (synthesis) where opportunity for exposure arises

PROC 4

Contributing worker scenario 5: Mixing or blending in batch processes for formulation of preparations and articles (multistage and/or significant con-tact)

PROC 5

Contributing worker scenario 6: Transfer of substance or preparation (charging/discharging) from/to vessels/large containers at non-dedicated facilities

PROC 8a

Contributing worker scenario 7: Transfer of chemicals from/to vessels/ large containers at dedicated facilities

PROC 8b

Contributing worker scenario 8: Transfer of chemicals into small containers (dedicated filling line)

PROC 9

Contributing worker scenario 9: Use as laboratory reagent PROC 15

Contributing worker scenario 10: Hand-mixing with intimate contact and only PPE available

PROC 19

Contributing worker scenario 11: Handling of solid inorganic substances at ambient temperature

PROC 26

Industrial use as processing aid and/or pH regulator in the synthesis of other chemicals and use as a laboratory reagent at large scale laboratories.

Explanation of technical processes and activities covered: Aluminium dihydrogen triphosphate is used as a processing aid in chemical synthesis and fulfils a number of functions. The substance is delivered to formulators or chemical plants by road trucks or rail tanks, unloaded from transport containers, transferred and stored in special storage containers at appropriate facilities. Samples of the substance may be taken after delivery and analysed for quality assurance in an on-site laboratory. Under industrial conditions, the substance is transferred on demand to the mixing vessel or reactors at dedicated indoor facilities. Formulation and chemical synthesis may be performed in closed continuous or batch processes and may involve extensive blending and mixing steps. Workers operate the processes by remote control carry out regular inspection rounds at each shift.

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 23/64

NB. Please read the NOTICE on the front page.

In case of defects, such as leakage of pipes or gaskets, repair and maintenance work is done after the affected part of the system has been separated from the process, completely emptied and flushed with water where possible. Cleaning tasks such as wiping of floors or equipment are performed regularly.

Control of environmental exposure during use (ERC 6a and ERC 6b)

Further specifications

Product characteristics

Aluminium dihydrogen triphosphate is supplied as either a solid material or in liquid formulations. Aluminium dihydrogen triphosphate is a solid at 20°C and 1013 hPa. Concentrations of solid aluminium dihydrogen triphosphate are assumed to be 100% w/w, as a worst-case. Concentrations in suspension are assumed to be 50% w/w (max) as a worst-case.

Amounts used

As no quantitative environmental assessment is required, it is not necessary to define the amount of aluminium dihydrogen triphosphate used in this application. As a worst-case: up to 1000 tonnes per year can be considered.

Frequency and duration of use

The use of aluminium dihydrogen triphosphate in synthesis and as a laboratory reagent may take place on 365 days a year for 24 hours a day divided into three working shifts. No information about frequency and duration of the various tasks is available.

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value)

Other given operational conditions affecting environmental exposure

Cyclones, scrubbers and filters are used to retain particles and ensure dust emission requirements are met. See below.

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

RMMs are employed as standard in industrial settings, see below.

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

Emissions to waste water are reduced by on-site waste-water treatment. Procedures for water treatment are detailed in the Integrated Pollution Prevention and Control (IPPC); reference document on the best available techniques in the non-ferrous metal industries (EC, 2001). Treatment measures are dependent on the specific processes and metals involved but direct water emissions are reduced by implementing one or more of the following: - Chemical precipitation - Sedimentation for suspended solids - Filtration for separation of filterable solids - Electrolysis: for low metal concentrations - Reverse osmosis – for dissolved metal ions - Ion exchange – removal of heavy metals from waste water - flow and load equalisation Further, phosphate removal using physical-chemical treatment methods may be in place. Emissions of particles into the atmosphere are generally considered to be low as the vapour pressure for this material is assumed to be 1x10-06 Pa at 20°C in accordance with Guidance on information requirements and chemical safety assessment Appendix R.7.13-2: Environmental risk assessment for metals and metal compounds, June 2008. To prevent the release of dust into the atmosphere, a cyclone and bag filter system is used to retain any particles and ensure that dust emission requirements are met. Other options for reducing emissions are: - Electrostatic precipitators using wide electrode spacing: 5-15 mg/Nm

3

- Wet electrostatic precipitators: 5-15 mg/Nm3

- Cyclones, but as primary collector: < 50 mg/Nm3

- Fabric or bag filters: highly efficient for controlling fine particulate : 10-15 mg/Nm3 . High Efficiency Particule

Arrestation (HEPA) filter or Two-stage dust filter techniques can achieve < 1 mg/Nm3.

Organisational measures to prevent/limit release from site

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 24/64

NB. Please read the NOTICE on the front page.

Good working practice and prevention of releases of waste to floor, water and soil. Process efficiency is maximised to ensure minimal emission to wastewater.

Conditions and measures related to municipal sewage treatment plant

Default conditions are assumed.

Conditions and measures related to external treatment of waste for disposal

Most processes are performed under controlled conditions and sampling is considered to be minimal. In addition filtration products are retained and recycled.

Conditions and measures related to external recovery of waste

Phosphates can be precipitated from wastewater by addition of metal ions and solid/liquid waste incinerated by a licenced contractor.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

If a site does not comply with the conditions detailed above it is recommended to monitor air and water releases. Phosphate emissions to surface water via industrial wastewater are regulated by Council Directive 96/61/EC concerning integrated pollution prevention and control. The Directive states that phosphates must be taken into account when fixing emission limit values for industrial wastewater.

Control of worker exposure during the industrial use of aluminium dihydrogen triphosphate as processing aid and/or pH regulator in the synthesis of other chemicals and use as a laboratory reagent at large scale laboratories.

Further specifications:

Product characteristics

Aluminium dihydrogen triphosphate is supplied as either a solid material or in liquid formulations. Aluminium dihydrogen triphosphate is a solid at 20°C and 1013hPa. Concentrations of solid aluminium dihydrogen triphosphate are assumed to be 100% w/w, as a worst-case. Concentrations in suspension are assumed to be 50 % w/w (max).

Amounts used

As no quantitative assessment is required, it is not necessary to define the amount of aluminium dihydrogen triphosphate used in this application. As a worst-case: up to 1000 tonnes per year can be considered.

Frequency and duration of use

Continuous exposure is assumed. Manufacturing processes may be operated on 365 days a year for 24 hours a day. It is assumed that workers will work 8-hr working shifts. A single worker may be exposed on 220 days per year.

Human factors not influenced by risk management

Bodyweight of workers is assumed to be 70 kg.

Other given operational conditions affecting worker exposure

Industrial synthesis is performed indoors in large volume rooms. Exposure is minimised via appropriate risk management measures.

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

Exposure is minimised to sampling times and transfer only.

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

Exhaust ventilation may be used for processes where aluminium dihydrogen triphosphate is handled. The efficiency and RMMs should be sufficient to ensure that exposure to dusts is in line with national dust exposure levels. No specific hazards from aluminium dihydrogen triphosphate are identified.

Organisational measures to prevent/limit releases, dispersion and exposure

No specific organisational measures are undertaken, however the following working practices may be used to reduce exposure: - Use of automated or closed processes and minimisation of manual tasks - Minimisation of splashes and spills - Training of staff on good practice - Management measures to ensure RMMs are used correctly and remain effective - Good standards of personal hygiene

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

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 25/64

NB. Please read the NOTICE on the front page.

Aluminium dihydrogen triphosphate is considered to fall under the hazard band: LOW in accordance with ECHA’s practical guide 15. The following are considered to be appropriate RMMs: - Eye protection: wearing of eye protection is required. Goggles should be consistent with EN166 or equivalent. When mixtures and preparations containing aluminium dihydrogen triphosphate are handled it may be necessary to consider the hazard potential of the additional substances within those mixtures and apply RMMs accordingly.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

See above.

Environmental exposure estimation: Aluminium dihydrogen triphosphate

No direct acute or long-term adverse effects on aqueous or terrestrial organisms are anticipated with aluminium dihydrogen triphosphate in the environment. Aluminium dihydrogen triphosphate is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. Further investigation of bioavailability (i.e. via a TDp protocol) is outside of the scope of REACH and is not considered to be appropriate as the metal ion of interest (aluminium) is not considered to pose a hazard to the aquatic environment. Aluminium dihydrogen triphosphate is not anticipated to contribute to eutrophication as it is insoluble in water and as such the bioavailability of phosphorus (as phosphate) is significantly reduced. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Worker exposure estimation: aluminium dihydrogen triphosphate

It is not considered to be appropriate to use modelling tools to calculate exposure. It is assumed that workplaces adhere to country-specific guidelines with regards to dust exposure. In addition, no specific systemic hazards are present for aluminium dihydrogen triphosphate. Concurrent exposure via various routes of exposure only needs to be accounted for when characterising overall systemic health risks. As the leading health effect of aluminium dihydrogen triphosphate is eye irritation, a local effect, concurrent exposure via various routes of exposure is considered not relevant and no risk characterisation has been performed. Risks relating to the eye irritancy of aluminium dihydrogen phosphate cannot be quantified but can be controlled by the use of protective face shield or goggles. Details of the RMMs are given in the exposure scenarios. Under these use conditions, no local eye effects are expected. Therefore, the identified uses are considered to be safe.

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 26/64

NB. Please read the NOTICE on the front page.

ES4: Industrial end use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks, etc

Exposure Scenario 4: Industrial end use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks, etc

List of applicable use descriptors: ERC 4, 5, 6b, 7, PROC 5, 6, 7, 8a,

8b, 9, 10, 13, 14, 22, 26, PC 1, 2,

3, 9a, 9b, 14, 15, 18, 20, 32, SU 5,

6a, 6b, 10, 12, 15, 18

Contributing environmental scenario 1: Industrial use of processing aids in processes and products, not becoming part of articles

ERC 4

Contributing environmental scenario 2: Industrial use resulting in inclusion into or onto a matrix

ERC 5

Contributing environmental scenario 3: Industrial use of reactive processing aids

ERC 6b

Contributing environmental scenario 4: Industrial use of substances in closed systems

ERC 7

Contributing worker scenario 1: Mixing or blending in batch processes for formulation of preparations and articles (multistage and/or significant con-tact)

PROC 5

Contributing worker scenario 2: Calendering operations PROC 6

Contributing worker scenario 3: Industrial spraying PROC 7

Contributing worker scenario 4: Transfer of substance or preparation (charging/discharging) from/to vessels/large containers at non-dedicated facilities

PROC 8a

Contributing worker scenario 5: Transfer of substance or preparation (charging/discharging) from/to vessels/large containers at dedicated facilities

PROC 8b

Contributing worker scenario 6: Transfer of substance or preparation into small containers (dedicated filling line, including weighing)

PROC 9

Contributing worker scenario 7: Roller application or brushing PROC 10

Contributing worker scenario 8: Treatment of articles by dipping and pouring

PROC 13

Contributing worker scenario 9: Production of preparations or articles by tabletting, compression, extrusion, pelletisation

PROC 14

Contributing worker scenario 10: Potentially closed processing opera-tions with minerals/metals at elevated temperature Industrial setting.

PROC 22

Contributing worker scenario 11: Handling of solid inorganic substances at ambient temperature

PROC 26

Industrial end use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks.

Explanation of technical processes and activities covered: Aluminium dihydrogen triphosphate acts as a processing aid, corrosion inhibitor and/or a ph-regulating agent in a number of end products, such as plastics, resin, paints, coatings and inks. The substance is delivered to plants by road trucks or rail tanks in liquid or powder form, unloaded from transport containers, transferred and stored in special storage containers at appropriate facilities. Samples of the substance may be taken after delivery and analysed for quality assurance in an on-site laboratory. The substance is transferred on demand to the mixing vessel or reactors at dedicated facilities. The manufacture of plastics, resins and paints may be performed in closed continuous or batch processes and may involve extensive blending and mixing steps. Workers operate the processes by remote control and do regular

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inspection rounds at each shift. In case of defects, such as leakage of pipes or gaskets, repair and maintenance work is done after the affected part of the system has been separated from the process, completely emptied and flushed with water where possible. Cleaning tasks such as wiping of floors or equipment are performed regularly. The manufacture of plastics involves calendering operations, which normally are carried out at elevated temperature and pressure. Use patterns for paints include tasks such as spraying where exposure to airborne droplets of the formulation is possible. Surface treatment solutions are transferred on demand into the coating baths or the spraying facilities. Other compounds may be added to these solutions before they are used in industrial and professional settings where they serve as protective coatings, oxidation inhibitors and for corrosion protection. The metal alkali phosphating is performed mainly in open processes by immersing the metal parts in baths or by spraying phosphate solutions onto the surfaces. On the one hand, phosphating in large companies may be performed in fully automated bathing/spraying lines, where workers are operating the process by remote control, doing regular inspection rounds and performing maintenance, repair and cleaning tasks. On the other hand, phosphating in smaller companies may be done in manual processes involving the manual mixing of solutions, degreasing of metal parts prior to coating, immersion of metal parts in the phosphating bath or spraying of solutions onto metal surfaces and drying the treated parts by wiping or blow-drying. Workers will also regularly perform cleaning and maintenance tasks.

Control of environmental exposure during use (ERCs 4, 5, 6b &7)

Further specifications

Product characteristics

Aluminium dihydrogen triphosphate is a solid at 20°C and 1013 hPa. Concentrations of solid aluminium dihydrogen triphosphate are assumed to be 100% w/w, as a worst-case. Concentrations in suspension are assumed to be 50% w/w (max) as a worst-case.

Amounts used

As no quantitative environmental assessment is required, it is not necessary to define the amount of aluminium dihydrogen triphosphate used in this application.

Frequency and duration of use

Continuous operation (3 shifts of 8 hours on 365 days per year). However, it is likely that tasks such as spraying take place over such shorter time scales, e.g 1-4 hours but may occur more frequently, i.e. twice a day.

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value).

Other given operational conditions affecting environmental exposure

Cyclones, scrubbers and filters are used to retain particles and ensure dust emission requirements are met. See below.

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

RMMs are employed as standard in industrial settings, see below.

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

Emissions to waste water are reduced by on-site waste-water treatment. Procedures for water treatment are detailed in the SIC BREF Best Available Techniques for the Production of Speciality Inorganic Chemicals, EC 2006. Treatment measures are dependent on the specific processes and metals involved but direct water emissions are reduced by implementing one or more of the following: - precipitation/ sedimentation/ filtration - crystallisation - chemical oxidation - chemical reduction - nanofiltration/reverse osmosis - adsorption - ion exchange

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- evaporation - stripping - incineration. The Eurometaux spERC for the manufacture of metal compounds (1.2 v. 2.1) states that removal efficiency using one or more of the above techniques is 99% (50

th percentile).

Further, phosphate removal using physical-chemical treatment methods. Emissions of particles into the atmosphere are generally considered to be low as the vapour pressure for this material is assumed to be 1x10

-06 Pa at 20°C in accordance with Guidance on information requirements and

chemical safety assessment Appendix R.7.13-2: Environmental risk assessment for metals and metal compounds, June 2008. To prevent the release of dust into the atmosphere, a cyclone and bag filter system is used to retain any particles and ensure that dust emission requirements are met. Other options for reducing emissions are: - Electrostatic precipitators using wide electrode spacing: 5-15 mg/Nm

3

- Wet electrostatic precipitators: 5-15 mg/Nm3

- Cyclones, but as primary collector: < 50 mg/Nm3

- Fabric or bag filters: highly efficient for controlling fine particulate : 10-15 mg/Nm3 . High Efficiency Particule

Arrestation (HEPA) filter or Two-stage dust filter techniques can achieve < 1 mg/Nm3.

Organisational measures to prevent/limit release from site

Good working practice and prevention of releases of waste to floor, water and soil. Process efficiency is maximised to ensure minimal emission to wastewater.

Conditions and measures related to municipal sewage treatment plant

Default conditions are assumed.

Conditions and measures related to external treatment of waste for disposal

Most processes are performed under controlled conditions and sampling is considered to be minimal. In addition filtration products are retained and recycled.

Conditions and measures related to external recovery of waste

Not applicable

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

If a site does not comply with the conditions detailed above it is recommended to monitor air and water releases. Phosphate emissions to surface water via industrial wastewater are regulated by Council Directive 96/61/EC concerning integrated pollution prevention and control. The Directive states that phosphates must be taken into account when fixing emission limit values for industrial wastewater.

Control of worker exposure during the industrial end use of aluminium dihydrogen triphosphate as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks, etc

Further specifications:

Product characteristics

Aluminium dihydrogen triphosphate is a solid at 20°C and 1013 hPa. Concentrations of solid aluminium dihydrogen triphosphate are assumed to be 100% w/w, as a worst-case. Concentrations in suspensions are assumed to be 50% w/w (max) as a worst-case.

Amounts used

The annual amounts used have not been determined; however as a worst-case it is prudent to consider the maximum annual tonnage.

Frequency and duration of use

No information about frequency and duration of the various tasks is available. In the first-tier assessment of exposure a frequency of once a day and an exposure duration of 8 hours will be considered. However, it is likely that tasks such as spraying take place over such shorter time scales, e.g 1-4 hours but may occur more frequently, i.e. twice a day.

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Human factors not influenced by risk management

Workers are assumed to be 70 kg.

Other given operational conditions affecting worker exposure

Industrial processes are usually performed indoors in large volume rooms. Exposure is minimised via appropriate risk management measures. The best practice operational conditions for the professional application of coatings or inks (PC 9a, 9b, 9c, 18) have been described by CEPE.

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

Industrial processes are designed so that exposure is minimised.

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

Exhaust ventilation or breathing masks may be used for processes where solid aluminium dihydrogen triphosphate is handled. The efficiency and RMMs should be sufficient to ensure that exposure to dusts is in line with national dust exposure levels. No specific hazards from aluminium dihydrogen triphosphate inhalation are identified.

Organisational measures to prevent/limit releases, dispersion and exposure

No specific organisational measures are undertaken, however the following working practices may be used to reduce exposure: - Use of automated or closed processes and minimisation of manual tasks - Minimisation of splashes and spills - Training of staff on good practice - Management measures to ensure RMMs are used correctly and remain effective - Good standards of personal hygiene - -anti-static safety footwear - anti-static overalls - Gloves to EN374; to protect against skin effects from powders and/or resistant to the solvents in use.

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

Aluminium dihydrogen triphosphate is considered to fall under the hazard band: LOW in accordance with ECHA’s practical guide 15. The following are considered to be appropriate RMMs: - Eye protection: wearing of eye protection is required. Goggles should be consistent with EN166 or equivalent. When mixtures and preparations containing aluminium dihydrogen triphosphate are handled it may be necessary to consider the hazard potential of the additional substances within those mixtures and apply RMMs accordingly. Airborne concentrations of aluminium dihydrogen triphosphate resulting from the handling of suspensions will be negligible if no aerosols are built during the activity.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

See above.

Environmental exposure estimation: Aluminium dihydrogen triphosphate

No direct acute or long-term adverse effects on aqueous or terrestrial organisms are anticipated with aluminium dihydrogen triphosphate in the environment. Aluminium dihydrogen triphosphate is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. Further investigation of bioavailability (i.e. via a TDp protocol) is outside of the scope of REACH and is not considered to be appropriate as the metal ion of interest (aluminium) is not considered to pose a hazard to the aquatic environment. Aluminium dihydrogen triphosphate is not anticipated to contribute to eutrophication as it is insoluble in water and as such the bioavailability of phosphorus (as phosphate) is significantly reduced.

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As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Worker exposure estimation: aluminium dihydrogen triphosphate

It is not considered to be appropriate to use modelling tools to calculate exposure. It is assumed that workplaces adhere to country-specific guidelines with regards to dust exposure. In addition, no specific systemic hazards are present for aluminium dihydrogen triphosphate. Concurrent exposure via various routes of exposure only needs to be accounted for when characterising overall systemic health risks. As the leading health effect of aluminium dihydrogen triphosphate is eye irritation, a local effect, concurrent exposure via various routes of exposure is considered not relevant and no risk characterisation has been performed. Risks relating to the eye irritancy of aluminium dihydrogen phosphate cannot be quantified but can be controlled by the use of protective face shield or goggles. Details of the RMMs are given in the exposure scenarios. Under these use conditions, no local eye effects are expected. Therefore, the identified uses are considered to be safe.

ES5: Industrial end use in building / construction materials and in ceramics.

Exposure Scenario 5: Industrial end use in building / construction materials and in ceramics.

List of applicable use descriptors: ERC 4, 5, 6b, 7, PROC 5, 6, 7, 8a,

8b, 9, 10, 13, 14, 21, 22, 23, 24,

26, PC 1, 2, 9a, 9b, 15, 20, UCN

B20300, UCN R30200 SU 10, 13,

19

Contributing environmental scenario 1: Industrial use of processing aids in processes and products, not becoming part of articles

ERC 4

Contributing environmental scenario 2: Industrial use resulting in inclusion into or onto a matrix

ERC 5

Contributing environmental scenario 3: Industrial use of reactive processing aids

ERC 6b

Contributing environmental scenario 4: Industrial use of substances in closed systems

ERC 7

Contributing worker scenario 1: Mixing or blending in batch processes for formulation of preparations and articles (multistage and/or significant con-tact)

PROC 5

Contributing worker scenario 2: Calendering operations PROC 6

Contributing worker scenario 3: Industrial spraying PROC 7

Contributing worker scenario 4: Transfer of substance or preparation (charging/discharging) from/to vessels/large containers at non-dedicated facilities

PROC 8a

Contributing worker scenario 5: Transfer of substance or preparation (charging/discharging) from/to vessels/large containers at dedicated facilities

PROC 8b

Contributing worker scenario 6: Transfer of substance or preparation PROC 9

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into small containers (dedicated filling line, including weighing)

Contributing worker scenario 7: Roller application or brushing PROC 10

Contributing worker scenario 8: Treatment of articles by dipping and pouring

PROC 13

Contributing worker scenario 9: Production of preparations or articles by tabletting, compression, extrusion, pelletisation

PROC 14

Contributing worker scenario 10: Low energy manipulation of substances bound in materials and/or articles

PROC 21

Contributing worker scenario 11: Potentially closed processing opera-tions with minerals/metals at elevated temperature Industrial setting.

PROC 22

Contributing worker scenario 12: Open processing and transfer operations with minerals/metals at elevated temperature

PROC 23

Contributing worker scenario 13: High (mechanical) energy work-up of substances bound in materials and/or articles

PROC 24

Contributing worker scenario 14: Handling of solid inorganic substances at ambient temperature

PROC 26

Industrial end use in building / construction materials and in ceramics.

Explanation of technical processes and activities covered: Aluminium dihydrogen triphosphate acts as a processing aid, corrosion inhibitor, ph-regulating agent, hardener and/or binding agent in a number of building / construction materials and in ceramics. The substance is delivered to plants by road trucks or rail tanks in liquid or powder form, unloaded from transport containers, transferred and stored in special storage containers at appropriate facilities. The substance is transferred on demand to the mixing vessel or reactors at dedicated facilities. The industrial application is described by the PROC codes selected. The preparations may be applied by spraying, roller application, dipping of articles into the solution, agglomeration and other operations carried out at elevated temperatures. The final ceramic and refractory materials are burned at high temperatures and this burning process leads to a polymerisation and binding of aluminium dihydrogen triphosphate in the material. Afterwards aluminium dihydrogen triphosphate is no longer existent in the final products. Use may occur indoors and outdoors.

Control of environmental exposure during use

Further specifications

Product characteristics

Aluminium dihydrogen triphosphate is a solid at 20°C and 1013hPa. Concentrations of solid aluminium dihydrogen triphosphate are assumed to be 100% w/w, as a worst-case. The pure solid is mixed with other substances before use. The concentration of aluminium dihydrogen triphosphate in suspensions is assumed to be ≤ 50% w/w.

Amounts used

As no quantitative environmental assessment is required, it is not necessary to define the amount of aluminium dihydrogen triphosphate used in this application. The typical substance maximum use rate as defined by spERC EFCC 5.1av.1 is 7500 kg/d.

Frequency and duration of use

Continuous operation (3 shifts of 8 hours on 365 days per year). However, it is likely that tasks such as spraying take place over such shorter time scales, e.g 1-4 hours but may occur more frequently, i.e. twice a day. The number of emitting days per year as described in spERC EFCC 5.1av.1 is 220.

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value).

Other given operational conditions affecting environmental exposure

In accordance with the relevant industry sector spERC (EFCC 5.1a.v1) RMMs are not obligatory for air as releases are considered to be very low (release factor 0.017)

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

In accordance with the relevant industry sector spERC (EFCC 5.1a.v1) waste water emissions are negligible

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as industrial use processes operate without water contact.

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

Operating conditions defined by the following use sector spERCs: EFCC5.1a.v1 The final ceramic and refractory materials are burned at high temperatures and this burning process leads to a polymerisation and binding of aluminium dihydrogen triphosphate in the material. Afterwards aluminium dihydrogen triphosphate is no longer existent in the final products and thus there are no intended releases to the environment. Emissions of particles into the atmosphere are generally considered to be low; aluminium dihydrogen triphosphate is non-volatile and contained within a matrix. As such, RMMs are not obligatory for releases to air. However, cyclones, scrubbers and filters may be used to retain particles and ensure dust emission requirements are met. Other options for reducing emissions are: - Electrostatic precipitators using wide electrode spacing: 5-15 mg/Nm

3

- Wet electrostatic precipitators: 5-15 mg/Nm3

- Cyclones, but as primary collector: < 50 mg/Nm3

- Fabric or bag filters: highly efficient for controlling fine particulate : 10-15 mg/Nm3 . High Efficiency Particule

Arrestation (HEPA) filter or Two-stage dust filter techniques can achieve < 1 mg/Nm3.

Organisational measures to prevent/limit release from site

Good working practice and prevention of releases of waste to floor, water and soil. Process efficiency is maximised to ensure minimal emission to wastewater.

Conditions and measures related to municipal sewage treatment plant

Default conditions are assumed.

Conditions and measures related to external treatment of waste for disposal

Not applicable.

Conditions and measures related to external recovery of waste

Not applicable

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

If a site does not comply with the conditions detailed above it is recommended to monitor air and water releases. Phosphate emissions to surface water via industrial wastewater are regulated by Council Directive 96/61/EC concerning integrated pollution prevention and control. The Directive states that phosphates must be taken into account when fixing emission limit values for industrial wastewater.

Control of worker exposure during the industrial end use in building / construction materials and in ceramics.

Further specifications:

Product characteristics

Aluminium dihydrogen triphosphate is a solid at 20°C and 1013hPa. Concentrations of solid aluminium dihydrogen triphosphate are assumed to be 100% w/w, as a worst-case. The pure solid is mixed with other substances before use. The concentration of aluminium dihydrogen triphosphate in suspensions is assumed to be ≤ 50% w/w.

Amounts used

Not relevant to assessment.

Frequency and duration of use

No information about frequency and duration of the various tasks is available. In the first-tier assessment of exposure a frequency of once a day and an exposure duration of 8 hours will be considered. However, it is likely that tasks such as spraying take place over such shorter time scales, e.g 1-4 hours but may occur more frequently, i.e. twice a day.

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Human factors not influenced by risk management

Workers are considered to weigh 70 kg.

Other given operational conditions affecting worker exposure

Industrial processes are usually performed indoors in large volume rooms however outdoors use may be envisaged. Exposure is minimised via appropriate risk management measures.

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

RMMs are employed. See below.

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

It is assumed that exhaust ventilation or breathing masks (efficiency 95%) may be used for processes where solid aluminium dihydrogen triphosphate is sprayed (as determined by the sector use report: EFCC6). The efficiency and RMMs should be sufficient to ensure that exposure to dusts is in line with national dust exposure levels. No specific hazards from aluminium dihydrogen triphosphate inhalation are identified.

Organisational measures to prevent/limit releases, dispersion and exposure

No specific organisational measures are undertaken, however the following working practices may be used to reduce exposure: - Use of automated or closed processes and minimisation of manual tasks - Minimisation of splashes and spills - Training of staff on good practice - Management measures to ensure RMMs are used correctly and remain effective - Good standards of personal hygiene

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

Aluminium dihydrogen triphosphate is considered to fall under the hazard band: LOW in accordance with ECHA’s practical guide 15. The following are considered to be appropriate RMMs: - Eye protection: wearing of eye protection is required. Goggles should be consistent with EN166 or equivalent. When mixtures and preparations containing aluminium dihydrogen triphosphate are handled it may be necessary to consider the hazard potential of the additional substances within those mixtures and apply RMMs accordingly. Airborne concentrations of aluminium dihydrogen triphosphate resulting from the handling of suspensions will be negligible if no aerosols are generated during the activity. If aerosols are generated for spray applications it will be necessary to consider the hazard profile of all components in the mixture and apply RMM’s accordingly (LEV). It is assumed for all industrial processes, that gloves are worn.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

See above.

Environmental exposure estimation: Aluminium dihydrogen triphosphate

No direct acute or long-term adverse effects on aqueous or terrestrial organisms are anticipated with aluminium dihydrogen triphosphate in the environment. Aluminium dihydrogen triphosphate is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. Further investigation of bioavailability (i.e. via a TDp protocol) is outside of the scope of REACH and is not considered to be appropriate as the metal ion of interest (aluminium) is not considered to pose a hazard to the aquatic environment. Aluminium dihydrogen triphosphate is not anticipated to contribute to eutrophication as it is insoluble in water and as such the bioavailability of phosphorus (as phosphate) is significantly reduced.

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As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Worker exposure estimation: aluminium dihydrogen triphosphate

It is not considered to be appropriate to use modelling tools to calculate exposure. It is assumed that workplaces adhere to country-specific guidelines with regards to dust exposure. In addition, no specific systemic hazards are present for aluminium dihydrogen triphosphate. Concurrent exposure via various routes of exposure only needs to be accounted for when characterising overall systemic health risks. As the leading health effect of aluminium dihydrogen triphosphate is eye irritation, a local effect, concurrent exposure via various routes of exposure is considered not relevant and no risk characterisation has been performed. Risks relating to the eye irritancy of aluminium dihydrogen phosphate cannot be quantified but can be controlled by the use of protective face shield or goggles. Details of the RMMs are given in the exposure scenarios. Under these use conditions, no local eye effects are expected. Therefore, the identified uses are considered to be safe.

ES6: Professional use as an intermediate in synthesis of other chemicals and use as a laboratory reagent.

Exposure Scenario 6: Professional use as an intermediate in synthesis of other chemicals and use as a laboratory reagent.

List of applicable use descriptors: ERC 8a, 8b, 8c, 8d, 8e, 8f; PROC

1, 2, 3, 4, 5, 8a, 8b, 9, 14, 15, 19,

23, 26; PC 18, 19 20, 21; SU 4, 8,

9, 10, 24

Contributing environmental scenario 1: Wide dispersive indoor use of processing aids in open systems

ERC 8a

Contributing environmental scenario 2: Wide dispersive indoor use of reactive substances in open systems

ERC 8b

Contributing environmental scenario 3: Wide dispersive indoor use resulting in inclusion into or onto a matrix

ERC 8c

Contributing environmental scenario 4: Wide dispersive outdoor use of processing aids in open systems

ERC 8d

Contributing environmental scenario 5: Wide dispersive outdoor use of reactive substances in open systems

ERC 8e

Contributing environmental scenario 6: Wide dispersive outdoor use resulting in inclusion into or onto a matrix

ERC 8f

Contributing worker scenario 1: Use in closed process, no likelihood of exposure

PROC 1

Contributing worker scenario 2: Use in closed, continuous process with occasional controlled exposure

PROC 2

Contributing worker scenario 3: Use in closed batch process (synthesis or formulation)

PROC 3

Contributing worker scenario 4: Use in batch and other process (synthesis) where opportunity for exposure arises

PROC 4

Contributing worker scenario 5: Mixing or blending in batch processes PROC 5

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for formulation of preparations and articles (multistage and/or significant con-tact)

Contributing worker scenario 6: Transfer of substance or preparation (charging/discharging) from/to vessels/large containers at non-dedicated facilities

PROC 8a

Contributing worker scenario 7: Transfer of chemicals from/to vessels/ large containers at dedicated facilities

PROC 8b

Contributing worker scenario 8: Transfer of chemicals into small containers (dedicated filling line)

PROC 9

Contributing worker scenario 9: Production of preparation or articles by tableting, compression, extrusion, pelletisation

PROC 14

Contributing worker scenario 10: Use as laboratory reagent PROC 15

Contributing worker scenario 11: Hand-mixing with intimate contact and only PPE available

PROC 19

Contributing worker scenario 12: Open processing and transfer operations with minerals/metals at elevated temperatures

PROC 23

Contributing worker scenario 13: Handling of solid inorganic substances at ambient temperature

PROC 26

Professional use as an intermediate in synthesis of other chemicals and use as a laboratory reagent.

Explanation of technical processes and activities covered: Aluminium dihydrogen triphosphate is used as a processing aid in chemical synthesis and fulfils a number of functions. The substance is delivered to formulators or chemical plants by road trucks or rail tanks, unloaded from transport containers, transferred and stored in special storage containers at appropriate facilities. Samples of the substance may be taken after delivery and analysed for quality assurance in an on-site laboratory. The substance is used as laboratory reagent in a range of chemical reactions. Only small quantities of the substance will be used at once in the course of an experiment, which will be taken from a storage vessel by means of an applicator and added to the reaction mass. Weighing of the substance may be involved. Transfer, weighing and chemical reactions may be carried out inside or outside a fume hood.

Control of environmental exposure during use

Further specifications

Product characteristics

Aluminium dihydrogen triphosphate is a solid at 20°C and 1013hPa. Concentrations of solid aluminium dihydrogen triphosphate are assumed to be 100% w/w, as a worst-case. Concentration in suspensions is assumed to be ≤ 50% w/w.

Amounts used

The amount used in professional synthesis and laboratory settings has not been defined however according to the standard operating conditions defined for the CEFIC RMM library, typically < 1kg / 1L of material is used at any one time.

Frequency and duration of use

The use of aluminium dihydrogen triphosphate in synthesis and as a laboratory reagent may take place on 365 days a year for 24 hours a day divided into three working shifts. No information about frequency and duration of the various tasks is available.

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value)

Other given operational conditions affecting environmental exposure

Cyclones, scrubbers and filters are used to retain particles and ensure dust emission requirements are met. See below.

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

See below.

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

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In professional settings Emissions of particles into the air of workplaces or the atmosphere can be significantly reduced by the use of cyclones, gas scrubbers or bag filters. The efficiency of the process is maximised in such a way that minimal emission of phosphates into the wastewater will occur. In addition, phosphate can be precipitated from the wastewater by addition of metal ions. Solid waste will be appropriately incinerated or disposed of as chemical waste.

Organisational measures to prevent/limit release from site

Good working practice and prevention of releases of waste to floor, water and soil.

Conditions and measures related to municipal sewage treatment plant

Default conditions are assumed.

Conditions and measures related to external treatment of waste for disposal

Not applicable.

Conditions and measures related to external recovery of waste

Phosphates can be precipitated from wastewater by addition of metal ions and solid/liquid waste incinerated by a licenced contractor.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Phosphate emissions to surface water via industrial wastewater are regulated by Council Directive 96/61/EC concerning integrated pollution prevention and control. The Directive states that phosphates must be taken into account when fixing emission limit values for industrial wastewater.

Control of worker exposure during the use of aluminium dihydrogen triphosphate

Further specifications:

Product characteristics

Aluminium dihydrogen triphosphate is supplied as either a solid material or in liquid formulations.

Amounts used

The amount used in professional synthesis and laboratory settings has not been defined however according to the standard operating conditions defined for the CEFIC RMM library, typically < 1kg / 1L of material is used at any one time.

Frequency and duration of use

No information about the frequency or duration of use is available, however it is anticipated that exposure does not exceed 8 hours.

Human factors not influenced by risk management

Workers are assumed to weigh 70 kg. Direct contact during processing tasks is considered to be minimal.

Other given operational conditions affecting worker exposure

Exposure may occur during weighing and transfer operations. If performed in a fume hood these operations are considered to result in minimal exposure. It is also considered likely that LEV (or at the very least general ventilation) is used in a professional setting.

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

Chemicals are handled according to health and safety assessments made by the laboratory technicians.

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

Fume cupboards will prevent dispersion from source, however due to the very low vapour pressure (assumed to be 1x10

-06 Pa at 20°C in accordance with Guidance on information requirements and chemical safety

assessment Appendix R.7.13-2: Environmental risk assessment for metals and metal compounds, June 2008) of this material this is not considered to be a key hazard.

Organisational measures to prevent/limit releases, dispersion and exposure

No specific organisational measures are undertaken, however the following working practices may be used to reduce exposure: - Use of automated or closed processes and minimisation of manual tasks - Minimisation of splashes and spills - Training of staff on good practice - Management measures to ensure RMMs are used correctly and remain effective - Good standards of personal hygiene

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 37/64

NB. Please read the NOTICE on the front page.

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

Aluminium dihydrogen triphosphate is considered to fall under the hazard band: LOW in accordance with ECHA’s practical guide 15. The following are considered to be appropriate RMMs: - Eye protection: wearing of eye protection is required. Goggles should be consistent with EN166 or equivalent. When mixtures and preparations containing aluminium dihydrogen triphosphate are handled it may be necessary to consider the hazard potential of the additional substances within those mixtures and apply RMMs accordingly. It is good practice to wear chemical impervious gloves when handling chemicals.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

See above.

Environmental exposure estimation: Aluminium dihydrogen triphosphate

No direct acute or long-term adverse effects on aqueous or terrestrial organisms are anticipated with aluminium dihydrogen triphosphate in the environment. Aluminium dihydrogen triphosphate is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. Further investigation of bioavailability (i.e. via a TDp protocol) is outside of the scope of REACH and is not considered to be appropriate as the metal ion of interest (aluminium) is not considered to pose a hazard to the aquatic environment. Aluminium dihydrogen triphosphate is not anticipated to contribute to eutrophication as it is insoluble in water and as such the bioavailability of phosphorus (as phosphate) is significantly reduced. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Worker exposure estimation: aluminium dihydrogen triphosphate

It is not considered to be appropriate to use modelling tools to calculate exposure. It is assumed that workplaces adhere to country-specific guidelines with regards to dust exposure. In addition, no specific systemic hazards are present for aluminium dihydrogen triphosphate. Concurrent exposure via various routes of exposure only needs to be accounted for when characterising overall systemic health risks. As the leading health effect of aluminium dihydrogen triphosphate is eye irritation, a local effect, concurrent exposure via various routes of exposure is considered not relevant and no risk characterisation has been performed. Risks relating to the eye irritancy of aluminium dihydrogen phosphate cannot be quantified but can be controlled by the use of protective face shield or goggles. Details of the RMMs are given in the exposure scenarios. Under these use conditions, no local eye effects are expected. Therefore, the identified uses are considered to be safe.

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 38/64

NB. Please read the NOTICE on the front page.

ES7: Professional use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks

Exposure Scenario 7: Professional use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks

List of applicable use descriptors: ERC 8a, 8b, 8c, 8d, 8e, 8f;

PROC 5, 8a, 8b, 10, 11, 13, 14,

19, 21, 23, 24, 26; PC 1, 2, 3,

9a, 9b, 14, 15, 18, 20,32 ; SU

5, 6a, 6b, 10, 12, 15, 18

Contributing environmental scenario 1: Wide dispersive indoor use of processing aids in open systems

ERC 8a

Contributing environmental scenario 2: Wide dispersive indoor use of reactive substances in open systems

ERC 8b

Contributing environmental scenario 3: Wide dispersive indoor use resulting in inclusion into or onto a matrix

ERC 8c

Contributing environmental scenario 4: Wide dispersive outdoor use of processing aids in open systems

ERC 8d

Contributing environmental scenario 5: Wide dispersive outdoor use of reactive substances in open systems

ERC 8e

Contributing environmental scenario 6: Wide dispersive outdoor use resulting in inclusion into or onto a matrix

ERC 8f

Contributing worker scenario 1: Mixing or blending in batch processes for formulation of preparations and articles (multistage and/or significant con-tact)

PROC 5

Contributing worker scenario 2: Transfer of substance or preparation (charging/discharging) from/to vessels/large containers at non-dedicated facilities

PROC 8a

Contributing worker scenario 3: Transfer of chemicals from/to vessels/ large containers at dedicated facilities

PROC 8b

Contributing worker scenario 4: Roller application or brushing PROC 10

Contributing worker scenario 5: Non industrial spraying PROC 11

Contributing worker scenario 6: Treatment of articles by dipping and pouring

PROC 13

Contributing worker scenario 7: Production of preparation or articles by tableting, compression, extrusion, pelletisation

PROC 14

Contributing worker scenario 8: Hand-mixing with intimate contact and only PPE available

PROC 19

Contributing worker scenario 9: Low energy manipulation of substances bound in materials and/or articles

PROC 21

Contributing worker scenario 10: Open processing and transfer operations with minerals/metals at elevated temperatures

PROC 23

Contributing worker scenario 11: High (mechanical) energy work-up of substances bound in materials and/or articles

PROC 24

Contributing worker scenario 12: Handling of solid inorganic substances at ambient temperature

PROC 26

Professional use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks

Explanation of technical processes and activities covered: Aluminium dihydrogen triphosphate is used as a corrosion inhibitor, pH regulating agent and/or a processing aid in the formulation of and use of plastics, resins, paints, coatings and inks.

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 39/64

NB. Please read the NOTICE on the front page.

The substance is delivered to formulators or chemical plants by road trucks or rail tanks, unloaded from transport containers, transferred and stored in special storage containers at appropriate facilities. The substance is transferred on demand to the mixing vessel or reactors at dedicated facilities. The manufacture of plastics, resins and paints may be performed in closed continuous or batch processes and may involve extensive blending and mixing steps. Workers operate the processes by remote control and do regular inspection rounds at each shift. In case of defects, such as leakage of pipes or gaskets, repair and maintenance work is done after the affected part of the system has been separated from the process, completely emptied and flushed with water where possible. Cleaning tasks such as wiping of floors or equipment are performed regularly. The manufacture of plastics involves calendering operations, which normally are carried out at elevated temperature and pressure. Professional uses also involve the application of the final products via painting, rolling and spray applications.

Control of environmental exposure during use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks

Further specifications

Product characteristics

Aluminium dihydrogen triphosphate is a solid at 20°C and 1013hPa. Concentrations of solid aluminium dihydrogen triphosphate are assumed to be 100% w/w, as a worst-case. The maximum concentration in suspensions is considered to be 50% w/w.

Amounts used

As no quantitative environmental assessment is required, it is not necessary to define the amount of aluminium dihydrogen triphosphate used in this application.

Frequency and duration of use

The use of aluminium dihydrogen triphosphate as an additive in plastics, resins and paints may take place on 365 days a year for 24 hours a day divided into three working shifts. No information about frequency and duration of the various tasks is available but a worst-case of 8 hours per day is assumed.

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value)

Other given operational conditions affecting environmental exposure

Cyclones, scrubbers and filters are used to retain particles and ensure dust emission requirements are met. See below.

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

See below.

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

In professional settings emissions of particles into the air of workplaces or the atmosphere can be significantly reduced by the use of cyclones, gas scrubbers or bag filters. Phosphate can be precipitated from the wastewater by addition of metal ions. Solid waste will be appropriately incinerated or disposed of as chemical waste. The following spERCs are considered to accurately describe the processes identified and the relevant conditions of use for the application of coatings, paints and inks. Professional spraying and application by brush/roller of coatings/paints and inks : CEPE SPERC 8a.2a.v1- application - professional - bush/roller - indoor use - volatiles CEPE SPERC 8c.2a.v1 - application - professional - bush/roller - indoor use - solids CEPE SPERC 8d.2a.v1 - application - professional - bush/roller - outdoor use - volatiles CEPE SPERC 8f.2a.v1 - application - professional - bush/roller - outdoor use – solids

Organisational measures to prevent/limit release from site

Good working practice and prevention of releases of waste to floor, water and soil.

Conditions and measures related to municipal sewage treatment plant

SAFETY DATA SHEET Date of issue: xxx

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Revision date: X Version: XX Page 40/64

NB. Please read the NOTICE on the front page.

Default conditions are assumed.

Conditions and measures related to external treatment of waste for disposal

Not applicable.

Conditions and measures related to external recovery of waste

Phosphates can be precipitated from wastewater by addition of metal ions and solid/liquid waste incinerated by a licenced contractor.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Phosphate emissions to surface water via industrial wastewater are regulated by Council Directive 96/61/EC concerning integrated pollution prevention and control. The Directive states that phosphates must be taken into account when fixing emission limit values for industrial wastewater.

Control of worker exposure during the use of aluminium dihydrogen triphosphate as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks

Further specifications:

Product characteristics

Aluminium dihydrogen triphosphate is supplied as either a solid material or in liquid formulations.

Amounts used

The amount of aluminium dihydrogen triphosphate has not been defined.

Frequency and duration of use

4 - 8 hours , 225 days per annum (defined by CEPE)

Human factors not influenced by risk management

Workers are assumed to weigh 70 kg. Direct contact during processing tasks is considered to be minimal.

Other given operational conditions affecting worker exposure

The best practice operational conditions for the professional application of coatings or inks (PC 9a, 9b, 9c, 18) have been described by CEPE. It is envisaged that in an industrial setting engineering controls may be in place to reduce respiratory exposure, If not then the use of a half-mask respirator to EN 529 is likely.

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

It is envisaged that in a professional setting engineering controls may be in place to reduce respiratory exposure, If not then the use of a half-mask respirator to EN 529 is likely.

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

As above.

Organisational measures to prevent/limit releases, dispersion and exposure

No specific organisational measures are undertaken, however the following working practices may be used to reduce exposure and are identified as being likely RMMs by the trade organisation CEPE: - Use of automated or closed processes and minimisation of manual tasks - Minimisation of splashes and spills - Training of staff on good practice - Management measures to ensure RMMs are used correctly and remain effective - Good standards of personal hygiene - anti-static safety footwear - anti-static overalls - Gloves to EN374; to protect against skin effects from powders and/or resistant to the solvents in use.

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

Aluminium dihydrogen triphosphate is considered to fall under the hazard band: LOW in accordance with ECHA’s practical guide 15. The following are considered to be appropriate RMMs to adequately address the specific hazard from aluminium dihydrogen triphosphate:

SAFETY DATA SHEET Date of issue: xxx

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Revision date: X Version: XX Page 41/64

NB. Please read the NOTICE on the front page.

- Eye protection: wearing of eye protection is required. Goggles should be consistent with EN166 or equivalent. They should also be designed to protect against splashes. When mixtures and preparations containing aluminium dihydrogen triphosphate are handled it may be necessary to consider the hazard potential of the additional substances within those mixtures and apply RMMs accordingly. It is good practice to wear chemical impervious gloves (EN 374) when handling chemicals.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

See above.

Environmental exposure estimation: Aluminium dihydrogen triphosphate

No direct acute or long-term adverse effects on aqueous or terrestrial organisms are anticipated with aluminium dihydrogen triphosphate in the environment. Aluminium dihydrogen triphosphate is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. Further investigation of bioavailability (i.e. via a TDp protocol) is outside of the scope of REACH and is not considered to be appropriate as the metal ion of interest (aluminium) is not considered to pose a hazard to the aquatic environment. Aluminium dihydrogen triphosphate is not anticipated to contribute to eutrophication as it is insoluble in water and as such the bioavailability of phosphorus (as phosphate) is significantly reduced. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Worker exposure estimation: aluminium dihydrogen triphosphate

It is not considered to be appropriate to use modelling tools to calculate exposure. It is assumed that workplaces adhere to country-specific guidelines with regards to dust exposure. In addition, no specific systemic hazards are present for aluminium dihydrogen triphosphate. Concurrent exposure via various routes of exposure only needs to be accounted for when characterising overall systemic health risks. As the leading health effect of aluminium dihydrogen triphosphate is eye irritation, a local effect, concurrent exposure via various routes of exposure is considered not relevant and no risk characterisation has been performed. Risks relating to the eye irritancy of aluminium dihydrogen phosphate cannot be quantified but can be controlled by the use of protective face shield or goggles. Details of the RMMs are given in the exposure scenarios. Under these use conditions, no local eye effects are expected. Therefore, the identified uses are considered to be safe.

ES8: Professional use in construction materials and ceramics: in coating systems, as a binding agent and as a silicate hardener

Exposure Scenario 8: Professional use in construction materials and ceramics: in coating systems, as a binding agent and as a silicate hardener

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 42/64

NB. Please read the NOTICE on the front page.

List of applicable use descriptors: ERC 8a, 8b, 8c, 8d, 8e, 8f;

PROC 5, 8a, 8b, 9, 10, 11, 14,

19, 26; PC 1, 2, 9a, 9b, 15, 20,

UCN H15500, R30200 ; SU 10,

13, 19

Contributing environmental scenario 1: Wide dispersive indoor use of processing aids in open systems

ERC 8a

Contributing environmental scenario 2: Wide dispersive indoor use of reactive substances in open systems

ERC 8b

Contributing environmental scenario 3: Wide dispersive indoor use resulting in inclusion into or onto a matrix

ERC 8c

Contributing environmental scenario 4: Wide dispersive outdoor use of processing aids in open systems

ERC 8d

Contributing environmental scenario 5: Wide dispersive outdoor use of reactive substances in open systems

ERC 8e

Contributing environmental scenario 6: Wide dispersive outdoor use resulting in inclusion into or onto a matrix

ERC 8f

Contributing worker scenario 1: Mixing or blending in batch processes for formulation of preparations and articles (multistage and/or significant con-tact)

PROC 5

Contributing worker scenario 2: Transfer of substance or preparation (charging/discharging) from/to vessels/large containers at non-dedicated facilities

PROC 8a

Contributing worker scenario 3: Transfer of chemicals from/to vessels/ large containers at dedicated facilities

PROC 8b

Contributing worker scenario 4: Transfer of substance or preparation into small containers (dedicated filling line including weighing)

PROC 9

Contributing worker scenario 4: Roller application or brushing PROC 10

Contributing worker scenario 6: Non industrial spraying PROC 11

Contributing worker scenario 7: Production of preparation or articles by tableting, compression, extrusion, pelletisation

PROC 14

Contributing worker scenario 8: Hand-mixing with intimate contact and only PPE available

PROC 19

Contributing worker scenario 9: Handling of solid inorganic substances at ambient temperature

PROC 26

Professional use in construction materials and ceramics: in coating systems, as a binding agent and as a silicate hardener

Explanation of technical processes and activities covered: Aluminium dihydrogen triphosphate acts as a processing aid, corrosion inhibitor, ph-regulating agent, hardener and/or binding agent in a number of building / construction materials and in ceramics. The substance is delivered to plants by road trucks or rail tanks in liquid or powder form, unloaded from transport containers, transferred and stored in special storage containers at appropriate facilities. The substance is transferred on demand to the mixing vessel or reactors at dedicated facilities. The industrial application is described by the PROC codes selected. The preparations may be applied by spraying, roller application, dipping of articles into the solution, agglomeration and other operations carried out at elevated temperatures. The final ceramic and refractory materials are burned at high temperatures and this burning process leads to a polymerisation and binding of aluminium dihydrogen triphosphate in the material. Afterwards aluminium dihydrogen triphosphate is no longer existent in the final products. Use may occur indoors and outdoors.

Control of environmental exposure during professional use in construction materials and ceramics: in coating systems, as a binding agent and as a silicate hardener

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 43/64

NB. Please read the NOTICE on the front page.

Further specifications

Product characteristics

Aluminium dihydrogen triphosphate is a solid at 20°C and 1013hPa. Concentrations of solid aluminium dihydrogen triphosphate are assumed to be 100% w/w, as a worst-case. The concentration in suspensions is considered to be 50% w/w.

Amounts used

As no quantitative environmental assessment is required, it is not necessary to define the amount of aluminium dihydrogen triphosphate used in this application.

Frequency and duration of use

The use of aluminium dihydrogen triphosphate in construction materials may take place on 365 days a year for 24 hours a day divided into three working shifts (spERC Emitting days: 365).

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value)

Other given operational conditions affecting environmental exposure

None.

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

None. Professional and consumer product use with limited or no technical control of emission.

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

In professional settings emissions of particles into the air of workplaces or the atmosphere can be significantly reduced by the use of cyclones, gas scrubbers or bag filters. Phosphate can be precipitated from the wastewater by addition of metal ions. Solid waste will be appropriately incinerated or disposed of as chemical waste. The following spERCs are considered to accurately describe environmental exposure and the processes identified for this use: EFCC SPERC 8c.1a.v1 Wide dispersive use of non-volatile substances in construction chemicals, indoor EFCC SPERC 8f.1a.v1 Wide dispersive use of non-volatile substances in construction chemicals, outdoor The final construction materials are burned /cured at high temperatures and this burning process leads to a polymerisation and binding of aluminium dihydrogen triphosphate in the material. Afterwards aluminium dihydrogen triphosphate is no longer existent in the final products and thus there are no intended releases to the environment.

Organisational measures to prevent/limit release from site

Good working practice and prevention of releases of waste to floor, water and soil. Assumptions from relevant spERCs: Release factor to air (EFCC 8c.1a.v1 and EFCC 8f.1a.v1): 0 Release factor to soil (EFCC 8c.1a.v1 and EFCC 8f.1a.v1): 0 Release factor to water (EFCC 8c.1a.v1 and EFCC 8f.1a.v1): 0.01

Conditions and measures related to municipal sewage treatment plant

None. Release factor to waste (EFCC 8c.1a.v1 and EFCC 8f.1a.v1): 0

Conditions and measures related to external treatment of waste for disposal

Not applicable.

Conditions and measures related to external recovery of waste

Phosphates can be precipitated from wastewater by addition of metal ions and solid/liquid waste incinerated by a licenced contractor.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Phosphate emissions to surface water via industrial wastewater are regulated by Council Directive

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 44/64

NB. Please read the NOTICE on the front page.

96/61/EC concerning integrated pollution prevention and control. The Directive states that phosphates must be taken into account when fixing emission limit values for industrial wastewater.

Control of worker exposure during professional use in construction materials and ceramics: in coating systems, as a binding agent and as a silicate hardener

Further specifications:

Product characteristics

Aluminium dihydrogen triphosphate is supplied as either a solid material or in liquid formulations.

Amounts used

The amount of aluminium dihydrogen triphosphate has not been defined.

Frequency and duration of use

Frequency and duration of certain tasks are defined by the relevant industry use reports (EFCC 8, ECC10) and are as follows: - PROC 8a: 1-4 hrs/day, 5 days/week - PROC 10: 8 hrs/day, 5 days/week - PROC 13: 8 hrs/day, 5 days/week For those processes not mentioned in the use report, a working day of 8 hours is considered.

Human factors not influenced by risk management

Workers are assumed to weigh 70 kg. Direct contact during processing tasks is considered to be minimal.

Other given operational conditions affecting worker exposure

None.

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

It is envisaged that in a professional setting engineering controls may be in place to reduce respiratory exposure, If not then the use of a half-mask respirator to EN 529 is likely.

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

As above.

Organisational measures to prevent/limit releases, dispersion and exposure

No specific organisational measures are undertaken, however the following working practices may be used to reduce exposure and are identified as being likely RMMs: - Use of automated or closed processes and minimisation of manual tasks - Minimisation of splashes and spills - Training of staff on good practice - Management measures to ensure RMMs are used correctly and remain effective - Good standards of personal hygiene - Gloves to EN374; to protect against skin effects from powders and/or resistant to the solvents in use.

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

Aluminium dihydrogen triphosphate is considered to fall under the hazard band: LOW in accordance with ECHA’s practical guide 15. The following are considered to be appropriate RMMs to adequately address the specific hazard from aluminium dihydrogen triphosphate: - Eye protection: wearing of eye protection is required. Goggles should be consistent with EN166 or equivalent. They should also be designed to protect against splashes. When mixtures and preparations containing aluminium dihydrogen triphosphate are handled it may be necessary to consider the hazard potential of the additional substances within those mixtures and apply RMMs accordingly. It is good practice to wear chemical impervious gloves (EN 374) when handling chemicals.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 45/64

NB. Please read the NOTICE on the front page.

See above.

Environmental exposure estimation: Aluminium dihydrogen triphosphate

No direct acute or long-term adverse effects on aqueous or terrestrial organisms are anticipated with aluminium dihydrogen triphosphate in the environment. Aluminium dihydrogen triphosphate is an insoluble inorganic material and is not considered to be bioavailable in aquatic environments. Further investigation of bioavailability (i.e. via a TDp protocol) is outside of the scope of REACH and is not considered to be appropriate as the metal ion of interest (aluminium) is not considered to pose a hazard to the aquatic environment. Aluminium dihydrogen triphosphate is not anticipated to contribute to eutrophication as it is insoluble in water and as such the bioavailability of phosphorus (as phosphate) is significantly reduced. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Worker exposure estimation: aluminium dihydrogen triphosphate

It is not considered to be appropriate to use modelling tools to calculate exposure. It is assumed that workplaces adhere to country-specific guidelines with regards to dust exposure. In addition, no specific systemic hazards are present for aluminium dihydrogen triphosphate. Concurrent exposure via various routes of exposure only needs to be accounted for when characterising overall systemic health risks. As the leading health effect of aluminium dihydrogen triphosphate is eye irritation, a local effect, concurrent exposure via various routes of exposure is considered not relevant and no risk characterisation has been performed. Risks relating to the eye irritancy of aluminium dihydrogen phosphate cannot be quantified but can be controlled by the use of protective face shield or goggles. Details of the RMMs are given in the exposure scenarios. Under these use conditions, no local eye effects are expected. Therefore, the identified uses are considered to be safe.

ES9: Consumer use of paints, coatings and varnishes containing aluminium dihydrogen triphosphate

Exposure Scenario 9: Consumer use of paints, coatings and varnishes containing aluminium dihydrogen triphosphate

List of applicable use descriptors: SU Not applicable; PC 1, 9a; PROC Not applicable; ERC 8c, 8f

Contributing environmental scenario: wide dispersive indoor/outdoor use resulting in inclusion into or onto a matrix

ERC 8c, 8f

Contributing consumer scenario 1: Adhesives, sealants PC 1

Contributing consumer scenario 2: Coatings and paints, thinners, paint removers

PC 9a

Consumer use of paints, coatings and varnishes containing aluminium dihydrogen triphosphate

Explanation of technical processes and activities covered: Aluminium dihydrogen triphosphate performs the following technical functions in paints, coatings and varnishes: - corrosion inhibitor - processing aid

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 46/64

NB. Please read the NOTICE on the front page.

- pH-regulating agent Consumers may perform mixing and loading processes as well as rolling, brushing, spraying applications. It is assumed that consumers will not always wear PPE.

Control of environmental exposure during consumer use of paints, coatings and varnishes containing aluminium dihydrogen phosphate.

Further specifications:

Product characteristics

Products contain <10% aluminium dihydrogen triphosphate.

Amounts used

According to the relevant sector-specific spERCs (CEPE 8c.1a.v1, CEPE 8f.1a.v1) the use of 5kg product per day at any one location is anticipated. For a substance that is used as a binder that relates to a Maximum use for any one substance (MSPERC) of 0.5 kg/d and for additives 0.03 kg/d.

Frequency and duration of use

Dispersive use Continuous release: 365 d/y

Environment factors not influenced by risk management

Local freshwater dilution factor: 10 Local marine dilution factor: 100 Receiving surface water flow is 18,000 m3/d (REACH defaults)

Other given operational conditions affecting environmental exposure

Indoor and outdoor use. Consumer product use leading of emissions to air. Consumer product use leading to disposal via wastewater. Consumer product use with limited or no technical control of emission. During application of coatings outdoors, a proportion of the applied coating can be deposited on the soil below the area being painted. No exposure to soil from indoor application. No emissions to air are anticipated.

Conditions and measures related to municipal sewage Treatment plant

Application equipment (brushes/rollers/containers/roller trays) can be washed in domestic sinks and washings discharged into public sewers.

Conditions and measures related to external Treatment of waste for disposal

Not applicable.

Conditions and measures related to external recovery of waste

No direct acute or long-term adverse effects on aqueous or terrestrial organisms are reported for orthophosphates. However, phosphates are a key nutrient for plants and elevated phosphates levels in water can lead to excessive growth of algae and other aquatic plants (eutrophication) if phosphate is the growth limiting factor. Although in some cases nutrient enrichment will be absorbed and have no effect, in other circumstances it can lead to a negative effect. Sewage treatment may be necessary to prevent ecosystem modification ranging from algal blooms to extreme cases of oxygen depletion and collapse of biocenosis in surface water.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Council directive 91/271/EEC concerning urban waste water requires phosphate removal from sewage, wherever receiving waters are potentially susceptible to eutrophication, in agglomerations >10,000 person equivalents. This requirement is confirmed by the EU Water Framework Directive 2000/60, which also further requires phosphate removal in smaller agglomerations where this is necessary to achieve water quality standards. The directives are not yet fully implemented in all new EU member states. This should be done by end of 2018.

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 47/64

NB. Please read the NOTICE on the front page.

Control of consumer exposure during consumer use of paints, coatings and varnishes containing aluminium dihydrogen phosphate.

Further specifications:

Product characteristics

Products contain <10% aluminium dihydrogen triphosphate.

Amounts used

According to the relevant sector-specific spERCs (CEPE 8c.1a.v1, CEPE 8f.1a.v1) the use of 5kg product per day at any one location is anticipated. For a substance that is used as a binder that relates to a Maximum use for any one substance (MSPERC) of 0.5 kg/d and for additives 0.03 kg/d.

Frequency and duration of use/exposure

Dispersive use Continuous release: 365 d/y

Human factors not influenced by risk management

Consumers on average have a body weight of 60 kg (females) or 70 kg (males).

Other given factors affecting consumer exposure

It is anticipated as a worst-case that consumers will not wear PPE.

Conditions and measures related to information and behavioural advice to consumers

Consumers should observe the safety warnings on the product (S-phrases)

Conditions and measures related to personal protection and hygiene

Paints, coatings and varnishes should be used only in well-ventilated areas.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Refer to product labels.

Environmental exposure estimation: Consumer use of paints, coatings and varnishes containing aluminium dihydrogen triphosphate

The substance is not classified for environmental effects and quantitative assessment of exposure is unnecessary. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Consumer exposure estimation: Consumer use of paints, coatings and varnishes containing aluminium dihydrogen triphosphate

No consumer estimation is considered to be appropriate. The substance is not classified as systemically toxic and is only present in products at <10% w/w and as such the hazards of the product will be based on the mixture of all components and no specific hazards are expected from aluminium dihydrogen triphosphate at this level. Therefore, no further risk characterisation is performed.

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ES10: Consumer use of inks and toners containing aluminium dihydrogen triphosphate

Exposure Scenario 10: Consumer use of inks and toners containing aluminium dihydrogen triphosphate

List of applicable use descriptors: SU Not applicable; PC 9a, 9b, 18; PROC Not applicable; ERC 8c

Contributing environmental scenario: Wide dispersive indoor use resulting in inclusion into or onto a matrix

ERC 8c

Contributing consumer scenario 1: Coatings and paints, thinners, paint removers

PC 9a

Contributing consumer scenario 2: Fillers, putties, plaster, modelling clay

PC 9b

Contributing consumer scenario 3: Ink and toners PC 18

Consumer use of inks and toners containing aluminium dihydrogen triphosphate

Explanation of technical processes and activities covered: Aluminium dihydrogen triphosphate performs the following technical functions in inks and toners: - corrosion inhibitor - processing aid - pH-regulating agent

Control of environmental exposure during consumer use of inks and toners containing aluminium dihydrogen triphosphate

Further specifications:

Product characteristics

Products contain <10% aluminium dihydrogen triphosphate.

Amounts used

According to the relevant sector-specific spERCs (CEPE 8c.1a.v1, CEPE 8f.1a.v1) the use of 5kg product per day at any one location is anticipated.

Frequency and duration of use

Dispersive use Continuous release: 365 d/y

Environment factors not influenced by risk management

Local freshwater dilution factor: 10 Local marine dilution factor: 100 Receiving surface water flow is 18,000 m3/d (REACH defaults)

Other given operational conditions affecting environmental exposure

Consumer product use leading to disposal via wastewater. Consumer product use with limited or no technical control of emission. No emissions to air are anticipated. Aluminium dihydrogen triphosphate is contained within a matrix and as such exposure is considered to be negligible.

Conditions and measures related to municipal sewage Treatment plant

Application equipment can be washed in domestic sinks and washings discharged into public sewers.

Conditions and measures related to external treatment of waste for disposal

Not applicable.

Conditions and measures related to external recovery of waste

No direct acute or long-term adverse effects on aqueous or terrestrial organisms are reported for orthophosphates. However, phosphates are a key nutrient for plants and elevated phosphates levels in water can lead to excessive growth of algae and other aquatic plants (eutrophication) if phosphate is the growth limiting factor. Although in some cases nutrient enrichment will be absorbed and have no effect, in other

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circumstances it can lead to a negative effect. Sewage treatment may be necessary to prevent ecosystem modification ranging from algal blooms to extreme cases of oxygen depletion and collapse of biocenosis in surface water.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Council directive 91/271/EEC concerning urban waste water requires phosphate removal from sewage, wherever receiving waters are potentially susceptible to eutrophication, in agglomerations >10,000 person equivalents. This requirement is confirmed by the EU Water Framework Directive 2000/60, which also further requires phosphate removal in smaller agglomerations where this is necessary to achieve water quality standards. The directives are not yet fully implemented in all new EU member states. This should be done by end of 2018.

Control of consumer exposure during consumer use of inks and toners containing aluminium dihydrogen triphosphate

Further specifications:

Product characteristics

Products contain <10% aluminium dihydrogen triphosphate.

Amounts used

According to the relevant sector-specific spERCs (CEPE 8c.1a.v1, CEPE 8f.1a.v1) the use of 5kg product per day at any one location is anticipated.

Frequency and duration of use/exposure

Dispersive use Continuous release: 365 d/y

Human factors not influenced by risk management

Consumers on average have a body weight of 60 kg (females) or 70 kg (males).

Other given factors affecting consumer exposure

It is anticipated as a worst-case that consumers will not wear PPE however, aluminium dihydrogen triphosphate is contained within a matrix and as such exposure is considered to be negligible.

Conditions and measures related to information and behavioural advice to consumers

Consumers should observe the safety warnings on the product (S-phrases)

Conditions and measures related to personal protection and hygiene

Not applicable

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Refer to product labels.

Environmental exposure estimation: consumer use of inks and toners containing aluminium dihydrogen triphosphate

The substance is not classified for environmental effects and quantitative assessment of exposure is unnecessary. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Consumer exposure estimation: consumer use of inks and toners containing aluminium dihydrogen triphosphate

No consumer estimation is considered to be appropriate. The substance is not classified as systemically toxic

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and is only present in products at <10% w/w and as such the hazards of the product will be based on the mixture of all components and no specific hazards are expected from aluminium dihydrogen triphosphate at this level. Therefore, no further risk characterisation is performed.

ES11: Consumer use of construction materials containing aluminium dihydrogen triphosphate

Exposure Scenario 10: Consumer use of construction materials containing aluminium dihydrogen triphosphate

List of applicable use descriptors: SU Not applicable; PC 9b; PROC Not applicable; ERC 8c, 8f

Contributing environmental scenario: Wide dispersive indoor/outdoor use resulting in inclusion into or onto a matrix

ERC 8c, 8f

Contributing consumer scenario: Fillers, putties, plaster, modelling clay

PC 9b

Consumer use of construction materials containing aluminium dihydrogen triphosphate

Explanation of technical processes and activities covered: Aluminium dihydrogen triphosphate performs the following technical functions in inks and toners: - corrosion inhibitor - processing aid - pH-regulating agent Decorative painting and other construction chemicals cover the use applied to buildings, their trim and fittings and for decorative and protective purposes by the general public. According to information from the producing industry, the chemicals are used in the following key applications: - transfer of substance/preparation - roller application/brushing - spraying (non-industrial) - dipping and pouring of articles

Control of environmental exposure during consumer use of construction materials containing aluminium dihydrogen triphosphate

Further specifications:

Product characteristics

Products contain <10% aluminium dihydrogen triphosphate.

Amounts used

According to the relevant sector-specific spERCs (EFCC 8c.1a.v1, EFCC 8f.1a.v1) the typical annual amounts used can vary according to % in product and can be calculated using the following equation: MSPERC = Msite x Csp x ndays

-1

Where: Msite = the amount of product manufactured Csp = concentration of substance in product ndays

-1 = number of days emitting

Frequency and duration of use

Dispersive use Continuous release: 365 d/y

Environment factors not influenced by risk management

Local freshwater dilution factor: 10 Local marine dilution factor: 100 Receiving surface water flow is 18,000 m3/d (REACH defaults)

Other given operational conditions affecting environmental exposure

Consumer product use leading to disposal via wastewater: release factor to wastewater – 0.01

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Consumer product use with limited or no technical control of emission. No emissions to air are anticipated: release factor to air – 0. Aluminium dihydrogen triphosphate is contained within a matrix and as such exposure is considered to be negligible.

Conditions and measures related to municipal sewage Treatment plant

Application equipment can be washed in domestic sinks and washings discharged into public sewers.

Conditions and measures related to external Treatment of waste for disposal

Not applicable.

Conditions and measures related to external recovery of waste

No direct acute or long-term adverse effects on aqueous or terrestrial organisms are reported for orthophosphates. However, phosphates are a key nutrient for plants and elevated phosphates levels in water can lead to excessive growth of algae and other aquatic plants (eutrophication) if phosphate is the growth limiting factor. Although in some cases nutrient enrichment will be absorbed and have no effect, in other circumstances it can lead to a negative effect. Sewage treatment may be necessary to prevent ecosystem modification ranging from algal blooms to extreme cases of oxygen depletion and collapse of biocenosis in surface water.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Council directive 91/271/EEC concerning urban waste water requires phosphate removal from sewage, wherever receiving waters are potentially susceptible to eutrophication, in agglomerations >10,000 person equivalents. This requirement is confirmed by the EU Water Framework Directive 2000/60, which also further requires phosphate removal in smaller agglomerations where this is necessary to achieve water quality standards. The directives are not yet fully implemented in all new EU member states. This should be done by end of 2018.

Control of consumer exposure during consumer use of construction materials containing aluminium dihydrogen triphosphate

Further specifications:

Product characteristics

Products contain <10% aluminium dihydrogen triphosphate.

Amounts used

According to the relevant sector-specific spERCs (EFCC 8c.1a.v1, EFCC 8f.1a.v1) the typical annual amounts used can vary according to % in product and can be calculated using the following equation: MSPERC = Msite x Csp x ndays

-1

Where: Msite = the amount of product manufactured Csp = concentration of substance in product ndays

-1 = number of days emitting

Frequency and duration of use/exposure

Dispersive use Continuous release: 365 d/y

Human factors not influenced by risk management

Consumers on average have a body weight of 60 kg (females) or 70 kg (males).

Other given factors affecting consumer exposure

It is anticipated as a worst-case that consumers will not wear PPE however, aluminium dihydrogen triphosphate is contained within a matrix and as such exposure is considered to be negligible.

Conditions and measures related to information and behavioural advice to consumers

Consumers should observe the safety warnings on the product (S-phrases)

Conditions and measures related to personal protection and hygiene

Not applicable

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of

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REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Refer to product labels.

Environmental exposure estimation: Consumer use of construction materials containing aluminium dihydrogen triphosphate

The substance is not classified for environmental effects and quantitative assessment of exposure is unnecessary. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Consumer exposure estimation: Consumer use of construction materials containing aluminium dihydrogen triphosphate

No consumer estimation is considered to be appropriate. The substance is not classified as systemically toxic and is only present in products at <10% w/w and as such the hazards of the product will be based on the mixture of all components and no specific hazards are expected from aluminium dihydrogen triphosphate at this level. Therefore, no further risk characterisation is performed.

ES12: Service life of paper articles where industrial and consumer use of the finished article is possible

Exposure Scenario 12: Service life of paper articles where industrial and consumer use of the finished article is possible

List of applicable use descriptors (relating to service life number 1): SU not applicable; PC not applicable; PROC 21(workers); ERC 11a; AC 8

Contributing environmental scenario: Wide-dispersive indoor use of long-life articles with low release

ERC 11a

Contributing worker scenario 1: Low energy manipulation of substances bound in materials and/or articles

PROC 21

Service life of paper articles where industrial and consumer use of the finished article is possible

Title and number of the Exposure Scenario leading to inclusion of the substance into the article: Service life of paper articles; paper is processed by workers in both an industrial and professional setting. Consumers will also come into contact with paper articles during their normal use. Release is considered to be negligible in both cases. Exposure Scenario 4: Industrial end use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks, etc Exposure scenario 7: Professional use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks Exposure scenario 10: Consumer use of inks and toners containing aluminium dihydrogen triphosphate

Control of environmental exposure during service life of paper articles where industrial and consumer use of the finished article is possible

Further specifications

Product (article) characteristics

Aluminium dihydrogen triphosphate present in concentrations < 10% w/w and bound in the chemical matrix of the article.

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Amounts used

Not relevant to scenario.

Frequency and duration of use/exposure from service life

Continuous use- consumers and workers

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value)

Other given operational conditions affecting environmental exposure

Industrial / professional processing is assumed to be indoors. Consumers may have contact with paper articles both indoors and outdoors.

Conditions and measures at level of article production process to prevent release during service life

No release during service life.

Conditions and measures related to municipal sewage treatment plant

Triphosphates are hydrolysed or biotically degraded (by the action of phosphatases) to soluble inorganic orthophosphate (PO4

3-) in wastewater, sewage systems and natural waters. In addition, organisms can break

down pyrophosphates to orthophosphate via the action of phosphatases.

Conditions and measures related to disposal of articles at end of service life

Paper articles are generally recycled – releases are not expected during recycling.

Conditions and measures related to external recovery of articles at end of service life

Recycling - no specific measures required.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Council directive 91/271/EEC concerning urban waste water requires phosphate removal from sewage, wherever receiving waters are potentially susceptible to eutrophication, in agglomerations >10,000 person equivalents. This requirement is confirmed by the EU Water Framework Directive 2000/60, which also further requires phosphate removal in smaller agglomerations where this is necessary to achieve water quality standards. The directives are not yet fully implemented in all new EU member states. This should be done by end of 2018.

Control of exposure during service life of paper articles

Further specifications

Not applicable.

Product (article) characteristics

Aluminium dihydrogen triphosphate present in concentrations < 10% w/w and bound in the chemical matrix of the article.

Amounts used

Not specified.

Frequency and duration of use/exposure from service life

Continuous use. No releases expected.

Human factors not influenced by risk management

Not applicable. Direct contact during processing tasks is considered to be minimal.

Other given operational conditions affecting worker and consumer exposure from article service life

Releases are considered to be negligible. Industrial / professional processing is assumed to be indoors. Consumers may have contact with paper articles both indoors and outdoors.

Conditions and measures at level of article production to prevent release during service life

Paper articles are generally recycled – releases are not expected during recycling.

Conditions and measures related to information and behavioural advice to consumers

Not applicable

Conditions and measures related to personal protective equipment and hygiene

PPE is not considered to be required.

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Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Not applicable.

Environmental exposure estimation: Service life of paper articles where worker and consumer contact with the finished article is possible

The substance is not classified for environmental effects and quantitative assessment of exposure is unnecessary. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Worker and Consumer exposure estimation: Service life of paper articles where industrial and consumer use of the finished article is possible

Releases are considered to be negligible and as such no exposure estimate is required. In addition, aluminium dihydrogen triphosphate is not considered to be systemically toxic and as such quantification of the exposure is not considered to be necessary. The risks relating to the eye irritancy of aluminium dihydrogen triphosphate are not relevant in this case due to the amount present in the articles (<10% w/w) and the fact that the substance is bound in a matrix.

ES13: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when handled by industrial and professional users

Exposure Scenario 13: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when handled by industrial and professional users

List of applicable use descriptors (relating to service life numbers 2,3,4): SU not applicable; PC not applicable; PROC 14, 21, 22, 23, 24, 25; ERC 10a, 10b, 11a, 11b; AC 1, 2, 5, 7, 10, 11. 13

Contributing environmental scenario: Service life of articles, indoors and outdoors with low release and articles that are further processed with high or intended release.

ERC 10a, 10b, 11a, 11b

Contributing worker scenario 1: Production of preparations or articles by tabletting, compression, extrusion, pelletisation

PROC 14

Contributing worker scenario 2: Low energy manipulation of substances bound in materials and/or articles

PROC 21

Contributing worker scenario 3: Potentially closed processing operations with minerals/metals at elevated temperature in an industrial setting

PROC 22

Contributing worker scenario 4: Open processing and transfer operations with minerals/metals at elevated temperature

PROC 23

Contributing worker scenario 5: High (mechanical) energy work-up of substances bound in materials and/or articles

PROC 24

Contributing worker scenario 6: Other hot work operations with metals PROC 25

Service life of articles where production requires use of paints, varnishes, coatings, printing inks,

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mastics, rubbers, plastics, resins; including service life of coated articles when handled by industrial and professional users

Title and number of the Exposure Scenario leading to inclusion of the substance into the article Exposure Scenario 4: Industrial end use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks Exposure Scenario 7: Professional use as an additive/pigment/auxiliary in plastics, resins, paints, coatings and inks Description of scenario: treatment of articles coated with, or containing aluminium dihydrogen triphosphate- paints / coatings / pigments may be further processed in an industrial and/or professional

Control of environmental exposure during service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when handled by industrial and professional users

Further specifications

Routine processing of articles under modern industrial/professional conditions.

Product (article) characteristics

Aluminium dihydrogen triphosphate is considered to be present at < 10% w/w and bound in a chemical matrix

Amounts used

Not relevant to scenario.

Frequency and duration of use/exposure from service life

Not relevant to scenario.

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value)

Other given operational conditions affecting environmental exposure

Cyclones, scrubbers and filters are used to retain particles and ensure dust emission requirements are met. See below.

Conditions and measures at level of article production process to prevent release during service life

Not applicable. Release of aluminium dihydrogen phosphate is considered to be negligible.

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

RMM’s are employed as standard in industrial settings. In professional settings, it is considered that the workers will adhere to good working practices and work in environments that are well ventilated.

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

Techniques for treating process wastewater include filtration for separation of filterable solids, flow and load equalisation, sedimentation for suspended solids, and phosphate removal using physico-chemical methods.

Organisational measures to prevent/limit release from site

Industrial work environments will employ technical measures to limit releases to air, water and soil.

Conditions and measures related to municipal sewage treatment plant

Pyrophosphates are hydrolysed or biotically degraded (by the action of phosphatases) to soluble inorganic orthophosphate (PO4

3-) in wastewater, sewage systems and natural waters. In addition, organisms can break

down pyrophosphates to orthophosphate via the action of phosphatases.

Conditions and measures related to disposal of articles at end of service life

No specific measures required for aluminium dihydrogen triphosphate.

Conditions and measures related to external recovery of articles at end of service life

No specific measures required for aluminium dihydrogen triphosphate.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Council directive 91/271/EEC concerning urban waste water requires phosphate removal from sewage, wherever receiving waters are potentially susceptible to eutrophication, in agglomerations >10,000 person equivalents. This requirement is confirmed by the EU Water Framework Directive 2000/60, which also further requires phosphate removal in smaller agglomerations where this is necessary to achieve water quality

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standards. The directives are not yet fully implemented in all new EU member states. This should be done by end of 2018.

Control of worker exposure during service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when handled by industrial and professional users

Further specifications

Routine processing of articles under modern industrial/professional conditions.

Product (article) characteristics

Aluminium dihydrogen triphosphate is considered to be present at < 10% w/w and bound in a chemical matrix

Amounts (contained in articles) present in the workplace

Not relevant to scenario.

Frequency and duration of use/exposure

Continuous use is assumed (shifts 8-hr/day).

Human factors not influenced by risk management

Not applicable. Direct contact during processing tasks is considered to be minimal.

Other given operational conditions affecting worker exposure

Releases are considered to be negligible. Industrial/professional processing may occur both indoors and outdoors.

Conditions and measures at level of article production to prevent release during service life

Articles are designed in such a way that releases are minimised. Processing is assumed to be low energy and industrial processes at elevated temperature will be contained.

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

Exhaust ventilation and/or general ventilation is assumed. Further, for hot work operations a degree of containment of fumes is expected.

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

Much of the work is controlled automatically; however for processes where workers may come into contact with the articles to be processed it is expected that they are trained in the safe use of the required machinery.

Organisational measures to prevent/limit releases, dispersion and exposure

No specific measures are required for the prevention of exposure to aluminium dihydrogen triphosphate.

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

Appropriate PPE should be worn, depending upon the nature of the processing activity and the nature of the specific article to be processed. No specific measures are required for aluminium dihydrogen triphosphate. Health and safety evaluations should be performed in accordance with regulatory requirements of country in which the work takes place.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Not applicable.

Environmental exposure estimation: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when handled by industrial and professional users

The substance is not classified for environmental effects and is bound within articles at < 10% w/w. Therefore, quantitative assessment of exposure is unnecessary. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Worker exposure estimation: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated

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articles when handled by industrial and professional users

Releases are considered to be negligible and as such no exposure estimate is required. In addition, aluminium dihydrogen triphosphate is not considered to be systemically toxic and as such quantification of the exposure is not considered to be necessary. The risks relating to the eye irritancy of aluminium dihydrogen triphosphate are not relevant in this case due to the amount present in the articles (<10% w/w) and the fact that the substance is bound in a matrix.

ES14: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when consumer contact with the finished article is possible

Exposure Scenario 14: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when consumer contact with the finished article is possible

List of applicable use descriptors (relating to service life number 2, 3, 4): SU not applicable; PC not applicable; PROC not applicable; ERC 10a, 10b, 11a, 11b; AC 1, 2, 5, 7, 10, 11, 13

Contributing environmental scenario: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins etc and consumer contact with the finished article is possible

ERC 10a, 10b, 11a, 11b

Contributing consumer scenario 1: Vehicles AC 1

Contributing consumer scenario 2: machinery, mechanical appliances, electrical/electronic articles

AC 2

Contributing consumer scenario 3: Fabrics, Textiles and Apparel AC 5

Contributing consumer scenario 4: Metal articles AC 7

Contributing consumer scenario 5: Rubber articles AC 10

Contributing consumer scenario 6: Wood articles AC 11

Contributing consumer scenario 7: Plastic articles AC 13

Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when consumer contact with the finished article is possible

Title and number of the Exposure Scenario leading to inclusion of the substance into the article: Exposure Scenario 9: Consumer end use of paints, coatings and varnishes containing aluminium dihydrogen triphosphate

Control of environmental exposure during service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when consumer contact with the finished article is possible

Further specifications

Routine handling of articles by the general public.

Product (article) characteristics

Aluminium dihydrogen triphosphate is anticipated to present in the finished articles at < 10% and bound in the chemical matrix of the article.

Amounts used

Not relevant to scenario

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Frequency and duration of use/exposure from service life

Continuous, wide-dispersive use.

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value)

Other given operational conditions affecting environmental exposure

Articles are used both indoors and outdoors.

Conditions and measures at level of article production process to prevent release during service life

No releases of aluminium dihydrogen triphosphate are anticipated during service life.

Conditions and measures related to municipal sewage treatment plant

Release to STP is not anticipated.

Conditions and measures related to disposal of articles at end of service life

Article may be recycled, incinerated or sent to land fill depending upon type.

Conditions and measures related to external recovery of articles at end of service life

No specific measures relating to aluminium dihydrogen triphosphate.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Council directive 91/271/EEC concerning urban waste water requires phosphate removal from sewage, wherever receiving waters are potentially susceptible to eutrophication, in agglomerations >10,000 person equivalents. This requirement is confirmed by the EU Water Framework Directive 2000/60, which also further requires phosphate removal in smaller agglomerations where this is necessary to achieve water quality standards. The directives are not yet fully implemented in all new EU member states. This should be done by end of 2018.

Control of consumer exposure during service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when consumer contact with the finished article is possible

Further specifications

Routine handling of articles by the general public.

Product (article) characteristics

Aluminium dihydrogen triphosphate is anticipated to present in the finished articles at < 10% and bound in the chemical matrix of the article.

Amounts used

Not relevant to scenario.

Frequency and duration of use/exposure from service life

Continuous, wide-dispersive use.

Human factors not influenced by risk management

Not applicable. Direct contact during processing tasks is considered to be minimal.

Other given operational conditions affecting consumer exposure from article service life

Releases are considered to be negligible. Outdoor and indoor use is anticipated.

Conditions and measures at level of article production to prevent release during service life

No release of aluminium dihydrogen triphosphate is anticipated.

Conditions and measures related to information and behavioural advice to consumers

Not required for aluminium dihydrogen triphosphate.

Conditions and measures related to personal protective equipment and hygiene

PPE is not required.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 59/64

NB. Please read the NOTICE on the front page.

Not applicable.

Environmental exposure estimation: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when consumer contact with the finished article is possible

The substance is not classified for environmental effects and quantitative assessment of exposure is unnecessary. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Consumer exposure estimation: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins; including service life of coated articles when consumer contact with the finished article is possible

Releases are considered to be negligible and as such no exposure estimate is required. In addition, aluminium dihydrogen triphosphate is not considered to be systemically toxic and as such quantification of the exposure is not considered to be necessary. The risks relating to the eye irritancy of aluminium dihydrogen triphosphate are not relevant in this case due to the amount present in the articles (<10% w/w) and the fact that the substance is bound in a matrix.

ES15: Service life of building and construction materials and ceramic articles when handled by industrial and professional users

Exposure Scenario 15: Service life of building and construction materials and ceramic articles when handled by industrial and professional users

List of applicable use descriptors (relating to service life number 5): SU not applicable; PC not applicable; PROC 14, 21, 22, 23, 24, 25; ERC 10a, 10b, 11a, 11b; AC 4

Contributing environmental scenario 1: Service life of articles, indoors and outdoors with low release and articles that are further processed with high or intended release.

ERC 10a, 10b, 11a, 11b

Contributing environmental scenario 2: Industrial processing of articles with abrasive techniques (low and high release)

ERC 12a, 12b

Contributing worker scenario 1: Production of preparations or articles by tabletting, compression, extrusion, pelletisation

PROC 14

Contributing worker scenario 2: Low energy manipulation of substances bound in materials and/or articles

PROC 21

Contributing worker scenario 3: Potentially closed processing operations with minerals/metals at elevated temperature in an industrial setting

PROC 22

Contributing worker scenario 4: Open processing and transfer operations with minerals/metals at elevated temperature

PROC 23

Contributing worker scenario 5: High (mechanical) energy work-up of substances bound in materials and/or articles

PROC 24

Contributing worker scenario 6: Other hot work operations with metals PROC 25

Service life of building and construction materials and ceramic articles when handled by industrial and professional users

Title and number of the Exposure Scenario leading to inclusion of the substance into the article

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 60/64

NB. Please read the NOTICE on the front page.

Exposure Scenario 5: Industrial end use in building / construction materials and ceramics. Exposure Scenario 8: Professional use in construction materials and ceramics: in coating systems, as a binding agent and as a silicate hardener. Description of scenario: service life of construction articles containing small amounts of aluminium dihydrogen triphosphate.

Control of environmental exposure during service life of building and construction materials and ceramic articles when handled by industrial and professional users

Further specifications

Routine processing of articles under modern industrial/professional conditions.

Product (article) characteristics

Aluminium dihydrogen triphosphate is considered to be present at < 10% w/w and bound in a chemical matrix

Amounts used

Not relevant to scenario.

Frequency and duration of use/exposure from service life

Not relevant to scenario.

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value)

Other given operational conditions affecting environmental exposure

Cyclones, scrubbers and filters are used to retain particles and ensure dust emission requirements are met.

Conditions and measures at level of article production process to prevent release during service life

Not applicable. Release of aluminium dihydrogen phosphate is considered to be negligible.

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

RMM’s are employed as standard in industrial settings. In professional settings, it is considered that the workers will adhere to good working practices and work in environments that are well ventilated.

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

Techniques for treating process wastewater include filtration for separation of filterable solids, flow and load equalisation, sedimentation for suspended solids, and phosphate removal using physico-chemical methods.

Organisational measures to prevent/limit release from site

Industrial work environments will employ technical measures to limit releases to air, water and soil.

Conditions and measures related to municipal sewage treatment plant

Pyrophosphates are hydrolysed or biotically degraded (by the action of phosphatases) to soluble inorganic orthophosphate (PO4

3-) in wastewater, sewage systems and natural waters. In addition, organisms can break

down pyrophosphates to orthophosphate via the action of phosphatases.

Conditions and measures related to disposal of articles at end of service life

No specific measures required for aluminium dihydrogen triphosphate.

Conditions and measures related to external recovery of articles at end of service life

No specific measures required for aluminium dihydrogen triphosphate.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Council directive 91/271/EEC concerning urban waste water requires phosphate removal from sewage, wherever receiving waters are potentially susceptible to eutrophication, in agglomerations >10,000 person equivalents. This requirement is confirmed by the EU Water Framework Directive 2000/60, which also further requires phosphate removal in smaller agglomerations where this is necessary to achieve water quality standards. The directives are not yet fully implemented in all new EU member states. This should be done by end of 2018.

Control of worker exposure during service life of building and construction materials and ceramic articles when handled by industrial and professional users

Further specifications

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 61/64

NB. Please read the NOTICE on the front page.

Routine processing of articles under modern industrial/professional conditions.

Product (article) characteristics

Aluminium dihydrogen triphosphate is considered to be present at < 10% w/w and bound in a chemical matrix

Amounts (contained in articles) present in the workplace

Not relevant to scenario.

Frequency and duration of use/exposure

Continuous use is assumed (shifts; 8-hr/day).

Human factors not influenced by risk management

Not applicable. Direct contact during processing tasks is considered to be minimal.

Other given operational conditions affecting worker exposure

Releases are considered to be negligible. Industrial/professional processing may occur both indoors and outdoors.

Conditions and measures at level of article production to prevent release during service life

Articles are designed in such a way that releases are minimised. Processing is assumed to be low energy and industrial processes at elevated temperature will be contained.

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

Exhaust ventilation and/or general ventilation is assumed. Further, for hot work operations a degree of containment of fumes is expected.

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

Much of the work is controlled automatically; however for processes where workers may come into contact with the articles to be processed it is expected that they are trained in the safe use of the required machinery.

Organisational measures to prevent/limit releases, dispersion and exposure

No specific measures are required for the prevention of exposure to aluminium dihydrogen triphosphate.

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

Appropriate PPE should be worn, depending upon the nature of the processing activity and the nature of the specific article to be processed. No specific measures are required for aluminium dihydrogen triphosphate. Health and safety evaluations should be performed in accordance with regulatory requirements of country in which the work takes place.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Not applicable.

Environmental exposure estimation: Service life of building and construction materials and ceramic articles when handled by industrial and professional users

The substance is not classified for environmental effects and is bound within articles at < 10% w/w. Therefore, quantitative assessment of exposure is unnecessary. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Worker exposure estimation: Service life of building and construction materials and ceramic articles when handled by industrial and professional users

Releases are considered to be negligible and as such no exposure estimate is required. In addition, aluminium dihydrogen triphosphate is not considered to be systemically toxic and as such quantification of the exposure is not considered to be necessary. The risks relating to the eye irritancy of aluminium dihydrogen triphosphate are not relevant in this case due to the amount present in the articles (<10% w/w) and the fact that the substance is bound in a matrix.

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 62/64

NB. Please read the NOTICE on the front page.

ES16: Service life of building and construction materials and ceramic articles when consumer contact with the finished article is possible

Exposure Scenario 16: Service life of building and construction materials and ceramic articles when consumer contact with the finished article is possible

List of applicable use descriptors (relating to service life number 5): SU not applicable; PC not applicable; PROC not applicable; ERC 10a, 10b, 11a, 11b; AC 4

Contributing environmental scenario: Service life of articles where production requires use of paints, varnishes, coatings, printing inks, mastics, rubbers, plastics, resins etc and consumer contact with the finished article is possible

ERC 10a, 10b, 11a, 11b

Contributing consumer scenario 1: Stone, plaster, cement, glass and ceramic articles

AC 4

Service life of building and construction materials and ceramic articles when consumer contact with the finished article is possible

Title and number of the Exposure Scenario leading to inclusion of the substance into the article: Exposure Scenario 10: Consumer use of construction materials containing aluminium dihydrogen triphosphate

Control of environmental exposure during service life of building and construction materials and ceramic articles when consumer contact with the finished article is possible

Further specifications

Routine handling of articles by the general public.

Product (article) characteristics

Aluminium dihydrogen triphosphate is anticipated to present in the finished articles at < 10% and bound in the chemical matrix of the article.

Amounts used

Not relevant to scenario

Frequency and duration of use/exposure from service life

Continuous, wide-dispersive use.

Environment factors not influenced by risk management

Flow rate of receiving water 18,000 m3/day (default value)

Other given operational conditions affecting environmental exposure

Articles are used both indoors and outdoors.

Conditions and measures at level of article production process to prevent release during service life

No releases of aluminium dihydrogen triphosphate are anticipated during service life.

Conditions and measures related to municipal sewage treatment plant

Release to STP is not anticipated.

Conditions and measures related to disposal of articles at end of service life

Article may be recycled, incinerated or sent to land fill depending upon type.

Conditions and measures related to external recovery of articles at end of service life

No specific measures relating to aluminium dihydrogen triphosphate.

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 63/64

NB. Please read the NOTICE on the front page.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Council directive 91/271/EEC concerning urban waste water requires phosphate removal from sewage, wherever receiving waters are potentially susceptible to eutrophication, in agglomerations >10,000 person equivalents. This requirement is confirmed by the EU Water Framework Directive 2000/60, which also further requires phosphate removal in smaller agglomerations where this is necessary to achieve water quality standards. The directives are not yet fully implemented in all new EU member states. This should be done by end of 2018.

Control of consumer exposure during service life of building and construction materials and ceramic articles when consumer contact with the finished article is possible

Further specifications

Routine handling of articles by the general public.

Product (article) characteristics

Aluminium dihydrogen triphosphate is anticipated to present in the finished articles at < 10% and bound in the chemical matrix of the article.

Amounts used

Not relevant to scenario.

Frequency and duration of use/exposure from service life

Continuous, wide-dispersive use.

Human factors not influenced by risk management

Not applicable. Direct contact during processing tasks is considered to be minimal.

Other given operational conditions affecting consumer exposure from article service life

Releases are considered to be negligible. Outdoor and indoor use is anticipated.

Conditions and measures at level of article production to prevent release during service life

No release of aluminium dihydrogen triphosphate is anticipated.

Conditions and measures related to information and behavioural advice to consumers

Not required for aluminium dihydrogen triphosphate.

Conditions and measures related to personal protective equipment and hygiene

PPE is not required.

Additional good practice advice beyond the REACH Chemical Safety Assessment (CSA) Note: The measures reported in this section have not been taken into account in the exposure estimates related to the exposure scenario above. They are not subject to obligation laid down in Article 37(4) of REACH, thus the downstream user is not obliged to i) carry out own CSA and ii) to notify the use to the Agency, if he does not implement these measures.

Not applicable.

Environmental exposure estimation: Service life of building and construction materials and ceramic articles when consumer contact with the finished article is possible

The substance is not classified for environmental effects and is bound within articles at < 10% w/w. Therefore, quantitative assessment of exposure is unnecessary. As a result of the hazard assessment and as the assessment of PBT/vPvB properties is not applicable for inorganic materials, it is found that aluminium dihydrogen triphosphate does not meet the criteria for classification as hazardous to the environment (according to Directives 67/548/EEC and Regulation 1272/2008/EC) nor is it considered to be a PBT/vPvB. An exposure assessment and the subsequent step of risk characterisation are not required. Consequently, all identified uses of the substance are assessed as safe for the environment.

Consumer exposure estimation: Service life of building and construction materials and ceramic articles when consumer contact with the finished article is possible

Releases are considered to be negligible and as such no exposure estimate is required. In addition, aluminium dihydrogen triphosphate is not considered to be systemically toxic and as such quantification of the

SAFETY DATA SHEET Date of issue: xxx

Aluminium dihydrogen triphosphate

Revision date: X Version: XX Page 64/64

NB. Please read the NOTICE on the front page.

exposure is not considered to be necessary. The risks relating to the eye irritancy of aluminium dihydrogen triphosphate are not relevant in this case due to the amount present in the articles (<10% w/w) and the fact that the substance is bound in a matrix.