Use of paint stripper containing > 0.1% Dichloromethane (DCM) in the alloy wheel refurbishment industry
Overview
Related carcinogens:
DichloromethaneType of intervention(s):
Inspection campaignNumber of inspections undertaken:
35 inspections during the campaign by Occupational Hygiene Inspectors.
Sites inspected typically employed < 10 operatives and were involved in the motor vehicle repair or tyre repair sectors. A small number of larger engineering / metal fabrication sites were also inspected.
10 inspections covering 11 products by Market Surveillance Inspectors.
The majority of inspection sites were supplying the product to the motor- vehicle or tyre repair sector (7/10) and the remaining inspection sites were companies supplying furniture restoration sector.
Scope of intervention
Key duties
Duties examined under CAD, CMRD and REACH
Focus of the Campaign
Focus on compliance of operators involved in alloy wheel refurbishment using paint stripper containing > 0.1% Dichloromethane (DCM) with the restriction conditions set out in REACH Annex XVII, Entry Number 59.
- Focus: reducing or eliminating exposure of workers to DCM.
- Raising awareness of REACH Restriction for DCM.
- Enforcement of technical protective measures conditions outlined in REACH Annex XVII, No. 59. substitution of DCM by less hazardous alternative.
- Elimination of exposure to DCM by use of engineering control.
The Market Surveillance of Chemicals team supported in the enforcement of the supply of paint stripper containing > 0.1% Dichloromethane (DCM) with the restriction conditions set out in REACH Annex XVII, Entry Number 59.
Focus: ensuring that suppliers were supplying such products within the conditions of the restriction, that is ensuring no supply to the general public or to professionals.
Key findings of intervention
Positive findings
Improvements indicated were:
- Awareness that DCM is classified as a hazardous chemical agent and has carcinogenic potential for humans.
- Awareness that REACH Annex XVII, Entry No. 59 sets out minimum health & safety conditions for professional users in industrial setting using paint stripper containing > 0.1% DCM.
- Elimination of exposure to DCM by engineering measure such as diamond cut lathe or shot blasting to strip paint from alloy wheel.
- Substitution of paint stripper containg > 0.1% DCM with less hazardous alternative.
- Enforcement of compliance with the DCM REACH restriction conditions.
- Risk assessment for DCM use.
- Availability of health and safety documents in the workplace
- rotective and technical measures to reduce and prevent DCM exposure.
- Technical measures to ensure that the limit values for DCM are not exceeded.
On market surveillance intervention
- Removal of paint stripping products containing > 0.1% Dichloromethane (DCM) from sale to members of the general public including online sale (three Contravention [Improvement] Notices issued)
- Awareness raising with suppliers on their duty to ensure members of the public and professionals are not supplied paint stripping products containing > 0.1% Dichloromethane (DCM)
- Replacement of paint stripping products containing > 0.1% Dichloromethane (DCM) with less hazardous alternatives by some suppliers or improvement of procedures and documentation by other suppliers.
Negative findings
- Some operators wished to continue to use paint stripper containing DCM by complying with REACH restriction conditions. Reasons given were that (i) Diamond cut lathe equipment is expensive (ii) Alternative hot strip chemicals are not as efficient at paint stripping, is a much slower process, is more expensive and has its own hazards.
- Suppliers lacked clarity on the definition of an industrial installation and did not have the requisite knowledge to determine if their customer met this definition and/or the Restriction Entry 59 paragraph 4 minimum conditions.
Key outcomes following intervention
- Increase in compliance with the conditions for use of paint stripper containing > 0.1% DCM set out in REACH Annex XVII, Entry No. 59.
- Substitution of paint stripper containing > 0.1% DCM with less hazardous alternative.
- Elimination of requirement to use paint stripper by engineering process.
- Removal of paint stripper containing > 0.1% DCM from sale to the general public
- Removal of paint stripper containing > 0.1% DCM from sale by certain suppliers
- Improvement of procedures by suppliers of paint stripper containing > 0.1% DCM in the supply to industrial installations
Level and type of enforcement issued
- Verbal advice
- Written advice
- Improvement notice
- Prohibition notice
Key EU legislation
- CAD
- REACH
- CLP
