 |
CyclohexaneSubject: Proposal for a decision of the European Parliament and of the Council amending Council Directive 76/769 as regards restrictions on the marketing and use of certain dangerous substances and preparations - cyclohexaneFEICA the European Adhesive & Sealant Manufacturing Association is a multinational association representing the European Adhesive and Sealant Industry. With the support of all national association members and several direct or affiliated members, FEICA coordinates, represents and advocates the common interests of our industry throughout Europe. In this regard FEICA aims at establishing a constructive dialogue with legislators in order to act as a reliable partner to resolve issues affecting the European Adhesive and Sealant industry. Since the beginning of the discussion on cyclohexane in neoprene adhesives in the European Commission Working Group on Limitations on Marketing and Use of Dangerous Substances and Preparations, FEICA has been closely involved with the Commission and the rapporteur of the dossier in order to realistically assess the risks of neoprene adhesives and propose solutions acceptable to all stakeholders. To our knowledge no evidence of incidents with cyclohexane in neoprene adhesives has been reported and there are no records of any harm caused to consumers. The calculations that were made by RIVM give an interesting input to the discussion but they are based on extreme scenarios that do not reflect day-to-day reality. Therefore, our industry arranged for tests to be carried out by two independent test laboratories, Eurofins and BG Bau the latter of which is associated to the German government. In May 2006 the laboratories tested realistic worst case scenarios, namely gluing cork and fibre boards together. The results were clearly below the Occupational Exposure Limits (OELs). Although FEICA recognizes that a direct conclusion from OELs to a consumer situation is not possible, we would like to point out that in contrary to a professional, a consumer will use neoprene adhesives much more rarely. Some applications are so difficult that consumers could not even handle them, such as carpet laying with a neoprene adhesive. Also it is unlikely that any sensitive consumer group, such as pregnant women or children would handle these products as they are generally used for physical tasks around the house. Therefore, we are convinced that the 650g packaging size as stated in the Commission proposal for amending Council Directive 76/769 does not pose any risk to the consumers. Any further limitation of the packaging size would be disproportional to the risk and can cause significant economic damage to our industry which is largely composed of SMEs.
January 18th 2008 |
