ACTION 3: REACH framework on HSE parameters: MSDS and on-site measurements

A list with Selected Dangerous Substances (SelDS) and mixtures will be created containing all common fossil fuels (liquid and gas) and all lubricants and other engine oils widely produced, transported, handled and consumed in Greece and other EU countries. The list will also contain the most common Hazardous Chemicals (HazChem) handled in large quantities by the refineries, the petrochemical industry and its supply and product distribution chains. In the framework of this project we examine Hazardous Chemicals (HazChem) that have the potential to create adverse effects to the Health and Safety of employees, professionals and the public or significant damage to the environment.

A short number of generalized Material Safety Data Sheets (GenMSDS) will be created based on the UNRTDG hazard classes and in accordance with the terms and formulation of REACH, CLP and other HSE relevant European Regulations. According to the UNRTDG the various substances are classified into 9 classes as presented below. From those classes and divisions, Class 2 (including all divisions), Class 3, Class 5 (Division 5.1), Class 6 (Division 6.1), Class 8 and Class 9 are the classes on which the present project will focus (handled and transported by target groups) (see also sub action 4.1).

UNRTDG Class            Nature of Hazard

• Class 1: Explosives
• Class 2:  Gases
  • Division 2.1: Flammable Gases           
  • Division 2.2 : Non-Flammable, Non-Toxic gases         
  • Division 2.3: Toxic Gases
• Class 3:  Flammable Liquids
• Class 4: Flammable Solids, Pyrophorics, Water
• Class 5: Oxidizing substances and Organic Peroxides
  • Division 5.1: Oxidising substances
  • Division 5.2: Organic Peroxides
• Class 6:      Toxic and Infectious Substances
  • Division 6.1: Toxic Substances
  • Division 6.2: Infectious substances
• Class 7: Radioactive materials
• Class 8:  Corrosive substances
• Class 9: Other dangerous substances

A grouping of the selected substances (SelDS) will be performed based on their common or similar HSE parameters or on the HSE provision and measures identified in their formal MSDS as developed within REACH. Clusters of HSE parameters of the SelDS will be developed and basic indices will be introduced based on appropriate ranges of HSE parameters and Threshold Limit Values (TLVs). Single indices or any appropriate combination of them into indicators will support the examination of SelDS in groups that participate in common accidental phenomena (BLEVE, Fires, UVCE, Toxic Cloud Dispersion, etc), require common emergency actions, refer to common HSE provisions such as the implementation of preventative, controlling and mitigation measures or in general address common issues in their Risk Management System.

In order to create generalized MSDSs, REACH formatted MSDSs will be used, and all available information will be structured in terms of UN RTDG covering a wide range of TLVs and substance properties. All SelDS properties, environmental effects, legislative limits for human health and the environment appearing in REACH formatted MSDS will be grouped according to the substance participation in past accidental spills and accidental phenomena following LOC.

In addition main impact categories with potential environmental effects will be examined separately for all SelDS. The results of a past Best Life Project “ECOREG” will be utilized and proposed environmental impact categories will be taken into account in order to identify key impact categories per transportation stage and SeIDS  e.g.Climate change, Stratospheric ozone depletion, Tropospheric ozone formation, Acidification, Eutrophication, Ecotoxicity, Odor, Noise etc.

For the selected impact categories appropriate interventions as proposed by “ECOREG” and as indicated by the present analysis will be chosen e.g.

• Climate change (e.g. CO2, CH4),
• Tropospheric ozone formation (e.g. NO_x),
• Eutrophication (e.g. NO_x),
• Deterioration of local air quality (e.g. CO, NO_x),

in order to perform appropriate measurements in the transportation stages.

This will provide a quantifiable measure for the identification of hazards that can be activated in the transportation stages (pollutant impact in specific receptors).

Τhe results from past national project (Risk Management of Hazardous Substances in Storage Areas in Ports, Airports and Train Stations – Hellenic Ministry for the Environment, Physical Planning & Public Works) will be taken into account. In the above mentioned national project the UNRTDG was used in order to classify hazardous substances which are being transported or traded in ports. The categories of hazardous substances were classified into classes and subclasses and were evaluated on their intrinsic properties, the risk and the possibility of an accidental spill. For every class/sub class Safety Operation Procedures were created.

In addition a thorough MSDS data banks and libraries review will be carried out with key criteria the amount of comprising information on MSDSs and the completeness data banks / libraries.

The review will be made through a world wide web search via search engines, in known organizations sites (Joint Research Centre, OSHA, etc.), in existing databases (International Uniform Chemical Information Database – IUCLID, European Chemicals Agency), in libraries, in scientific magazines and conferences, etc. These databanks will be used as the main MSDS source (combined information) and the papers and scientific researches will be used for the MSDS library. An in-house databank of MSDSs for all selected substances will be developed.

For the development of in-house MSDS databank the principles of IUCLID will be used:

1. Harmonised Templates/Fields of information. Standard data formats for reporting results of studies with chemicals in order to determine their properties and effects on human health and the environment will be used.

2. Data exchangeability provisions.

Finally a search engine with advanced and customized searching utilities, connected with several databanks and with web data mining possibility will be developed. This search engine is designed to be used for the in-house databank.

The sub action 3.1 is expected to start after the recording and the assessment of existing situation in Greece (Action 2).

No constraints are expected due to the fact that this sub action comprise restructuring and clustering of existing information with well defined criteria.

Beneficiary responsible for implementation of this sub action will be TUC in collaboration with MOH and AVINOIL. Moreover an external assistance will be subcontracted in order to undertake the implementation of some tasks of this sub action (e.g. MSDS databanks and libraries review, creation of in-house databank, development of search engine connected to the in-house databank, – to be defined).

When registering products under the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH) Regulation, a report has to be submitted in which the risks of that product to Man and the Environment has to be assessed.

This risk assessment comprises of the description of the routes of exposure through all the life stages of the products and the estimation of released amount and the associated human and environmental exposure concentrations. These concentrations are either measured (MEC) or predicted (PEC) and are then compared with the threshold levels that are developed based upon the toxicological and ecotoxicological data, available. These threshold values are the Derived No Effect Level (DNEL) for human (and e.g. mammalian, fish, algae) effects, and Predicted No Effect Concentrations for environmental effects (PNECs). When the MECs or PECs of a product or substances appear to be larger than the DNEL or PNEC, there is a risk and these, then, are assumed to have a negative impact.

Therefore, it is absolutely essential that the estimation of releases of substances or products are as accurate as possible, reflecting the current Industry practises.

In this sub action analytical samplings and measurements aiming to specify the concentrations (if any) of HazChem in water and soil, as well as the emissions to air in several highly frequented locations around Greece and in many loading/unloading points (ports, loading / unloading installations of ships, trucks, gas stations, etc.) and other transportation stages will be carried out.

Different locations of samples will be chosen in the supply and distribution of chemicals taking into account locations where potential HSE hazards could cause impact to environmental receptors. The samples’ analysis will be performed according to national and EU standards applying the Emission Estimation Techniques (EETs) in air, water and soil as recorded by Action 2.5.

Moreover, there will be conducted laboratory analyses of important HSE parameters (according to REACH CSR required information) of selected HazChem as indicated by industrial partners (water spills, soil and air emissions). HSE parameters will address critical emissions, spills and exposures to water, soil and atmosphere in all lifecycle stages of petrochemical products. The analytical results of the collected samples will be used in the creation of CSR of REACH and as a structural element of the paragraphs of a MSDS (for §2, 8, 9, 11, 12, 14 sample information is used unchanged and for §3, 4, 5, 6, 7, 10, 13, 15, 16 sample information is used in order to derive the required information).

An appropriate number of samples will be analyzed that would ensure the delivery of reliable results. A repetition of measurements and analyses may be carried out at a later stage of the project in case data and measurements are found to be not reliable.

Existing laboratories and a mobile laboratory will be used for this purpose. There exist specialized laboratories in all partners concerning related to fuel and petrochemical product analyses. Analytical instruments and detectors will be purchased to cover all monitoring and measurements needs of this project. It will be examined whether necessary analyses requiring large fixed lab instruments with high cost and dedicated personnel and space in the existing laboratories will be performed by purchased equipment in the project or by external subcontractors. All purchased instruments will be established and operated in the existing laboratories by the specialized personnel of TUC, MOH and AVIL OIL.

A mobile laboratory will be developed for the specific project manned and equipped from all partners and with new monitoring and analysis equipment. A preparatory study will be performed for the determination of all specifications and functions that will make the mobile laboratory operational and fully equipped for the purpose. The results of action 2 and of the preparatory study for the mobile lab will delineate priorities for the type of functions and equipment necessary i.e. air and  gas monitoring, chromatography, measuring instruments for occupational health parameters, ecotoxicological measurements, soil and water monitoring, explosive atmospheres, etc.  Samples will be collected by specialized personnel in selected key areas and will be analyzed in certified laboratories. A mobile laboratory would contribute to the faster identification of spills and emissions during transportation and loading/unloading procedures.

Collection of samples from soil, air and water and from highly visited and frequented locations in specific time periods and during standard transportation and loading / unloading procedures. To this end, experts from TUC along with experts from MOH and AVINOIL will perform site visits in key locations (probably in Athens and Corinth) to implement on-site measurements and samples collection. Further the samples will be analyzed by an accredited laboratory for specific parameters of the following interventions for the impact categories, as described in sub action 3.1: (detection of CO₂, N₂O, CH_4, NH₄, C, H₂, N, S, diesel, organic/inorganic fuels, etc.)

For the detection and estimation of emissions and spills a mobile laboratory equipped with specialized equipment and detectors will be available to collect samples according to a predefined on-site measurements plan but also extra samples found necessary after the first series of sample analyses.

No constraints are expected because in this field great experience exists in the last 20 years. In case new particular parameters need to be measured, novel techniques will be adopted.

Beneficiary responsible for implementation of this sub action will be MOH in collaboration with TUC and AVINOIL. In addition an external assistance will be subcontracted in order to facilitate in the implementation of the samplings and measurements and presumably in the laboratory analyses (to be defined).

The expected results from this sub action will be the collection of an important number of samples and their analytical results which could be used for the creation of an emissions and oil spills databank in water soil and air. Additionally a record file will be created having as input information the analytical results of the samples, in order to compare results from different sampling places and from different time periods.

The scope of this action is to assess the results of the measurements based on the comparison with National and European legislative thresholds. Compliance and deviations will be defined for each selected type of receptor in water, soil and air and for the LC stages of the products examined.  This will also apply to all selected dangerous chemicals (SelDS). The outcome will produce estimates of pollution degree, health threads and unsafe conditions caused by the level of dangerous substances concentrations and doses in excess of limit values in LC stages. This assessment will also provide quantified estimates and verified data as input to LCA Analysis (Action 4) and also to the assessment of the overall results (LCA, GenMSDS, operational practices etc. Action 5). The assessed and reliable data will especially utilized in the improvement of the GenMSDS (Sub-Action 3.1) and will provide valuable information in the preparation of recommendations for the safe handling of chemicals.

The assessment of samples’ analysis will be performed according to national and EU standards addressing the Emission Estimation Techniques (EETs) in air, water and soil (action 2.5) as performed in Sub-action 3.2. The assessment will cover all possible parameters of the measurements taking into account data from past recorded emissions by the industrial partners. Statistical analysis will be performed for all measurement results deduced. A literature survey will be performed to identify the appropriate framework for the assessment criteria and the involvement of expert judgment. A set of criteria will be set up based on the following:

1. International standards, National and European legislative exposure limits of chemicals,
2. Official guidelines and directives (e.g. Integrated pollution prevention and control (IPPC) Directive),
3. Methodologies adopted by EU Authorities in the framework of Regulations (e.g. REACH, CLP, NIOSH),
4. Environmental and health indicators used by accredited organizations and laboratories (e.g. CONCAWE, CEFIC, TNO).
5. Individual studies on chemicals (Substance Information Exchange Fora – SIEF procedures)
6. Techniques applied in past Life Projects for assessment of environmental results/impacts

The action results, where possible, will be scrutinized with official data available in public databases for dangerous substances (e.g. ESIS – IUCLID).

The main constrain may be the absence of accredited methodologies for the development of solid remediate measures and recommendations from the assessment of results. Another constrain of the present sub-action may be the lack of precise quantified data on environmental and human exposure limits of certain dangerous substances which makes the comparison difficult among  data of other sources.

Beneficiary responsible for the implementation of this sub action will be MOH in collaboration with TUC and AVINOIL