lunes, 4 de mayo de 2009

A morning of April... (a poetic licence)

"April is the cruellest month" said T.S. Eliot in the first line of his great poem " The Waste Land”. Of course poets do not sing about chemistry (and even less about chemicals legal classification) but, as we can't blame on European Authorities (they always act for common wealth), we shall blame on calendar... What else?

"Complaining again?", you surely ask... and it’s a shame for me, because I don't want to look like a maudlin always-crying-dude, but sometimes an honest Official Journal of the European Union reader, ups their eyes to sky and curses April, the Journal and... a butterfly who was just flying around and doesn't know anything about chemicals or about European Union.

Let me explain my concern…

I have already talked about the 31st Adaptation to Technical Progress of Directive 67/548/EEC on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances, and the apparently out of sense created by the publication of the last review of the Substances Directive a month later than the official spread in Official Journal of the legal instrument that eliminate the entire legal act: GHS Regulation 1907/2006/EC… but we can’t complain against European Authorities… and the comming into force of this 31st ATP brings a new matter of worries for Basque Industry.

One day, not a long time ago, somewhere, in an obscure bureau in Brussels (I presume), the European Union experts met and, based on solid evidences and deep studies, decided that was time to change the legal classification of Furfuryl Alcohol (NºCAS 98-00-0).

Inserted on Annex I of Directive 67/548/ECC on 19th ATP, its classification was as follow:


And they decided that it was time to change and that the legal classification of Furfuryl Alcohol, hereinafter (as lawyers said) will be this one:



It’s present and clear that change is notorious… and the concern of clients by the inclusion of a legal classification that relates Furfuryl Alcohol with cancer will create many problems in the foundry industry….. but, the practical consequences of this change, for clients and providers, go beyond:

The stocks of chemical must be checked because the position of many companies has changed. Their calculus for applying Chemical Products Storage laws has changed… and, in fact, the deepest change of this far away meeting, in a cruel morning of April, is that Seveso regulation is around the corner... waiting for us...

Furfuryl Alcohol was not included on Seveso formula. Now, beyond 50 metric tonnes of storage individuall, the site is “in”, and it must be considered in Seveso’s formula for combine hazards: sharp your SAP, because if you storage Furfuryl Alcohol you must check out your hazards formula… (excuse me the commercial but the word game was too tempting…)

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