Coal tar pitch and REACH authorisation: what you must know

22/9/2017

Identity of Coal tar pitch

Name Coal tar pitch

IUPAC name Coal tar pitch

CAS number 65996-93-2

EC number 266-028-2

Hazard classification of Coal tar pitch

HAZARDOUS TO THE AQUATIC ENVIRONMENT

H400 : Very toxic to aquatic life
H412 : Harmful to aquatic life with long lasting effects

VERY HAZARDOUS TO HEALTH

H350: May cause cancer
H340: May cause genetic defects
H360: May damage fertility or the unborn child
H371: May cause damage to organs
H304: May be fatal if swallowed and enters airways
H334: May cause allergy or asthma symptoms or breathing difficulties if inhaled

HAZARDOUS TO THE OZONE LAYER

EUH 059: Hazardous to the ozone layer

Coal tar pitch in annex XIV of REACH

Key regulatory information

Intrinsic property for which it was included in Annex XIV of REACH Carcinogenic, mutagenic or toxic to reproduction, skin sensitizer, PBT (Persistant, Bioaccumulative and toxic), vPvB (very persistant and very bioaccumulative)

Sunset date 4 October 2020

Latest date to submit the authorisation dossier to ECHA 4 April 2019

Who is concerned by REACH authorisation? Main industries concerned Construction, chemical, metallurgy, aeronautics

EcoMundo’s advice to succeed in your authorisation application

Recommendations for your authorisation dossier

  • As the substance does not have a threshold, the Socio-Economic Analysis route will be chosen. This analysis will demonstrate that the benefits related to the granting of the authorisation outweigh the risks associated.
  • The applicant will thus have to conduct a socio-economic analysis as well as the CSR and Analysis of Alternatives.
  • The exposure and associated impacts assessment is particularly complex for this substance due to its PBT and vPvB properties
  • To assess the impacts for health and the environment, EcoMundo recommends to double the approaches through modelling and data monitoring
  • The creation of a dossier is usually between 6 and 18 months depending on the complexity of the dossier (intrinsic properties of the substance, complexity of the applicants’ value and production chain.
  • Key elements of a successful authorisation dossier:
  • A specific request with the most elements possible in relation to your activity
  • Transparence and realism of the hypotheses and data as all elements produced will be challenged by the committees or stakeholders
  • Underlining the exposure for man and the environment with associated emission measures
  • The choice of the monetary assessment methodology is key for this dossier

Planning recommendations

  • The Latest Application date for this substance is 04/04/2019, the last submission window is on February 2019.
  • It is therefore recommended to start the creation of the dossier immediately (september 2017).

Identity of Coal tar pitch

Name Coal tar pitch

IUPAC name Coal tar pitch

CAS number 65996-93-2

EC number 266-028-2

Hazard classification of Coal tar pitch

HAZARDOUS TO THE AQUATIC ENVIRONMENT

H400 : Very toxic to aquatic life
H412 : Harmful to aquatic life with long lasting effects

VERY HAZARDOUS TO HEALTH

H350: May cause cancer
H340: May cause genetic defects
H360: May damage fertility or the unborn child
H371: May cause damage to organs
H304: May be fatal if swallowed and enters airways
H334: May cause allergy or asthma symptoms or breathing difficulties if inhaled

HAZARDOUS TO THE OZONE LAYER

EUH 059: Hazardous to the ozone layer

Coal tar pitch in annex XIV of REACH

Key regulatory information

Intrinsic property for which it was included in Annex XIV of REACH Carcinogenic, mutagenic or toxic to reproduction, skin sensitizer, PBT (Persistant, Bioaccumulative and toxic), vPvB (very persistant and very bioaccumulative)

Sunset date 4 October 2020

Latest date to submit the authorisation dossier to ECHA 4 April 2019

Who is concerned by REACH authorisation? Main industries concerned Construction, chemical, metallurgy, aeronautics

EcoMundo’s advice to succeed in your authorisation application

Recommendations for your authorisation dossier

  • As the substance does not have a threshold, the Socio-Economic Analysis route will be chosen. This analysis will demonstrate that the benefits related to the granting of the authorisation outweigh the risks associated.
  • The applicant will thus have to conduct a socio-economic analysis as well as the CSR and Analysis of Alternatives.
  • The exposure and associated impacts assessment is particularly complex for this substance due to its PBT and vPvB properties
  • To assess the impacts for health and the environment, EcoMundo recommends to double the approaches through modelling and data monitoring
  • The creation of a dossier is usually between 6 and 18 months depending on the complexity of the dossier (intrinsic properties of the substance, complexity of the applicants’ value and production chain.
  • Key elements of a successful authorisation dossier:
  • A specific request with the most elements possible in relation to your activity
  • Transparence and realism of the hypotheses and data as all elements produced will be challenged by the committees or stakeholders
  • Underlining the exposure for man and the environment with associated emission measures
  • The choice of the monetary assessment methodology is key for this dossier

Planning recommendations

  • The Latest Application date for this substance is 04/04/2019, the last submission window is on February 2019.
  • It is therefore recommended to start the creation of the dossier immediately (september 2017).