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Towards chemical sustainability Putting the EU Strategy into action - 2021 Review Meeting - Ecetoc
2021 Review Meeting

       Towards chemical sustainability

      Putting the EU Strategy into action

         14 April 2021
| 1
Towards chemical sustainability Putting the EU Strategy into action - 2021 Review Meeting - Ecetoc
Overview of ECETOC activities
                   Introduction
                                  Objectives of the event
Programme of the
day                  Keynote      Prof. Annemarie van Wezel, UoA

                                  ‘Talking about the role of science in the context of
                      Panel
                                  the Chemicals Strategy for Sustainability’

                                  Persistent chemicals and water resources
                                  protection
                     Reviews      Assessing the human health and environmental
                                  safety of polymers
                                  Making best use of exposure science developments

                    Breakout      What further could ECETOC do to support
                                  the Chemicals Strategy for Sustainability
                                  implementation?

                   Conclusion     Plenary wrap-up and close

 | 2                                                                     @ECETOC
Towards chemical sustainability Putting the EU Strategy into action - 2021 Review Meeting - Ecetoc
Overview of ECETOC
activities

 | 3
Towards chemical sustainability Putting the EU Strategy into action - 2021 Review Meeting - Ecetoc
100+ scientific experts involved
2020 in numbers
                  2 Scoping meetings
                  4 Technical Reports
                  4 manuscripts in peer reviewed publications
                  3 Workshops
                  2 Workshop reports
                  2+ Online contributions to SETAC Dublin
                  3 Webinars on Science Communications #ScienceChats
                  1 App for the registration of nanomaterials #NanoApp

  | 4
                  Contributions to ECHA, CARACAL and UNEP meetings
Towards chemical sustainability Putting the EU Strategy into action - 2021 Review Meeting - Ecetoc
Discussion/debate seminars on
                                                                                                                        Persistence in the 21st Century (TBC)

2021 Outputs                                Manuscript from Expert Group on                                              Special Thyroxine (T4) Task Force
                                                  State of the science of                                                         Manuscript #4
                                            invertebrate endocrine disruption
                                               in relation to EU regulation                                                    TR 133-3 on Polymers
                                                                                                                                   (Case Studies)

                                                TR on Exposure Based                                                      Workshop on Use of generic in
                                                Adaptations (end April)                                                    vitro – in vivo extrapolation
                                                                                                                                  (IVIVE) models

                                                         TR 139
                     Q1                                                                                                  Workshop on Omics thresholds
                                            Persistent Chemicals and Water                      Q3                             of non-adversity
                                                 Resources Protection

                 WR 37 on
         Exposure Based Adaptations                                                  Literature Review on TRA
                 (February)                                                                   Workers

                 TR 136 on                                Q2                      Manuscript on TRA Consumers                           Q4
           Derived No-Effect Level
                 (February)
                                                                                   Manuscript and TR from Task
          TR 138 Guidance on dose-                                                     Force on Geospatial
           setting in repeated-dose                                                Approaches to increasing the
           toxicity studies (March)                                                  ecological relevance of
                                                                                    chemical risk assessments
    Special Thyroxine (T4) Task Force
 Manuscript #2 (accepted for publication)                                        Special Thyroxine (T4) Task Force
                                                                                          Manuscript #3
 Manuscripts from Task Force on Moving
 Persistence assessment into 21st century                                         Discussion/debate seminars on
          (submitted for review)                                                Persistence in the 21st Century (TBC)
   | 5
Towards chemical sustainability Putting the EU Strategy into action - 2021 Review Meeting - Ecetoc
Objectives of today

 | 6
Towards chemical sustainability Putting the EU Strategy into action - 2021 Review Meeting - Ecetoc
Putting the EU
Strategy into
action

                 Review    Share

                 Discuss   Plan

  | 7
Towards chemical sustainability Putting the EU Strategy into action - 2021 Review Meeting - Ecetoc
Keynote address

Prof. Annemarie van Wezel
Professor of Environmental Ecology
Institute for Biodiversity and
Ecosystem Dynamics
University of Amsterdam

  | 8
Towards chemical sustainability Putting the EU Strategy into action - 2021 Review Meeting - Ecetoc
Faculty of Science

 Science to help reaching a
 toxic-free environment
 Annemarie van Wezel
Towards chemical sustainability Putting the EU Strategy into action - 2021 Review Meeting - Ecetoc
Faculty of Science

Growth in numbers and volumes of synthetic chemicals used
outpace other factors of global change

                                               Bernhardt et al 2017 Front Ecol Environ
Faculty of Science

Global Understanding of Chemical Pollution

Over 350 000 chemicals and
mixtures registered for production
and use worldwide
Identities of many chemicals publicly
unknown, claimed as confidential
(over 50 000) or ambiguously
described (up to 70 000)

                                             Wang et al 2020
Faculty of Science

    Current chemical legislation is not sufficiently protective
•  Chemicals increasingly detected in EU
   surface and drinking waters
• Chemical pollution affects biodiversity in EU
   water bodies
• Over 50% of EU water bodies in poor
   ecological condition
• Future societal developments result in
   higher concentrations and diversity of
   chemicals in the environment
• 90% of EU citizens worry about the impact
   of chemicals on the environment
→ increasing pressure to make EU chemicals
regulation more stringent

                         msPAF‐EC50 highest share in relative explained deviance; Lemm et al Glob Change Biol ‘20
Faculty of Science

    As part of EUGD; Chemicals Strategy for Sustainability (CSS)

•       Chemicals Strategy for
        Sustainability (CSS, oct ‘20)
•       First regional framework
        addressing chemical pollution in a
        holistic manner
•       Covers complete life-cycle of a
        chemical, including design and
        remediation options
Faculty of Science

Current (fragmented) EU registration/authorization frameworks

                                                       Van Wezel et al 2017
Faculty of Science

One Substance – One Assessment?

Chemicals can be registered under multiple
frameworks
Chemicals not approved under one framework can be
allowed under others

Similar function of frameworks, but important
differences in risk assessment strategies → incoherent
assessments

PNEC values for 65 substances registered under
multiple frameworks can differ up to a factor of 5625,
a median difference of 3.6

                                                         Van Dijk et al 2021
Faculty of Science

Comparing ecotoxicity
Comparing PNECs; biocides on average are the most hazardous group of
chemicals

                                                     Van Dijk et al 2021, J Environ Man
Faculty of Science

Use of assessment factors

Applied on most sensitive endpoint, differ
between the frameworks
Little empirical evidence, debated if AFs
sufficiently cover extrapolations (acute to
chronic, lab to environment) and mixture
effects
→ additional uncertainties to
     environmentally safe concentration

                                              Van Dijk et al 2021
Faculty of Science

Towards a successful move toa OS-OA
 • Harmonise environmental protection goals and risk assessment strategies, no
   exemptions for environmental risk assessments, regular re-evaluation
 • Emission, use and production data publicly available and shared, before critical
   PEC/PNEC ratio prioritize most essential uses/sectors
 • Align criteria used to classify problematic substances (SVHC, CfS)
 → streamlining of RAs is not only key to achieve coherent and more transparent
 outcomes but is also essential for functioning of the EU single market

                                                                                Van Dijk et al 2021
Faculty of Science

A toxic-free environment
CSS; where chemicals are produced and used in a way that maximises their contribution to
society including achieving the green and digital transition, while avoiding harm to the planet
and to current and future generations

                                                            → crucial to define what
                                                            organisms, functions and
                                                            environmental effects are
                                                            to be protected

                                                                         Van Dijk et al in press IAEM
Faculty of Science

Optimism on achievability a toxic-free environment

                                             Van Dijk et al in press IAEM
Faculty of Science

Key research requirements
1)           Inclusion of spatial (mobility) and temporal (persistency) variation
             in the risk assessments, including future scenarios and improved
             emission data
2)           Recognise which compounds drive the toxicity of mixtures and
             how these vary
3)           Integrate solutions into the risk assessment process, ie improved
             wastewater treatment, but also development of the sustainable
             chemicals concept
4)           Develop protocol for identifying safer (non)-chemical alternatives
5)           Strengthen the science-policy interface

                                                                         Van Dijk et al in press
Faculty of Science

                     Escher et al 2020
Faculty of Science

 Example target monitoring; Pesticide occurrence in sources for
 drinking water
 Data 2010-2014, The Netherlands,
 63/408 pesticides and 6/52 metabolites
 were prioritized.
 Vast majority not detected or only in low
 concentrations
 In 67% of sources pesticides/metabolites
 detected, in 31% of sources WFD water
 quality standards exceeded

                                                    Sjerps et al 2019 Chemosphere
Faculty of Science

Mobile and persistent pesticides more likely to be classified as
(high) priority pesticides

                     High priority: Pesticides or relevant metabolites present in drinking water
                     Priority: Pesticides or relevant metabolites present in drinking water sources >0.1 μg/L
                     Potential priority: Pesticides or relevant metabolites present drinking water sources > 0.1 < 0.1 μg/L
                     Low priority: Pesticides or relevant metabolites do not exceed 0.01 μg/L                                 Sjerps et al 2019
Faculty of Science

patRoon: Open-Source Software Platform for Environmental
Non-Target Studies

                                                     Helmus et al 21
Faculty of Science

  Risk based monitoring
• 108 source waters clustered on both
  target as suspects
• Half relatively non-vulnerable
• 153/731 target chemicals detected
• 1,398/12,294 occurring HRMS
  features match to 3,590 suspects
• Suspects prioritized for further
  identity confirmation based on semi-
  quantitative occurrence, frequencies
  and info on toxicy
• Once confirmed and assessed as
  relevant, the suspects could be added
  to target monitoring

                                          Sjerps et al 2021
Faculty of Science

Source waters with higher number of chemicals
relate to high levels of infiltrated surface water

                                              Sjerps et al 2021
Faculty of Science

Computational material flow analysis for thousands of CECs in
European waters
• Europe-wide hydrology model E-Hype
• “Locator” values;
    • REACH chemicals and pharmaceuticals -
       Pop x GDP-PPP x WF
    • Pesticides - agriculture land use, 7-day
       application periods during the relevant
       season
• STREAM-EU dynamic mass balance model
  spatially and temporally resolved
• Substance properties
• Estimated emission for 621 pharmaceuticals, 408
  pesticides and 4159 REACH registered organic
  chemicals
• Comparison to monitoring data

                                                         Van Gils et al 2020
Faculty of Science

Prediction per compound per basin

                                    Van Gils et al 2020
Faculty of Science

CMFA accuracy

Model outputs could be compared to measured
concentrations for 226 substance/basin combinations
Average error is effectively zero (-0.01), standard
deviation is 1.20.
In 65% of cases error is below one order of
magnitude, in 90% of cases the error is below two
orders of magnitude

                                                      Van Gils et al 2020
Faculty of Science

  Essentiality & benign-by-design

                        No available            Equal/better functionality
Necessary for                                   Less hazardous
                        technically and
health, safety or                               Less persistant/More
                        economically feasible
critical for societal                           durable
                        non-chemical
functioning                                     Lower emissions
                        alternatives
Faculty of Science

When is redesign suitable

                            Flerlage etal
Faculty of Science

Computer aided approach

                          Flerlage etal
Faculty of Science

Relevance and reliability criteria for water treatment removal
efficiencies
   •9 relevance criteria and 51
   reliability criteria
   •Applied to 244 treatment
   technology studies, 49 papers
   fulfilled the relevance criteria
   •Reliability criteria applied to
   the 49 remaining papers.
   •Findings clearly demonstrates
   the need for a more uniform
   approach.

                                                            Fischer et al 2019
Faculty of Science

                                                                                                          Treatment

                                                              R e m o v a l e f f ic ie n c y ( f r a c t io n )
                                                           -1 . 0
                                                                         -0 . 5
                                                                                     0.0
                                                                                                 0.5
                                                                                                              1.0

                                            S im p le

                                          S o r p ti o n

                                S i z e e x c l u si o n

                    S o r p ti o n a n d si z e e x c l
Sjerps et al 2021
Faculty of Science

Essential elements for a
Chemicals strategy for sustainability                     Thanks to
                                                          Funders (NWO, EU)
                                                          Co-authors
Legislation, chemical design & essentiality, technology   YOU for listening
Panel discussion

Annemarie van Wezel
Professor of Environmental Ecology
Institute for Biodiversity and Ecosystem Dynamics,
University of Amsterdam

Chantal Smulders
General Manager Health Risk and Governance, Shell
Chair of the Board, ECETOC

Christel Musset
Director of Hazard Assessment
European Chemicals Agency (ECHA)

Maurice Whelan
Head of Unit
Chemical Safety and Alternative Methods
European Commission, Joint Research Centre (JRC)

   | 37
Review of ongoing ECETOC activities

Persistent chemicals and water
resources protection:
Tiered approach to exposure and risk
assessment
Nathalie Vallotton, Dow

Assessing the human health and
environmental safety of polymers
Mark Pemberton, Systox Ltd.

Making best use of exposure science
developments
Tanya Dudzina, ExxonMobil

   | 38
Persistent
chemicals and
water resources
protection:
Tiered approach to
exposure and risk
                                                                                 Nathalie Vallotton, Dow
assessment
        Disclaimer: the Task Force’s Technical Report is still in preparation.
         Conclusions presented here should be considered preliminary and
 | 39                                        subject to change [April 2021]
Background   Protecting ground- and drinking water resources is an important
             common goal
             A PMT/vPvM hazard-based concept within the REACH context has
             been proposed to improve the protection of these resources
             Available groundwater monitoring data showed:
             • P/M criteria are not predictive of the occurrence of substances in
               groundwater – questioning the proposed criteria
             • Substances detected in drinking water(*) are not only REACH-
               regulated substances – questioning the PMT-concept under REACH
             This indicates the need for further adjustment of the concept

                                  P/vP – Persistent/very Persistent
                                  M/vM – Mobile/very Mobile
                                  T – Toxic
              (*)Arp, HP, Hale, S. 2018. Preliminary assessment of substances registered under REACH that could fulfil the proposed PMT/vPvM criteria, vol
              1. Norwegian Geological Institute (NGI).
  | 40
Material &   The ECETOC Task Force is elaborating on the following
             relevant topics:
Methods
             • Review of existing legislation
             • Appropriateness of the proposed PMT-criteria
             • Review of existing monitoring data
             • Level of relevant metabolite concentrations
             • Review of risk assessment approach
             • ECETOC tiered approach

  | 41
Material &   The ECETOC Task Force is elaborating on the following
             relevant topics:
Methods
             • Review of existing legislation
             • Appropriateness of the proposed PMT-criteria
             • Review of existing monitoring data
             • Level of relevant metabolite concentrations
             • Review of risk assessment approach
             • ECETOC tiered approach

  | 42
Findings                             •   Existing EU frameworks including REACH, already provide some
                                         measures (prospective and reactive) to protect drinking water
                                         resources. Opportunities were identified in improving the risk
                                         assessment of man via environment.
                                     •   P & M properties do not seem to be appropriate predictors of
                                         ground water/surface water contamination questioning the
                                         proposed criteria
                                     •   The criteria for ‘T’ as in Annex XIII of REACH already fulfil the
                                         protection goal to ensure a high level of human and environmental
                                         safety
                                     •   The T criteria in the PMT concept focus on human health aspects
Disclaimer: the Task Force’s             only in order to align with the protection goal of safe drinking water
Technical Report is still in             for humans
preparation. Conclusions presented
here should be considered
preliminary and subject to change    •   The threshold for identification of metabolites should follow the
[April 2021]                             recommendations as set within the OECD 307 – 309 test guidelines
      | 43
Material &   The ECETOC Task Force is elaborating on the following
             relevant topics:
Methods
             • Review of existing legislation
             • Appropriateness of the proposed PMT-criteria
             • Review of existing monitoring data
             • Level of relevant metabolite concentrations
             • Review of risk assessment approach
             •   ECETOC tiered approach

  | 44
Human health threshold approach
Overview of                                                     • Guideline values for water quality

frameworks
                                                              WHO                      Protection goal for humans health
                                                                                       • Quantitative risk assessment approaches for
                                                                                         man via the environment
Protection goal for humans health                                                      • Models: EUSES based models (e.g ECETOC TRA,
Quantitative risk assessment approaches for          EPA                                 CHESAR)
man via the environment                              FIFRA,         REACH
• Models: SciGrow, PRZM-GW, FIRST                    FFDCA

                                                                                                  Protection goal for groundwater
                                                              EU               BPR
Protection goal for groundwater resources &                   PPP                                 resources & man via environment
                                                              PPP                                 • Quantitative risk assessment for
human health
• Quantitative risk assessment for the groundwater                                                  groundwater and “man via environment”
  compartment                                                                                     • Property-based cut-off
• Property-based cut-off                                                                          • Models: EUSES based models and FOCUS
• Models: FOCUS GW                                                                                  GW

                                                                WHO:World Health Organization; FIFRA: Pesticide registration: Federal Insecticide, Fungicide, and
                                                                Rodenticide Act; FFDCA: Federal Food, Drug and Cosmetic Act; REACH: Registration, Evaluation,
                                                                Authorisation and Restriction of Chemicals; PPP: Regulation (EC) No. 1107/2009 (EC, 2009 placing of
                                                                plant protection products on the markets); BRP: Biocidal Product Regulation (EU) 528/2012
    | 45
REACH        Information required
             Use and release patterns - exposure
exposure     scenarios
assessment   Physical-chemical properties

framework    Abiotic and biotic degradation
                                                                        Fig. 1

             Routes of exposure
             Drinking water is included in the exposure
             assessment of man via environment
             Sources of drinking water are
             groundwater or surface water
             Exposure in both compartment is
             estimated

                                                                        Fig. 2

                          Fig. 1: REACH guidance R.16 (previous version - version 2.1; Oct 2012) [Source: European Chemicals Agency, http://echa.europa.eu/]
  | 46                    Fig. 2: REACH guidance R.16 (current version - version 3.0; Feb 2016) [Source: European Chemicals Agency, http://echa.europa.eu/]
REACH and PPP
Frameworks &
                                                                                       Route of exposure: indirect vs direct
Parametrisation
                                                                                       Application rate: estimate vs established dosing
                                                                                       Ground water : topsoil vs aquifer
Example of groundwater
                                                                              Fig. 1

    | 47                 Fig. 1: REACH guidance R.16 (previous version - version 2.1; Oct 2012) [Source: European Chemicals Agency, http://echa.europa.eu/]
(B) Indirect exposure from
Case study                                 (A) Pattern of exposure reflecting direct
                                           application to soil 1000g/ha
                                                                                                        release to the STP at 0.7 kg/d

Role of the exposure pathway on
groundwater exposure
Prediction of exposure [µg/L] with
selected degradation half-lives and
Koc values.
A. Direct dosing to soil
B. Emitted to Sewage treatment
    plant (STP)

Identification of the source of drinking
water in the REACH framework.
C. Source with selected degradation
   half-lives and Koc values for a
   theoretical water soluble and low
   volatility substance .
Blue - Surface water                           The transport of contaminants via bank filtration systems is addressed in
Green- Groundwater                             EUSES with a conservative approach and is not addressed in the higher
                                               tier models.

     | 48
ECETOC Tier 0

            Research gaps
                                                 Likelihood for exposure
1)    Ionisable substances
      •      Develop      appropriate
             tools    for     mobility
             assessment of ionisable
             substances                  Assessment of partitioning: Substances
      •      Develop and validate new    requiring specific assessments
             models based on a better    approaches (ionisable, UVCB)
             mechanistic
             understanding.
2)    Develop          screening
      approaches by inclusion of
      one or several leachability        Screening for potential leaching
      indices

     | 49
ECETOC tiered approach for assessment of drinking water safety: Tier 1, 2 and 3
exposure modelling

    | 50
Annual volumes, use patterns and emissions with routes of exposures are
Conclusion           considered as the drivers for groundwater appearance of substances
                     Therefore, a risk-based (modelling) approach, using chemical properties
Tiered approach to   combined with information on emissions and use pattern, provides a more
exposure and risk    suitable alternative to identify potential substances of concern
assessment           A tiered approach to characterising potential human exposure from contaminants
                     in drinking water has been developed by the Task Force
                     Research gaps have been identified:
                     •   Partitioning assessment for substances with specific properties (e.g. ionisables)
                         or for soils with low organic carbon content
                     •   Develop screening approaches by inclusion of one or several leachability indices.
                     •   Improve comprehension of bank filtration processes with respect to transfer
                         of contaminants to and from water bodies
                     •   Integrate this knowledge into environmental distribution models
                     ECO54: Developing a tiered modeling framework in support of risk assessment of
                     chemical substances associated with mobility concerns https://cefic-lri.org/projects/
    | 51
Assessing the
human health and
environmental
safety of polymers

                     Mark Pemberton, Systox Ltd.

 | 52
Task Force    April 2018: Formation of the TaskForce
                                                                                               2018

timeline     May 2019: Publication of ECETOCTechnical Report (TR)
                                                                                               2019
             No. 133-1*

             March 2020: Publication of TR No. 133-2**
                                                                                               2020
             September 2021:
             Planned publication of TR No. 133-3***
                                                                                               2021

             * TR 133-1: The ECETOC Conceptual Framework for Polymer Risk Assessment(CF4Polymers)
             **TR 133-2: Applicability of Analytical Tools, Methods and Models for Polymer Risk Assessment
             *** TR 133-3: Case Studies Putting the TR 133-1 CF4Polymers and TR 133-2 in Practice

  | 53
Conceptual Framework for Polymer Risk Assessment
 (CF4Polymers) [TR 133-1]

 Objective: Develop a Conceptual Framework which:
         – Addresses human health and environmental safety assessment of polymers
         – Builds on existing knowledge and practices
         – Addresses complexity of polymer chemistry, composition, lifecycles and associated
           protection goals
         – Outlines knowledge and data gaps

  | 54
CF4Polymers
[TR 133-1]

  | 55
Test method applicability [TR 133-2]

       ▪ Diversity of polymers so no “one size fits all”
       ▪ Determine applicability on case-by-case basis
       ▪ Not all test methods are applicable to all polymers
       ▪ Not all methods developed for substances are necessary to ensure polymer safety
       ▪ Decision process:
           1. Would the findings from this method add knowledge that would be relevant for risk assessment?
           2. Is it physically / technically possible to perform the test following the formal, TG-conforming
               protocol?
           3. Can the testing protocol be adapted to enable testing of the given type of polymer?

| 56
Grouping and PLC [TR 133-1 and 133-2]

        Recommendation 1 of TR 133-1: Identify sets of structural and/or morphological descriptors as well as
        physico-chemical and fate properties that are key parameters for different types of polymer products.
        Further research is merited to identify which specific properties are the relevant key parameters for fit-
        for-purpose polymer identification and grouping. Specific key parameters might generally be relevant
          across different types of polymers, or they might be unique to specific types of polymer products.
        Knowledge on such key parameters will also facilitate the identification of data needs during exposure
                                                 and hazard assessment.

          Recommendation 4 of TR 133-2: Expand the knowledge base to (1) substantiate the PLC concept
           and (2) to identify under which conditions the presence of specific structural alerts or physico-
                    chemical properties poses environmental or human health hazard concerns.
               Particularly, there is only weak evidence that anionic or amphoteric and water absorbing
                               polymers might generally have a relevant hazard potential.

| 57
▪ Address different components of polymer grouping and risk
                 assessment to put the CF4Polymers into practice
Case Studies
               ▪ Enhance the understanding on the applicability and/or technical
[TR 133-3]       limitations of the corresponding tools, test methods, and models
               ▪ Seven case studies being developed:
                   –   CS 1: Polyacrylates
                   –   CS 2: Cationic polymers
                   –   CS 3: Polyolefins
                   –   CS 4: BADGE (Bisphenol-A diglycidylether) polymers (“polymers undergoing further
                       reaction”)
                   – CS 5: Polyetherols (“polymers undergoing further reaction”)
                   – CS 6: Surfactant polymers
                   – CS 7: Professional applications of polyurethane/polyurea (agricultural/ horticultural
                     and fragrance microencapsulations and in professional paints)

  | 58
▪ Case studies support CF4Polymers (TR No. 133-1)
               ▪ Confirm no “one size fits all” for
Case Studies       ▪ Polymer hazard identification and risk assessment
[TR 133-3]         ▪ Testing methods, where some tests may be:
                        –   difficult or impossible to perform for some types of polymers
                        –   may be relevant to key physico-chemical descriptors / hazard and risk
                        –   irrelevant and be of little or no value

                   ▪ Polymer identification for grouping purposes i.e.
                        –   key structural descriptors / physico-chemical properties are specific to polymer type and not
                            generally applicable

               ▪ Confirm applicability of the three conceptual frameworks
                 for biodegradation / bioaccumulation & ecotoxicity testing
                 (presented in TR 133-2)

  | 59
▪ Provides important insight into grouping of polymers
                       ▪ Proposes a structured approach to grouping supplemental to
Case Studies             the CF4Polymers
[TR 133-3]
                                                          Polymers for

                                                                                                                             hazard similarity
                                                                                                                             Working towards
                                Graphic not to scale
                                                          grouping

                                                          Group level 1

                                   Layer 1:
                                Chemical nature           Group level 2

                                                                                                                            maintain hazard similarity
                                                                                                                            Establish, describe &
                                                          Group level 3
                                                          (final)
                                                          Maintain final group level

                                                                                           R
                                   Layer 2:
                          Physico-chemical properties

                                   Layer 3:
                         (Eco)toxicological properties
                                                          Hazard similarity achieved / maintained for polymers
               Note that the grouping concept is intended to be flexible:
               Certain steps steps may not be useful for all cases, and some cases may benefit from adding other aspects.
  | 60
Making best use of
exposure science
developments

                     Tanya Dudzina, ExxonMobil

 | 61
Overview   EU CSS elements - where/how exposure science
           developments may provide solutions
           Mapping to ongoing ECETOC work
           •Aggregate exposure TF
           •Exposure Based Adaptations TF
           •New Transformational Program
           Summary & conclusions
           •Delivering transparent, data-driven approaches

  | 62
EU CSS opens up opportunities
                     for exposure science
       Actions
       • banning the most harmful chemicals in consumer products - allowing their use only where essential

       • account for the cocktail effect of chemicals when assessing risks from chemicals

       • phasing out the use of per- and polyfluoroalkyl substances (PFAS) in the EU, unless their use is
         essential

       • boosting the investment and innovative capacity for production and use of chemicals that are safe
         and sustainable by design, and throughout their life cycle

       • promoting the EU’s resilience of supply and sustainability of critical chemicals

       • establishing a simpler “one substance one assessment” process for the risk and hazard assessment of
         chemicals

       • playing a leading role globally by championing and promoting high standards and not exporting
         chemicals banned in the EU

| 63
ECETOC exposure projects
                strategically address CSS objectives
       “One substance one assessment”, “cocktail effect”
       ECETOC TF on Mid-tier approaches to aggregate exposure
                                                                                                                                                                                                                                       Screening aggregate exposure for 13 substances

        –   Develop methods to estimate reasonable worst-                                                                                                                                                     D5 – use in cosmetics not
                                                                                                                                                                                                                              included
                                                                                                                                                                                                                                                                                                D5 – use in cosmetics
                                                                                                                                                                                                                                                                                                             included
            case/more realistic aggregate
                                 k=2
                                          exposure across
                                                    k=3 k=2
                                                                Triethyl phosphate                                             Triethyl phosphate
                                                                                                                                     Triethyl phosphate                            Triethyl phosphate
                                                                                                                                                                                         Triethyl
                                                                                                                                                                                                      k=4
                                                                                                                                                                                                  phosphate
                                                                                                                                                                                                                              k=3                                                      k=4
                                                                                                                                                                                                                                                                                                Triethyl phosphate
                                                   1,4-dichlorobenzene                                            1,4-dichlorobenzene                                1,4-dichlorobenzene
            different products/uses                   BPA Tributyl phosphate
                                                                            Acrylonitrile                                   1,4-dichlorobenzene
                                                                                                                     BPA Tributyl  phosphate
                                                                                                                                            Acrylonitrile                      1,4-dichlorobenzene
                                                                                                                                                                        BPA Tributyl
                                                                                                                                                                                               Acrylonitrile                                                                           1,4-dichlorobenzene
                                                                                                                                BPA                                                BPAphosphate                                                                                           BPA
                                             1                                                                  1                                    Acrylonitrile 1                                    Acrylonitrile                                                                                        Acrylonitrile
                                                                                                                         1      Tributyl phosphate                          1      Tributyl phosphate                                                                             1       Tributyl phosphate

        –   Address typical REACH widespread dispersive uses
                                                     DIDP                                                               DIDP                  DIDP        1-ethoxypropan-2-ol                           DIDP                   DIDP       1-ethoxypropan-2-ol                           DIDP         1-ethoxypropan-2-ol

            (e.g. consumer articles, cleaning, coatings, DIY
                                             0           DINP
                                                                   1-ethoxypropan-2-ol
                                                                                                                0             DINP
                                                                                                                                         1-ethoxypropan-2-ol
                                                                                                                                06,6'-di-tert-butyl-2,2'-methylenedi-p-cresol
                                                                                                                                                                          0                                   DINP
                                                                                                                                                                                                                         1-ethoxypropan-2-ol
                                                                                                                                                                                                                06,6'-di-tert-butyl-2,2'-methylenedi-p-cresol                     06,6'-di-tert-butyl-2,2'-methylenedi-p-cresol

            products)                             6,6'-di-tert-butyl-2,2'-methylenedi-p-cresol                       6,6'-di-tert-butyl-2,2'-methylenedi-p-cresol
                                                                                                                                        DINP                                                         6,6'-di-tert-butyl-2,2'-methylenedi-p-cresol                                             DINP
                              Dim2 (18.1%)

                                                                                                 Dim2 (18.1%)

                                                                                                                                                                                 Dim2 (18.1%)
                                                                                                                          Dim2 (20.7%)

                                                                                                                                                                                                          Dim2 (20.7%)

                                                                                                                                                                                                                                                                   Dim2 (20.7%)
                                                                                                                                                                                                                                DINP
                                                                                                                                                                             Toluene                                                                     Toluene                                                     Toluene
                                                                                                                                                                   Toluene
                                                                                 Toluene                                                 -1                                                                              -1                    Toluene                            -1

        –   Identify priorities & mechanisms for filling data
                                             -1

                                                       DEHP
                                                                                                                -1
                                                                                                                                              DEHP                               MEK
                                                                                                                                                                                                -1
                                                                                                                                                                                                                               DEHP                          MEK                                                         MEK

            gaps                                                                      MEK
                                                                                                                        DEHP
                                                                                                                                         -2                           MEK
                                                                                                                                                                                                        DEHP
                                                                                                                                                                                                                         -2                        MEK                            -2
                                                                                                                                                                                                                                                                                        DEHP

                                             -2                                                                 -2                                                                              -2

        –   Inform the need/scope of higher tier (probabilistic)                                                                                                                                                                                                                                           Cluster boundaries
                                                                                                                                                                                                                                                                                                           shifted
                                                                                                                                         -3                                                                              -3                                                       -3
            assessments and/or mixture risk assessment
                                             -3                                                                 -3                                   D5                                         -3
                                                      D5                                                                 D5                                                                              D5                         D5                                                         D5
                                                       -2           0            2                                        -2                  -2 0         0   2             2                            -2                    -2 0       0   2         2                               -2            0             2
                                                                 Dim1 (42.2%)                                                                  Dim1 (42.2%)
                                                                                                                                                       Dim1 (41.1%)                                                             Dim1 (42.2%)
                                                                                                                                                                                                                                        Dim1 (41.1%)                                                 Dim1 (41.1%)

                                                                                                                                                                                                                                                                                       Cluster composition may
                                                                                                                                                                                                                                                                                        change if more realistic
| 64
                                                                                                                                                                                                                                                                                         assessment performed
ECETOC exposure projects
            strategically address CSS objectives
       “Championing and promoting high standards”, e.g. by avoiding unnecessary
       animal testing                                                                                                        Industrial               Professional
                                                                                                      PROC20                                                                           PROC20
                                                                                                      PROC19
                                                                                                      PROC18                                                                           PROC19

       ECETOC TF on Exposure Based Adaptations                                                PROC17 Elevated
                                                                                                      PROC17
                                                                                                      PROC16
                                                                                                      PROC15
                                                                                                                                                                                       PROC18
                                                                                                                                                                                       PROC17
                                                                                                                                                                                       PROC16
                                                                                                                                                                                       PROC15
                                                                                                      PROC14
                                                                                                      PROC13                                                                           PROC14                                           TRA worker predicted exposure
                                                                                                                                                                              Volatility
        –   Develop a science-based decision and documentation                                        PROC12
                                                                                                      PROC11
                                                                                                      PROC10
                                                                                                       PROC9
                                                                                                                                                                                       PROC13
                                                                                                                                                                                       PROC12
                                                                                                                                                                                  LowPROC11
                                                                                                                                                                                        fugacity
                                                                                                                                                                                                                                          with and without
                                                                                                                                                                                                                                                    Use     RMMs
                                                                                                                                                                                       PROC10                                                                     Industrial
                                                                                              PROC8b Elevated
            framework for EBA of human health endpoints                                               PROC8b
                                                                                                      PROC8a
                                                                                                       PROC7                               Industrial
                                                                                                                                                                                  Medium Fugacity
                                                                                                                                                                                        PROC9
                                                                                                                                                                                  HighPROC8b
                                                                                                                                                                            Professionalfugacity
                                                                                                                                                                                                                                                                  Professional

                                                                                                                                                                                       PROC8a
                                                                                                       PROC6
                                                                                                           PROC20
                                                                                                       PROC5                                                                            PROC7
                                                                                                                                                                                                                     PROC20
                                                                                                           PROC19
                                                                                                PROC4 Elevated                                                                          PROC6
                                                    Industrial                      Professional                                                                                                                     PROC19
        –   Determine exposure refinement boundaries for common
                                 PROC20
                                 PROC19
                                                                                                PROC3
                                                                                                           PROC18
                                                                                                       PROC4
                                                                                                      Elevated
                                                                                                 PROC17PROC3
                                                                                                            Elevated
                                                                                                           PROC17
                                                                                                PROC2 Elevated
                                                                                                                                                    PROC20
                                                                                                                                                    PROC19
                                                                                                                                                                                        PROC5
                                                                                                                                                                                        PROC4
                                                                                                                                                                                        PROC3
                                                                                                                                                                                                                     PROC18
                                                                                                                                                                                                                      PROC17
                                 PROC18                                                                    PROC16                                                                       PROC2
            REACH exposure models
                           PROC17 Elevated
                                 PROC17
                                 PROC16      PROC14
                                                                                                       PROC2
                                                                                                           PROC15
                                                                                                       PROC1
                                                                                                              10
                                                                                                                 -2     0    2
                                                                                                                      10 10 10 10
                                                                                                                                  4     -2      0
                                                                                                                                                    PROC18
                                                                                                                                                    PROC17
                                                                                                                                             10 PROC16
                                                                                                                                                         2
                                                                                                                                                      10 10
                                                                                                                                                                4
                                                                                                                                                                                        PROC1
                                                                                                                                                                                                      10
                                                                                                                                                                                                         -3
                                                                                                                                                                                                                      PROC16
                                                                                                                                                                                                                      PROC15
                                                                                                                                                                                                                      -2
                                                                                                                                                                                                                  10PROC14     10
                                                                                                                                                                                                                                  -1
                                                                                                                                                                                                                                      10
                                                                                                                                                                                                                                         0
                                                                                                                                                                                                                                                10
                                                                                                                                                                                                                                                   1
                                                                                                                                                                                                                                                          10
                                                                                                                                                                                                                                                             2
                                 PROC15                                                                PROC13                                       PROC15
                                 PROC14
                                 PROC13
                                                                                                       PROC12       Inhalation exposure, mg/m3      PROC14
                                                                                                                                                                                                     Volatility
                                                                                                                                                                                                             Dermal        exposure, mg/kg/day
                                                                                                                                                                                                                      PROC13
                                 PROC12                                                                PROC11
                                                                                                  Volatility                                        PROC13                                                            PROC12                                                                Use
        –   Propose revisions to REACH Annex XI to allow consistent and
                                 PROC11
                                 PROC10
                                   PROC9
                                                                                                       PROC10
                                                                                                      Low PROC9
                                                                                                            fugacity
                                                                                              PROC8b Elevated                     LEV
                                                                                                                                            RMM
                                                                                                                                                        RMMs exposure reduction efficiencies assumed
                                                                                                                                                    PROC12
                                                                                                                                                    PROC11Industrial Professional
                                                                                                                                                           depends on PROC
                                                                                                                                                                                                       Note
                                                                                                                                                                                                               LowPROC11

                                                                                                                                                                                                               Medium
                                                                                                                                                                                     inh & derm (for PROCs 7, 11,
                                                                                                                                                                                                                        fugacity
                                                                                                                                                                                                                      PROC10
                                                                                                                                                                                                                  17, 18 only) Fugacity
                                                                                                                                                                                                                                           Use
                                                                                                                                                                                                                                               Industrial
                                                                                                                                                                                                                                                                                                  Industrial
                           PROC8b Elevated                                                                                                          PROC10
                                                                                                       PROC8b                                                                                                            PROC9
            robust EBA approaches
                                                                                                      Medium    Fugacity          Ventilation                  0.7         0.3       inh exposure only
                                                                                                                                                                                                                                                                                                  Professional
                                 PROC8b                                                                PROC8a                     RPE
                                                                                                                                                     PROC9    0.05         0.1       inh exposure only                                         Professional
                                 PROC8a                                                               High  fugacity              Duration (15 min-1PROC8b
                                                                                                                                                                                                               HighPROC8bfugacity
                                   PROC7                                                                  PROC7                                      hour)     0.2         0.2       inh & derm
                                                                                                                                                                                                                      PROC8a
                                                                                                                                  Gloves            PROC8a    0.05         0.1       dermal exposure only
                                   PROC6                                                                  PROC6                                      PROC7                                                               PROC7
                                   PROC5                                                                  PROC5
                            PROC4 Elevated                                                                                                           PROC6                                                               PROC6
                                                                                                PROC4 Elevated
               •    Clarify vague terminology
                                   PROC4 Industrial
                            PROC3 Elevated
                          PROC20PROC3
                                                                                    Professional          PROC4
                                                                                                PROC3 Elevated
                                                                                                                                                     PROC5
                                                                                                                                                     PROC4
                                                                                                                                                                                                                         PROC5
                                                                                                                                                                                                                         PROC4
                            PROC2 Elevated                                                                PROC3                                      PROC3                 PROC20
                          PROC19   PROC2                                                                                                             PROC2                                                               PROC3
                                                                                                PROC2 Elevated                                                             PROC19
               •    Re-consider restrictions on “risk-based” EBA
                          PROC18PROC1
                   PROC17 Elevated             -2         0        2    4      -2         0        2
                                                                                                          PROC2
                                                                                                            4
                                                                                                                                                     PROC1
                                                                                                                                                                                         PROC18
                                                                                                                                                                                                                         PROC2
                                                                                                                                                                                                                      PROC110
                         PROC17           10         10       10       10 10         10       10       10          PROC1                                                       10
                                                                                                                                                                                    -3
                                                                                                                                                                                           10
                                                                                                                                                                                              -2
                                                                                                                                                                                         PROC17  10
                                                                                                                                                                                                    -1
                                                                                                                                                                                                            10
                                                                                                                                                                                                                 0
                                                                                                                                                                                                                      10
                                                                                                                                                                                                                         1         2

                         PROC16                     Inhalation exposure, mg/m3                                                        -2        0        2       4     -2       0 Dermal
                                                                                                                                                                                      2 exposure,
                                                                                                                                                                                            4     mg/kg/day                                   -3           -2    -1            0   1    2
                         PROC15                                                                                                  10        10       10       10 10            10 PROC16
                                                                                                                                                                                   10    10                                          10          10           10 10      10        10
                                                                                                                                                                                  PROC15
        –   Set up the basis for “smarter” hazardVolatility
                         PROC14
                         PROC13
                         PROC12
                                                  data generation
                                                            Inhalation exposure, mg/m3                                                                                            PROC14
                                                                                                                                                                                  PROC13
                                                                                                                                                                                                                                            Dermal exposure, mg/kg/day

                         PROC11
            framework where actual exposure, not tonnage, drive data
                         PROC10
                           PROC9
                                                                                                                         Low fugacity
                                                                                                                                                                 LEV
                                                                                                                                                                           RMM
                                                                                                                                                                                       RMMs exposure reduction efficiencies assumed
                                                                                                                                                                                  PROC12
                                                                                                                                                                                  PROC11Industrial Professional
                                                                                                                                                                                          depends on PROC
                                                                                                                                                                                                                                      Note
                                                                                                                                                                                                                    inh & derm (for PROCs 7, 11, 17, 18 only)
                                                                                                                                                                                                                                                                    Use
                                                                                                                                                                                                                                                                        Industrial
                   PROC8b Elevated                                                                                                                                                PROC10
                                                                                                                         Medium Fugacity
            requirements PROC8b
                         PROC8a                                                                                          High fugacity
                                                                                                                                                                 Ventilation
                                                                                                                                                                 RPE
                                                                                                                                                                                    PROC9 0.05
                                                                                                                                                                                  PROC8b
                                                                                                                                                                 Duration (15 min-1 hour)
                                                                                                                                                                                              0.7

                                                                                                                                                                                              0.2
                                                                                                                                                                                                          0.3
                                                                                                                                                                                                          0.1
                                                                                                                                                                                                          0.2
                                                                                                                                                                                                                    inh exposure only
                                                                                                                                                                                                                    inh exposure only
                                                                                                                                                                                                                    inh & derm
                                                                                                                                                                                                                                                                        Professional
                           PROC7                                                                                                                                                  PROC8a 0.05
                                                                                                                                                                 Gloves                                   0.1       dermal exposure only
                           PROC6
                           PROC5                                                                                                                                                    PROC7
                    PROC4 Elevated                                                                                                                                                  PROC6
                           PROC4                                                                                                                                                    PROC5
                    PROC3 Elevated                                                                                                                                                  PROC4
| 65                       PROC3
                    PROC2 Elevated                                                                                                                                                  PROC3
                                                                                                                                                                                    PROC2
ECETOC exposure projects
            strategically address CSS objectives
       “Essential uses”, “safe and sustainable by design”
       Drafting an exposure pillar for the new Transformational Program on
       Evolutionary CSAs

        –   Develop a framework that defines what hazard     Proposed Risk Management scheme
                                                               based on Hazard AND Exposure
            data is necessary for a substance used in
            specific applications

        –   Describe mechanisms to determine how hazard
            data can be obtained

        –   Envision an exposure categorization
            system to guide consistent risk-based
            decisions on use(s) of substances

| 66
Key         Exposure scientists are keen to contribute to successful roll out of EU CSS
            Exposure-driven frameworks can enable transparent, objective risk-based
takeaways   decisions on chemicals management
            Exposure data gaps need to be filled (with appropriate mechanisms)
            • To inform hazard assessment

            • To verify safe use

            • To enable alternatives assessment

  | 67
Group discussion:

       What could ECETOC do to
        further support the CSS
           implementation?

| 68
Q1: What would be the top 3 points of focus of ECETOC efforts
Breakout              in the CSS context?
groups                •

session:              •
                      •

What could            Q2: What uncertainties in the CSS framework could be
ECETOC do to          assessed through ECETOC work?
further support the
                      •
CSS
implementation?       •
                      •

                      Comments:
                      •
                      •
   | 69
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info@ecetoc.org
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