EUROPEAN UNION

REACH:

Under REACH, modified alcohols (MA) have been registered for surface cleaning and textile cleaning application respectively and with their current classification under the Regulation (EC) No 1272/2008 (CLP-Regulation) they do not meet the definition of Substances of Very High Concern (SVHC). The use of MA in surface cleaning application is therefore not limited by REACH.

Currently SAFECHEM is not aware about any intentions within the EU to regulate MA more strictly.

Flammability:

The major safety aspect for the use of MA is not their toxicological profile (as in the case for chlorinated or fluorinated solvents) but their flammability. For the context of this chapter it needs to be understood, that some MA are not classified and labelled as flammable under the CLP-Regulation due to a flash point above 60°C. Nevertheless, they have the capability of catching fire and burning, thus they are per scientific definition flammable liquids.

Within the EU there is no overall regulation or directive regulating the handling and storage of flammable liquids. The Directive 1999/92/EC (ATEX-Directive)  sets minimum safety and health protection requirements. Storage of flammable liquids is regulated individually by each Member State.

As an example, Germany regulates the handling of hazardous goods in the Hazardous Goods Ordinance (Gefahrstoffverordnung) and concretizes the storage of hazardous goods, including flammable liquids in movable containers within the TRGS 510 (technical rule for hazardous goods = Technische Regeln für Gefahrstoffe).  

In the UK (although not part of the EU anymore), the applicable regulation is the Dangerous Substance and Explosive Atmosphere Regulation 2002 (DSEAR) which is enforced by the Health and Safety Executive (HSE). The HSE publishes Health and Safety Guidance’s (HSGs) which help to understand how to comply with the law. Of the most interest here would be the HSG51 (Storage of flammable liquids in containers), HSG140 (Safe use and handling of flammable liquids) and HSG176 (Storage of flammable liquids in tanks).

A general safety rule for the use of MA is that under atmospheric pressure the max. permissible temperature is the flash point minus 15°C. For a product with a flash point of 61°C, this would result in a max. permissible temperature of 46°C. To achieve required cleaning results in industrial parts cleaning applications, the solvent must even be operated above the flash point. The use of MA in closed cleaning machines is therefore only possible under vacuum.

As various requirements exist for the handling and storage of flammable liquids  within the EU, SAFECHEM recommends each user of MA to identify for his application the applicable laws, regulations, standards, guidelines in his region.