Manufacturers, importers and downstream users of the substance on its own (regardless of whether DMAC, NEP are a (main) constituent, an impurity or a stabilizer) or in mixtures in a concentration equal or greater than 0.3 % shall use in their chemical safety assessment and safety data sheets by [date to be specified] a worker based harmonized Derived No Effect Level (DNEL) value [to be specified] for long-term inhalation exposure and a worker based harmonized DNEL value [to be specified] for long-term dermal exposure. Manufacturers and downstream users are to implement appropriate risk management measures ensuring exposure of workers remains below the specified DNEL(s).
The scope may become wider during the development of the Annex XV in case unacceptable risk is identified for consumers due to DMAC and/or NEP presence in consumer articles (or product formulations below 0.3%).
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as they explain both the process and the proposal itself.
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The Consultation is intended to provide ECHA’s Committees with scientific and technical information to assist them in the development of their opinions. Although other information can be submitted, any abusive comments will not published monthly and only published at the end of the process without any response from the Dossier Submitter or the Rapporteurs.
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It is possible to provide both general comments on the Annex XV restriction report subject to
this Consultation and answers to the specific questions posed. In both cases, it is necessary to provide supporting
evidence to allow ECHA’s Committees to take your comments into account. It is important not to leave the submission of any
socio-economic information until the consultation on SEACs opinion but already submit relevant comments at this stage.
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Do you have information available regarding workplace exposure to DMAC/NEP and number of people exposed?
* Compulsory Fields
Experiences from NMP/DMF restrictions:
Similar binding DNELs as now suggested for DMAC/NEP have been earlier derived for NMP and DMF in restrictions.
Information on use and substitution of DMAC and NEP:
The professional use of formulations with high NEP concentrations are assumed to cease due to the proposed restriction (e.g. graffiti and paint remover, leather finishing agent and use as hardener for isocyanate-based sealers used on flooring).
What is the economic feasibility of potential alternatives? There are already potential alternatives for some applications, but so far mainly at the technical level, e.g. dialkyl carbonates for DMAC use in fibre production and hydroxymethylfurfural for NEP use in binders. Would you be able to give an assessment of whether such alternative processes might also be economically feasible? Are you aware of other potential alternatives/processes not mentioned above?
Costs of installing an LEV system (Local exhaust ventilation).
Effort and costs required for a training schemes.
Sectoral impacts and costs to downstream users: In case upstream companies currently using DMAC or NEP would have to discontinue their use of DMAC or NEP what kind of impacts there would be, please, describe:
Could negative socioeconomic impacts arising as a result of the proposed restriction be managed or avoided by means of specific transitional periods e.g. for specific sectors. Please describe the impacts that would occur under different lengths of transitional period. Please provide supporting information along with your comment.
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