National Industrial Chemicals Notification and Assessment Scheme



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Recommendation 1:


The recommended classification for trichloroethylene based on the hazard assessment of currently available data and in accordance with the National Commission’s Approved Criteria for Classifying Hazardous Substances (National Occupational Health and Safety Commission (NOHSC), 1994) is:

Skin and eye irritant (Risk phrase R36/38 Irritating to eyes and skin);

Mutagen - category 3, ie substances which cause concern for humans owing to possible mutagenic effects, but in respect of which available information does not satifactorily demonstrate heritable genetic damage (Risk phrase R40 (M3) May cause heritable genetic effect);

Carcinogen - category 2, ie substances regarded as if they are carcinogenic to humans (Risk phrase R45 May cause cancer).

Products or mixtures containing 0.1% or more of trichloroethylene should also be classified as hazardous.

Recommendation 2:


The draft report was completed in May 1998 and included the following Recommendation:

On the basis that further data relevant to the classification is expected to be available prior to the end of 1998, it is recommended that the NOHSC Hazardous Substances Sub Committee consider the timing of their adoption of the revised classification into the Designated List of Hazardous Substances to allow this additional information to be considered. Any period allowed for consideration of further data should be limited. Such data would require secondary notification and assessment by NICNAS.



The hearing by the Administrative Appeals Tribunal was held in November 1999 and all the data available up to the hearing was considered by the AAT. The above recommendation should therefore be disregarded.

Risk Phrase R65 – Harmful: May cause lung damage if swallowed. The draft Approved Criteria for Classifying Hazardous Substances – Revised Edition (1998) includes a new risk phrase R65 – Harmful: May cause lung damage if swallowed. This risk phrase applies to aliphatic, alicyclic and aromatic hydrocarbons in total concentrations equal to or greater than 10% satisfying certain criteria. From the data currently available to NICNAS it is not possible to consider the applicability of this risk phrase for trichloroethylene.

Recommendation 3:


Any information relating to the criteria needs to be provided under the secondary notification provision of the Industrial Chemical (Notification and Assessment) Act 1989 (section 18).

17.2Control measures


Trichloroethylene is a hazardous substance with carcinogenic and irritancy potential. In accordance with the National Commission’s National Code of Practice for the Control of Workplace Hazardous Substances (National Occupational Health and Safety Commission (NOHSC), 1994) exposure to hazardous substances should be prevented and where this is not practicable control measures should be implemented to minimise risks to health. Control measures should be implemented in accordance with the hierarchy of controls which is a list of control measures, in priority order, that can be used to eliminate or minimise exposure to hazardous substances. In some circumstances it may be appropriate to use two or more control measures to reduce exposure to as low a level as is practicable.

Trichloroethylene can be absorbed through the lungs and skin and control measures should minimise exposure through these routes.


17.2.1Elimination


In the hierarchy of control measures elimination is the first option to be considered to minimise health risks. Elimination is the removal of all chemicals from the process. For example, elimination may occur through a modification of the manufacturing process of the metal parts removing the need for cleaning.

17.2.2Substitution


Where elimination of chemicals from the process is not practicable, substitution with a less hazardous substance or method of application should be considered.

Recommendation 4:


It is recommended that greater research and development be directed to substitute processes and non-hazardous substances.

Other Uses

A number of alternative options are now available. Endusers should review their processes and the alternatives available before replacing trichloroethylene in the process.



Cold Cleaning

Most manufacturers do not support the use of trichloroethylene in cold cleaning. This assessment confirms this use is associated with a high and unacceptable risk.


Recommendation 5


It is therefore recommended that trichloroethylene not be used in cold cleaning, with this use phased out over a period of two years.

Information on solvent substitution is available on the Internet, for example, the Solvent Alternatives Guide (SAGE) and the Hazardous Substances Solvent Substitution Data System (HSSDS).



Products in aerosol form

Recommendation 6:


It is recommended that trichloroethylene not be used in industrial aerosol product form, due to the high and unacceptable risk identified in this assessment.

17.2.3Engineering controls


Formulation

Recommendation 7:


It is recommended that all stages of the formulation process, transfer, mixing and packaging, be enclosed. Transfer of trichloroethylene to the mixing tank and emptying of the tank into containers through closed pipelines will minimise emission of vapours. It is recommended that local extraction ventilation be installed above the mixing tank to remove any fugitive emissions. The area around the mixing tank should be bunded to contain any large spills.

Vapour degreasing

Recommendation 8:


To control worker exposure during vapour degreasing it is recommended that the vapour degreasing tank must conform to the requirements of the Australian Standard AS 2661 - 1983 (Standards Association of Australia, 1983).

Based on past experiences, the following engineering controls have been identified as important.




ENGINEERING CONTROLS
Local exhaust ventilation. The exhaust ventilation should be installed to prevent any agitation of the solvent surface or vapours which will result in vapour being drawn out of the tank;

Modification of old degreaser tanks (including rim ventilation) to include the controls recommended in AS 2661 - 1983 as they limit emission into the environment and therefore worker exposure. This would also reduce solvent requirement because of reduced loss resulting in economic benefit

fitting of roller or sliding doors below the rim ventilation to prevent escape of vapours into the atmosphere. Covers should be used when the tank is in use and when idling; and

use of an overhead lifting device to immerse and remove parts at a controlled rate. This eliminates excess loss and also keeps the operator away from the degreaser


Cold cleaning

Use of trichloroethylene in cold cleaning is not supported by this assessment. Appropriate engineering controls such as local exhaust ventilation must be used to minimise exposure, while use is phased out.



Trichloroethylene products

Use of industrial trichloroethylene products in aerosol form is not supported by this assessment. Local exhaust ventilation will help to minimise exposure of workers to other trichloroethylene products.


17.2.4Safe work practices



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