Substance identity -UVCB substancesLead registrant workshop2ndFebruary 2012Steven BuchananUnit C2 – Substance identification and data sharing2/7/20122Aims of this presentation•To highlight how elements ofUVCB substance identity(SID) should be presented in the dossier3⁄4... by providing some practical advice•To help lead registrants to understand why ECHArequires certain UVCB SID information3⁄4... and to what level of detail2/7/20123What is a UVCB substance?•Substance ofUnknown orVariable composition,Complexreaction products orBiological materials•Cannot be sufficiently identified by its chemicalcomposition, because:•The number of constituentsis relatively large and/or•The composition is, to a significant part, unknown and/or•The variability of composition is relatively large or poorly predictable•If the chemical composition of, for example, a complexreaction product is known3⁄4Identification either as mono- ormulti-constituent substance shouldbe considered2/7/20124Appropriateness of EC/CAS identifiers9Only assign an EC/CAS identifier that fits to yoursubstance9Check carefully whether a certain EC/CAS number/nameis specific to your substance9Make sure it does not cover multiple substances9In EINECS there are published descriptions which formpart of the substance identity –where these entries areused you should check whether your substance fits tothis description2/7/20125IUPAC name for UVCB substances•IUPAC rules cannot be easily applied to UVCB substances•Consequently the term “IUPAC” is not so relevant•However, a “substance” name should be provided•The naming of UVCB substances is specific to the UVCBtype•Broadly addressed in the ECHA guidance on SID•More detailed guidance on naming of specific types ofUVCB substance can be sought from the appropriatetrade association2/7/20126Description of manufacturing process9In addition to chemical composition UVCB substancesrequire information on source/manufacture9To be provided in the description field of section 1.1 /section 3.1, or as an attachment in section 1.49Forms part of the substanceidentity - any significantchange may lead to a different substance identity9Should be provided in asmuch detail as possible9identity of starting materials/source (and ratio)9reaction steps/mechanisms9plant operating parameters (e.g. temperatures/pressures)9solvents/reagents used9details of any clean-up/purification steps9Should be specific to the registered substance[Avoid a cut and paste of an EINECS description2/7/20127Example of a description of amanufacturing process1.An aqueous solution (...%) of A is acidified by additionof acid X in a 1:1 molar ratio to form B.2.This solution is then reacted with C, which isdissolved in solvent Y, in a 1:2 molar ratio.3.This 2-phase reaction forms the substance D,dissolved in solvent Y.4.The aqueous layer is separated and disposed of.5.The substance D is purified by distillation.2/7/20128Constituents of UVCB substances9Individual constituents > 10 % (w/w) or relevant for C&Land/or PBT assessment need to be specifically identified9Constituents < 10 % (w/w) which have been specificallyidentified should be reported separately or as part of genericconstituent9Constituents which cannot be specifically identified or are toan extent unknown should be identified as far as possible andreported in generic terms9It is important that close to 100 % accountability of thesubstance composition is achieved2/7/20129Example of how to present genericconstituents and concentration ranges•A hydrocarbon-based UVCB substance has beenanalysed and contains > 50 constituents of which noneare > 10 % in the chromatogram. The company hasgenerically presented the composition as follows:•Linear alkanes (C20-C32) 60-80 % w/w•Branched alkanes (C20-C25) 20-35 w/w•Cyclic alkanes (C20-C25) 0-5 % w/w2/7/201210Concentration ranges for constituents9Always specify: for each specific and generic constituent listedin section 1.29Minimum and maximumvalue (with units)9Realistic: based on knowledge of production batches9They should not be overly broad9Variability is an element of the definition of UVCB substance9It assists ECHA in performing its tasks under REACH such asdata sharing2/7/201211Spectral data and analytical informationfro UVCB substances•Establishes the presence and absence of certain groupsof constituents•Registrants should not limitthemselves to the basic setof techniques listed in Annex VI 2.3.5 and 2.3.6•Where more information can be provided by techniquesnot listed in Annex VI section2, this information shouldbe included2/7/201212Waiving of spectral data and analyticalinformation•If it is not technically possible or if it does not appearscientifically necessaryto give information on one or moreof the items listed in Annex VI, thereasons shall be clearlystated(Annex VI, Section 2)[The fact the substance is a UVCB is not a justification forwaiving9Important that these reasons are robust in their nature ANDpresented as scientifically-based justifications9A more comprehensive analysis has been gained by using analternative technique to those listed in Annex VI, Section 29However, it is still importantthat where the listed techniquesare not applied the reason is explained9Any justification for waiving will be assessed for its validityand consequently may not be accepted as valid2/7/201213Example of a justification for waiving ofspectral data•A company produces a crystalline inorganic UVCBsubstance.•The company considers that the list of spectral data inAnnex VI 2.3.5 is not the best way to identify thesubstance but instead applies elemental analysis (XRF)as well as XRD and IR spectral analyses.•These analyses characterise the substance.•In addition the company waives NMR and UV spectralanalysis based on the substance structure and the factthat more appropriate techniques have been appliedinstead.2/7/201214Key messages for substance identityInformation in the dossier shouldbe sufficient to allow ECHAto conclude on anunambiguoussubstance identityAll information should beclear, concise and noncontradictorySupplementary information can be attached in section 1.4ECHA does not have the same objectives with the use ofspectral data and analytical informationECHA does not possess factual knowledge typically availableto industrySupport:The inquiry TCC tool can be applied to your dossierDSM Part 18 and the ECHA SID Guidanceshould be used to assist in thepreparation of your registration dossier.Thank You!Steven Buchanansteven.buchanan@echa.europa.eu