Rank: Forum user
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Hi all, I appreciate I can't upload an MSDS here, but, we are importing a strong rubber adhesive from Japan (we are a Japanese manufacturing company and the managers want to use this amazing glue they use in Japan to repair our rubber moulds)
They at first gave me a Japanese MSDS which was a bit daft, then the translated version, for which I could make out CAS numbers etc, but, the MSDS is not to format at all, I can see some relevant info such as the major components, %, but no classification as such and the hazard statement is erm, at best, no good, for example "When it sucks, harmfulness (the steam)" is the actual term used
I've broken the major components down and obtained R Phrases through ECHA, then I've used COSHH Essentials and its come up as a "Special"
Here's a component list:
Trichloroethylene (80-90%) CAS 79-01-6
Chloroprene Type Rubber (12-18%) CAS 9010-98-4
2,6 Dj-tert-butyl-p-cresol )0.1-0.5%) CAS 128-37-0
Phenolic Resin (0.5-1.5) CAS 9003-35-4
You can check but some of those CAS dont check out either....
Basically I dont want to use it at the time, Im in a position where I don't feel we have the area, or equipment to control the risk, nor have we the means to dispose of the stuff. "But it's only glue" Ive been told...
Whats your opinion, what would you do next?
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Rank: Super forum user
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Not my specialism but I thought both 'Trics' had been outlawed in this country?
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Rank: Forum user
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Rank: Super forum user
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I've worked for Japanese companies in the past, so have an idea of what you are up against.
COSHH is the least of your problems; if you bring this into the EEC you take on lots of responsibilities as the importer.
Investigate this stuff - if its legal it will already be available to buy off the shelf.
Your Japanese managers are brought up to assume everywhere outside Japan is a bit technologically backward ( I think ours were surprised we were not living in mud huts). But if this stuff is any good someone somewhere will be importing or making is here.
By the way, Japan's product safety standards are very similar to ours, its just a matter of finding the right people to talk to. Again a cultural problem: "your people" will have considerable difficulty in saying " I don't know, I'll have to pass you to someone who does".
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Rank: Forum user
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Cheers guys, its exactly as I thought and Im pleased the opinion and evidence is right on Trike.
My opinion is that after 23 years, of using other solvents, why change now? So I asked one of the Japanese who are bringing this stuff over why? His response, "Because we have too!" My reply, "why now after all this time of not "Having" too" - his reply, "We want too"
I explained there's a difference, so, in this case, I am not prepared to allow it on-site until we've exhausted all alternatives and/or placed all safe measures in place.
Silence is deafening in this room right now, I'm awaiting the question/statement "but it's not illegal!"
Wall Head Bang!
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Rank: Super forum user
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First of all, as far as I am aware, trichloroethylene is not actually banned, but its use is subject to stringent controls, such as only being used in a closed environment.
Secondly, will you be the importer? If so, then you will need to consider REACH and its implications. How much will you be importing annually. If this falls within the remit of REACH then you will need to consider whether each of the constituents has already been registered under REACH. Also has the registration for each included your proposed use? If not, then you will have to face the problem of registering your use for each of the constituents not so registered.
Given the cost of all of this I would suggest you have a good case to put to the Japanese for staying with your existing product.
It might pay you to check out the situation in more detail than I have posted by contacting the Chemical Hazard Communication Society to find a local DGA who can help you.
Chris
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Rank: Super forum user
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Just another thought. Download a copy of the REACH and CLP regulations. (948 and 1335 pages respectively) and present these to your Japanese colleagues with the request that they check these out and decide how they are going to comply! It might just make them think again!
Chris
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Rank: Super forum user
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chris.packham wrote:Just another thought. Download a copy of the REACH and CLP regulations. (948 and 1335 pages respectively) and present these to your Japanese colleagues with the request that they check these out and decide how they are going to comply! It might just make them think again!
Chris
And make sure they have had a DSE Assessment prior...;)
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Rank: Forum user
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Chris, thank-you, it is a small quantity, approximately 500ml that will last over a year as a single use as adhesive. I'm afraid it seems to be falling on deaf ears, but, as far as I'm concerned, it won't be getting used until there's measures in place, we have no closed environments, we don't currently supply breathing apps, and LEV is irrelevant given we have no closed areas. It's a crazy situation them thinking this is going to be a normal procedure.
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Rank: Forum user
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Not actually a bad idea on those regs, given that the same Japanese manager has been tasked by the Parent company, in "Sorting REACH out"
I need a new company to take me on lol
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