Consumer exposure modelling under REACH: Assessing the defaults

An assessment of the ECETOC TRA Consumer tool performance as a screening level tool

BACKGROUND

The European Centre for Ecotoxicology and Toxicology of Chemicals (ECETOC) Targeted Risk Assessment (TRA) Consumer tool was developed to fill in a methodology gap for a high throughput, screening level tool to support industry compliance with the European Union's Registration, Evaluation, Authorization, and Restriction of Chemicals (REACH) regulation.

OBJECTIVE

To evaluate if the TRA Consumer tool has met its design of being a screening level tool (i.e., one which does not under-predict potential exposures).

METHODS

The TRA Consumer tool algorithms and defaults were reviewed and performance benchmarked vs. other consumer models and/or empirical data. Findings from existing reviews of the TRA consumer tool were also considered and addressed.

RESULTS

TRA predictions based on its default inputs exceeded measured exposures when available, typically by orders of magnitude, and were generally greater than or similar to those of other consumer exposure tools. For dermal exposure from articles, there was no evidence that a diffusivity approach would provide more appropriate exposure estimates than those of the TRA. When default values are refined using more specific data, the refined values must be considered holistically to reflect the situation being modeled as some parameters may be correlated.

SIGNIFICANCE

This is the first evaluation of the ECETOC TRA consumer tool in its entirety, considering algorithms, input defaults, and associated predictions for consumer products and articles. The evaluation confirmed its design as a screening level tool.

IMPACT STATEMENT

The ECETOC TRA Consumer tool has been widely applied to generate exposure estimates to support chemical registrations under the EU REACH regulation. This evaluation supports the appropriateness of the TRA as a screening level exposure assessment tool. It also warrants additional measurements of consumer exposure, especially for article use scenarios, to aid the development of consumer exposure tools and chemical risk assessment.

Modelling Exposure by Spraying Activities-Status and Future Needs

Spray applications enable a uniform distribution of substances on surfaces in a highly efficient manner, and thus can be found at workplaces as well as in consumer environments. A systematic literature review on modelling exposure by spraying activities has been conducted and status and further needs have been discussed with experts at a symposium. This review summarizes the current knowledge about models and their level of conservatism and accuracy. We found that extraction of relevant information on model performance for spraying from published studies and interpretation of model accuracy proved to be challenging, as the studies often accounted for only a small part of potential spray applications. To achieve a better quality of exposure estimates in the future, more systematic evaluation of models is beneficial, taking into account a representative variety of spray equipment and application patterns. Model predictions could be improved by more accurate consideration of variation in spray equipment. Inter-model harmonization with regard to spray input parameters and appropriate grouping of spray exposure situations is recommended. From a user perspective, a platform or database with information on different spraying equipment and techniques and agreed standard parameters for specific spraying scenarios from different regulations may be useful.

Consumer behaviour survey for assessing exposure from consumer products: a feasibility study

Evaluating chemical exposures from consumer products is an essential part of chemical safety assessments under REACH and may also be important to demonstrate compliance with consumer product legislation. Modelling of consumer exposure needs input information on the substance (e.g. vapour pressure), the product(s) containing the substance (e.g. concentration) and on consumer behaviour (e.g. use frequency and amount of product used). This feasibility study in Germany investigated methods for conducting a consumer survey in order to identify and retrieve information on frequency, duration, use amounts and use conditions for six example product types (four mixtures, two articles): hand dishwashing liquid, cockpit spray, fillers, paints and lacquers, shoes made of rubber or plastic, and ball-pens/pencils. Retrospective questionnaire methods (Consumer Product Questionnaire (CPQ), and Recall-Foresight Questionnaire (RFQ)) as well as protocol methods (written reporting by participants and video documentation) were used. A combination of retrospective questionnaire and written protocol methods was identified to provide valid information in a resource-efficient way. Relevant information, which can readily be used in exposure modelling, was obtained for all parameters and product types investigated. Based on the observations in this feasibility study, recommendations are given for designing a large consumer survey.