A much-respected industry contact contacted LCN in November to draw our attention to proposals by the European Chemicals Agency (ECHA) to restrict Siloxanes D4, D5 and D6.
The essential details are set in the panel below. Crucially, the source suggested that while no outright ban is proposed, he and his colleagues were concerned that this effectively means that it would no longer be possible to use Siloxane in drycleaning as “it will not be technically practicable bearing in mind that it would be almost impossible to conform to the terms of the derogation, ie no release to air or wastewater”.
We put these points to Ron Benjamin, the co-founder and managing director of GreenEarth Cleaning (pictured). We publish his comments in full.
“We appreciate you giving us this opportunity to provide you with full background information regarding the derogation that will allow GreenEarth’s current maximised sustainability drycleaning process to continue to be used in the EU and the role that GreenEarth has played in its genesis.
“GreenEarth Cleaning was formed in 1999 by three drycleaners for the express purpose of providing a safe alternative to perchloroethylene and petroleum-based solvents. As a part of our mission, we have always accepted the role of working with machine manufacturers, chemical formulators, garment manufacturers, the real estate industry, and importantly, regulators at the international, national, state, and local level in order to work towards the optimal sustainable drycleaning process from both a human health and environmental viewpoint. We’ve accepted a role that is significantly more than simply that of a marketeer.
“It was with this role in mind that we provided our initial submittal to Sanna Henrichson, the scientific officer of the Risk Management Implementation Unit for the European Chemicals Agency in July 2017. Because of the ECHA has issued publicly a call for information with regard to their proposal to restrict siloxanes from use in the EU, and because they had identified Siloxanes D4, D5 and D6 as having equal concern particularly in “wash off down the drain applications”, we provided a thorough initial response with two particular points of emphasis: 1) while D4 and D6 are persistent, bioaccuumulative and toxic, D5 is persistent and bioaccuumulative but IS NOT TOXIC; and 2) the GreenEarth drycleaning process uses D5 only and does not release D5 to the to the environment in an amount in excess of 0.1%.
“Based on our initial scientific submittal, Sanna Henrichson responded to us via an email dated 18 December 2017 wherein she acknowledged our submittal was useful as well as asking us to provide additional information for their consideration. We responded to her request on 26 December 2017.
“In May 2019 we submitted information that was in addition to that which we provided in our original submittal in July and subsequent information in December 2017. The additional information was submitted based upon the request for Public Consultation for ECHA Proposed Restriction on D4, D5 and D6 published earlier in 2019. Following our May 2019 submittal, we participated in a conference call with Peter Simpson, Maria Ottati and Sandrine Lefevre of the ECHA in which we had the opportunity to further clarify why the use of pure Siloxane D5 in the GreenEarth drycleaning process provided a reasonable and more sustainable alternative to other drycleaning methods in use in the EU. We were also asked to experiment with drycleaning equipment at our Kansas City headquarters and report our findings to them. We did so in a report in August 2019.
“The ten year derogation for using Siloxane D5 (and not Siloxane D4 and D6) in the GreenEarth drycleaning process was not published accidentally. Rather, it came as a result of the collaboration and information that we at GreenEarth provided to the ECHA.
“In summary, it has always been our belief that GreenEarth’s Siloxane D5 drycleaning process provides our industry with the current optimised sustainability solution and that the derogation the ECHA is providing will allow our 6,000 GreenEarth cleaners and affiliates to continue providing our current solution as well as our future solution with no release to the air or water.
“We appreciate the opportunity given to us by the ECHA to work cooperatively with them and to continue to provide our industry with the safest drycleaning process.”
ECHA ANNEX XV REPORT
The European Chemicals Agency (ECHA) submitted its restriction proposal on three substances – octamethylcyclotetrasiloxane (D4), decamethylcyclopentasiloxane (D5) and dodecamethylcyclohexasiloxane (D6) – in mid-January at the request of the European Commission. The consultation procedure began in March this year and ended in September.
Siloxanes D4, D5, and D6 are already classified as substances of very high concern (SVHC).
The ECHA Annex XV report outlines a proposal to restrict the placing on the market of D4, D5 and D6 as substances, as constituents of other substances, or in mixtures in a concentration equal to or greater than 0.1% w/w of each substance. Derogations were proposed for the use of D5 for drycleaning in certain circumstances. According to the Annex XV report, it is proposed that 10 years after the entry in force the use of D5 for dry-cleaning will continue to be permitted only if ‘D5 is fully recycled or incinerated, and where there is no release to air or wastewater.’