H4R Consortium - Substance Identification. Monday 27 th April 2015

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1 H4R Consortium - Substance Identification Monday Mike Penman Page 1

2 Outline H4R Consortium scope Rosin Chemistry basics Substance ID in H4R Common standards and reporting Reference Substances Development of SIPs and Categories Endpoint Data Alignment Communication with SIEFs Observations Page 2

3 Hydrocarbon Resins & Rosin Resins REACH Consortium.. Open to European and non-european companies manufacturing or importing of Hydrocarbon Resins, Rosin Resins and Pine Chemicals Materials which are similar to one or several of the substances covered. Downstream users and other data holders are invited to play an active role in the work of the consortium. Started November substances registered in 2010, 14 in 2013 Executive, Steering and Technical Committees Financial, Operational and Technical oversight Penman Consulting operational and technical management since 2011 Page 3

4 H4R Consortium Promotes cooperation Public website at Information Substance and category lists 2010 to 2018 Links to ECHA CLP site for all substances Letter of Access costs Page 4

5 Rosin One of the earliest mentioned chemicals in the world Genesis 6:14 Make yourself an ark of gopher wood. Make rooms in the ark, and cover it inside and out with pitch. The name colophony is directly linked to the ancient town Colophon in Turkey Page 5

6 Rosin Basic Chemistry Complex organic substances- Rosin extracted from trees True UVCBs* All types of rosin have the same basic chemistry Consists of Diterpenic monocarboxylic acids % Neutral fraction 5 to 15 % neutrals (> 50 components identified) It is unlikely that any of these constituents are present at concentration > 10 % Thousands of potential component structures Too many to identify individually *Unknown, of Variable Composition, or of Biological Origin Page 6

7 Chemical Composition Acid Fraction (85 95 %, 20 acids) Neutral Fraction (5 15 %) Page 7

8 Categories of Rosins and Derivatives Rosin and its salts Rosin esters Rosin adducts and their salts Adducted with maleic anhydride or fumaric acid Formation of a tri-acid Rosin adduct esters Page 8

9 Rosin and derivatives in H4R Category 1 Category 2 Category 3 Category 4 Rosin and its Salts Rosin Esters Rosin Adducts and Rosin Adduct Salts Rosin Adduct Esters esters Rosin, fumarated, reaction products Rosin, hydrogenated Rosin, maleated with triethylene glycol with glycerol and pentaerythritol Tal esters Rosin, fumarated fumarated, esters with calcium salts with pentaerythritol pentaerythritol Tal esters maleated, esters with Fat calcium zinc salts with glycerol maleated, calcium salts pentaerythritol hydrogenated, esters with magnesium salts maleated, sodium salts fumarated, esters with glycerol pentaerythritol Rosin hydrogenated, esters with glycerol esters potassium salts with diethylene glycol sodium salts polymerized, esters with glycerol Rosin, reaction products with polymerized, esters with formaldehyde pentaerythritol esters reaction products with with ethylene glycol formaldehyde, potassium salt Me Rosin, oligomers esters hydrogenated, Me esters hydrogenated, esters with triethylene glycol Page 9

10 H4R Timeline to June 2011 H4R set up PC DDLs Analytical and Substance ID Submissions Submissions Submissions Dossier Prep Page 10

11 Substance Identity 2010: Registration deadline 10% rule for reporting constituents No single structure above 10% Majority of dossiers submitted gave composition as 100% UVCB Variety of analytical techniques and presentation of data for similar substances Variety of reference substances in I5 Section 1.2 of the dossiers 2011 ECHA Draft Decision Letters Questions on Substance Identity More information required - method description, data and interpretation Uncharacterised substances coherence of categories /read across questioned Requested further compositional information But how to do it and make it coherent across all registrants? Page 11

12 A common standard for identifying Rosin substances Developed a common position on identification methodology Reviewed available technologies, made recommendations Gave detailed model spectra and structures Provided the basis for Individual registrant analysis Common text and interpretation for use in updating dossiers for all registrants Published on SIEF information pages Page 12

13 Developing a standard for reporting substance ID (2) Developed a common report format Methods and interpretation What to report - classes Advantages Commonality between registrants Ease of comparison for Substance ID discussions Page 13

14 Analytical Programme and Reporting Significant analytical programme by (initially) lead registrants Based upon the Reference Document Reported in the common format Some work done at the same time and at the same laboratory Drove consistency Analysis of the data within H4R Page 14

15 Reference Substances in IUCLID Reference substances did not exist for many constituent classes Activity to define / build a common set of reference substances Use in all updates, future registrants From review of analytical data List of constituents / constituent classes Most component classes not on EC inventory Built a set of reference substances Circulated in i5z file for upload into IUCLID Lead Registrants updated dossiers with new information Classes of substances not individual structures, unless >10% E.g. Abietic Acids, Pimaric Acids etc. Page 15

16 Development of SIP Driven by the registrants based upon standard identification for each substance Data from all members considered Reviewed in H4R to agree on substance identity range for each substance All available data from registrants and potential registrants considered Included basic production process description Promoted within the Consortium and the SIEFs Consistency Ability to read across data Page 16

17 Defining Categories on Identity / composition Similar to that described in OECD guidance* Candidate substances in the category Determined compositional possible / elements likely in any significant proportion Considering marker substances of effect (none for H4R) Considering if relevant Physchem data Production process Matrix: category members vs potential structures Populated with ranges of data based on the available data Analytical Physchem Gave sound basis for the Category hypothesis For read across and data development (if required) Recorded in the Category Justification Document *OECD (2014) OECD Guidance On Grouping of Chemicals, Second Edition Series on Testing & Assessment No. 194 Page 17

18 Category - Endpoint Data Alignment & Composition Substance ID allows Confidence that the available endpoint data are fit for purpose to identify intrinsic hazard New data are generated on an appropriate substance Testing proposals in H4R categories Matrix of potential structures. Principle: substances selected for toxicology testing allowed overall coverage of the bookends within the category Supported by Category Justification document H4R testing proposals accepted Page 18

19 Communication with SIEF Members One SIEF Report page per substance Consortia processes Substance Identity Alignment document (SIP) Reference Document Example Substance ID Report News / Updates ECHA decision process Costs for testing CoRAP Letters of access cost and process Once agreed, Registrants responsibility on sameness Page 19

20 H4R Timeline DDLs Testing Final Dev tox and RDT H4R set up DDLs Substance ID DDL Testing 2 Final Repro? Submissions Updates Submissions Updates Updates Submissions Dossier Prep Analytical / Physchem / Reference doc Dossier Prep 2013 Testing strategy Updates Absorption studies Testing Testing? Page 20

21 Observations on Substance ID Substance ID Registrant / SIEF led - cooperative working is key Data led - agree on what is required All need to be able to work to the same standard not exclusive Not a PhD thesis pragmatic approaches work best to get buy in Needs to be understood by all players - over complexity excludes Fit for purpose Supports confidence in the intrinsic hazard data Current data and any testing plans Page 21

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