Monday 16 April 2012

Dichloromethane (DCM) Restriction


A new ban on some supply and use of paint strippers containing the hazardous substance ‘dichloromethane’ (DCM, and also known as methylene chloride) is coming into force.  For the purposes of this ban, the term 'paint stripper' is taken to mean DCM (or mixtures containing it) intended for stripping paint, varnish or lacquer.

Pure DCM (or mixtures containing it) sold and used for other purposes (e.g. degreasing) aren’t banned and can continue to be sold and used (although not for stripping paint).

The new ban makes a distinction between three types of use:
     
‘Industrial’ use of paint strippers in ‘industrial installations’ (i.e. facilities where paint stripping takes place) – this is allowed to continue as long as certain safe working practices are followed.
‘Professional’ use by workers where this takes place away from an industrial installation.  This will be banned, but UK can choose to allow continued safe use by specifically trained professionals.
‘Consumer’ use by the general public, such as DIY.   Supply to consumers is banned.

Industrial use

Use of DCM-based paint strippers can continue in industrial installations so long as certain safe working practices are followed. Supply for these uses is also permitted. The required conditions for continued industrial use are listed in paragraph 4 of the restriction text:

(a) effective ventilation in all processing areas, in particular for the wet processing and the drying of stripped articles: local exhaust ventilation at strip tanks supplemented by forced ventilation in those areas, so as to minimise exposure and to ensure compliance, where technically feasible, with relevant occupational exposure limits;

(b) measures to minimise evaporation from strip tanks comprising: lids for covering strip tanks except during loading and unloading; suitable loading and unloading arrangements for strip tanks; and wash tanks with water or brine to remove excess solvent after unloading;

(c) measures for the safe handling of dichloromethane in strip tanks comprising: pumps and pipework for transferring paint stripper to and from strip tanks; and suitable arrangements for safe cleaning of tanks and removal of sludge;

(d) personal protective equipment that complies with Directive 89/686/EEC comprising: suitable protective gloves, safety goggles and protective clothing; and appropriate respiratory protective equipment where compliance with relevant occupational exposure limits cannot be otherwise achieved;

(e) adequate information, instruction and training for operators in the use of such equipment.


Paint strippers supplied for industrial use must be labelled in accordance with either the CHIP Regulations or CLP, and must also be 'visibly, legibly and indelibly marked' with the text 'Restricted to industrial use and to professionals approved in certain EU Member States — verify where use is allowed.' Suppliers will wish to satisfy themselves that mixtures are being supplied for legal uses, in order to explain such a due diligence approach if challenged.

Professional (mobile) use

The ban first took effect on 6 December 2010.  Since then formulators of DCM-based paint strippers have not been allowed to put their products into the supply chain for use outside industrial installations. Suppliers could however continue to sell existing stocks to professionals or the public for a further year, until 6 December 2011. On the 6 June 2012 all use of DCM-based paint strippers by professionals outside industrial installations will have to cease.

DCM-based paint strippers are particularly effective at removing very durable coatings – including leaded paint – quickly and without damaging the substrate.  Along with normal paint stripping, DCM-based strippers are widely used the heritage, aerospace and maritime sectors, and for graffiti removal. HSE will consult in the next few months on taking up the derogation to allow continued professional use.  In order to do so, both the government and stakeholders would need to make certain arrangements.  Although we don’t expect to be able to take up the derogation in time for the 6 June 2012 deadline, subject to consultation these measures may be made available later.

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