Submission of Information on ALTERNATIVES (NON-CONFIDENTIAL)

Submission of information on

Template

for third party submission of information on alternatives for

Applications for Authorisation

non-confidential

Legal name of submitter(s): National Institute for Public Health and the Environment (RIVM), The Netherlands

Table of CONTENTS

1. alternative ID and properties 3

2. Technical feasibility 3

3. Economic feasibility 3

4. Hazards and risks of the alternative 3

5. Availability 3

6. Conclusion on suitability and availability of the Alternative 3

7. other comments 3

References 3

APPENDIXES 3

1. alternative ID and properties

Substance name / CAS number
Castor oil / -
Diethylene glycol (DEG) / 106-19-4
Dioctyl sebacate (DOS) / 122-62-3
Glycerol / 56-81-5
Glycerol carbonate / 931-40-3
Trioctyl trimellitate / 3319-31-1

2. Technical feasibility

3. Economic feasibility

4. Hazards and risks of the alternative

5. Availability

6. Conclusion on suitability and availability of the Alternative

7. other comments

A report was prepared by AMEC, commissioned by RIVM, as preparation for the review of applications for authorisation on various phthalates that are now on the agenda's of RAC and SEAC. The report has been prepared up front in the authorisation process, before the actual applications had been submitted. Because of that, the report has a somewhat broader view than the applications for authorisations on DBP that have actually been submitted to ECHA. Some of the information could be relevant for specific applications during their public consultation. For the application of DBP in propellants, some additional potential alternatives are mentioned in the report of AMEC that have not been discussed by the applicant.

In addition to the potential alternatives for DBP used in propellants mentioned by the applicant, we would like the applicant to consider the following substances:

Table 1: Additional potential alternatives for DBP in propellants (excluding substances already assessed by the AoA of the applicant)

Substance name / CAS number
Castor oil / -
Diethylene glycol (DEG) / 106-19-4
Dioctyl sebacate (DOS) / 122-62-3
Glycerol / 56-81-5
Glycerol carbonate / 931-40-3
Trioctyl trimellitate / 3319-31-1

These substances are mentioned within research coordinated by the US Army Picatinny Arsenal in collaboration with other organisations and private companies. In 2006 the team developed a propellant that eliminated DBP, DNT and DPA among other substances for medium calibre ammunition (25 mm). This double-base propellant, denominated PAP-8386, involved the use of NG as a plasticiser in a solventless process. Coating deterrents were added but no details about the specific substance were made public. Further phases of the project explored the use of this propellant in larger calibres (120 mm). For this purpose, changes in the formulation of PAP-8386 were investigated, including the addition of inert plasticisers (table 1). Only one of these (not disclosed) is reported to have provided good technical results. Although PAP-8386 is already DBP-free, the selected plasticiser may offer potential as a replacement of DBP in other types of propellants. More information can be found on pages 37-46 of the attached document.

References

Analysis of alternatives for a group of phthalates - Final Report, AMEC Environment & Infrastructure UK Limited, December 2013

APPENDIXES

[insert consultation number] [insert non-confidential generic name of the alternative substance/mixture or description of the alternative technology] [insert date of submission]

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