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ANALYSIS OF ALTERNATIVES
non-confidential report
Legal name of applicant(s): DEZA, a.s.
Substance: Dibutyl phthalate
Use title: Use in ceramic sheets and printing pastes for production of
capacitors and lambda sensor elements
Use number: Use 3
ANALYSIS OF ALTERNATIVES
ii
CONTENTS
1. SUMMARY ............................................................................................................................................. 1
1.1. Background to this Application for Authorisation ......................................................................................... 1 1.1.1. Applicant and Uses .......................................................................................................................................... 1 1.1.2. The role of plasticizers ..................................................................................................................................... 2
1.2. Summary of Issues Considered When Determining the Approach to the AoA ............................................... 2
2. ANALYSIS OF SUBSTANCE FUNCTION.......................................................................................... 3
2.1. Background of the use of DBP in the manufacture of ceramic sheets and printing pastes ............................ 3
2.2. Descriptions of the use of DBP ...................................................................................................................... 4
2.3. Conditions of DBP use ................................................................................................................................... 9 2.3.1. Technical requirements for DBP and alternative substances ........................................................................ 11
3. IDENTIFICATION OF POSSIBLE ALTERNATIVES ................................................................... 11
3.1. Description of efforts made to identify possible alternatives .......................................................................11 3.1.1. Research and development ........................................................................................................................... 11 3.1.2. Data searches ................................................................................................................................................ 11 3.1.3. Consultations ................................................................................................................................................. 13
3.2. List of potential alternatives ........................................................................................................................13
4. SUITABILITY AND AVAILABILITY OF POSSIBLE ALTERNATIVES ................................... 16
4.1. ALTERNATIVE 1 ............................................................................................................................................16
4.2. ALTERNATIVE 2 ............................................................................................................................................16
4.3. ALTERNATIVE 3 ............................................................................................................................................16
4.4. ALTERNATIVE 4 ............................................................................................................................................16
4.5. ALTERNATIVE 5 ............................................................................................................................................16
4.6. ALTERNATIVE 6 ............................................................................................................................................17
5. OVERALL CONCLUSIONS ON SUITABILITY AND AVAILABILITY OF POSSIBLE ALTERNATIVES FOR USE 3 .................................................................................................................... 17
5.1. Conclusion on the technical feasibility of commercially proven alternatives ...............................................18
5.2. Conclusion on the economic feasibility of commercially proven alternatives ..............................................18
5.3. Conclusion on risk reduction potential of commercially proven alternatives ...............................................18
5.4. Overall conclusion........................................................................................................................................18
ANALYSIS OF ALTERNATIVES
iii
FIGURES
Figure 1: Description of production ceramic chip capacitors-part 1 (Johanson Dielectrics) .............. 4 Figure 2 Description of production ceramic chip capacitors-part 2 (Johanson Dielectrics) ................ 4 Figure 3: Description of production ceramic chip capacitors (Lee, 2008) ......................................... 5
Figure 4: The principle of ceramic slurry preparing ........................................................................... 6 Figure 5: Manufacture dielectric paste and sheet formation (TDK, 2008) ......................................... 6 Figure 6: Electrode printing and sheet layering (TDK, 2008) ............................................................ 7 Figure 7: Cutting and sintering ............................................................................................................ 8 Figure 8: Application of terminal electrode, inspection and packaging (TDK, 2008) ........................ 8
Figure 9: The structure of ceramic capacitor (With, 1993; He, 2004) ................................................. 8
TABLE
Table 1. Parameters for DBP use in the manufacture of ceramic types............................................. 10 Table 2. Key information sources used in the identification of potential alternatives ....................... 12 Table 3. Key information sources used in the collection of information on the properties of potential
alternatives ......................................................................................................................................... 12
Table 4. Identities and REACH registration status of alternative substances .................................... 14 Table 5. Comparison of selected potential alternative substances against key technical comparison
criteria ................................................................................................................................................ 15
ANALYSIS OF ALTERNATIVES
1
1. SUMMARY
1.1. Background to this Application for Authorisation
1.1.1. Applicant and Uses
The applicant, DEZA, a.s. (hereafter referred to as “the applicant” or “DEZA”), is a Czech
manufacturer of dibutyl phthalate (DBP), EC No. 201-557-4, CAS No. 84-74-2. Dibutyl phthalate is
manufactured at site in Otrokovice, approximately 60 km from Valašské Meziříčí. DBP made by
DEZA is consumed in a number of uses; one of the smaller ones is the use of the substance by a
small number of EU-based companies in production of ceramic sheets and printing pastes used for
manufacture of capacitors and lambda sensor elements. The DBP is used as a plasticiser in slurry
for ceramic sheets and printing pastes manufacture and the use for which Authorisation is sought is:
1. Use in ceramic sheets and printing pastes for production of capacitors and lambda sensor
elements
The hazard profile of DBP, together with the potential risks that this substance may pose, has been
the subject of extensive expert assessment including a European risk assessment report (EU RAR
2003, Danish EPA 2011). This assessment reached a number of conclusions which indicated that
concern was warranted with regard to human exposures (including workers, consumers and from
exposure via the environment) and some environmental compartments.
DBP was included in the candidate list for Authorisation following ECHA’s decision ED/67/2008
on 28 October 2008, based upon its classification as Toxic to Reproduction, Category 2 (i.e.
Category 1B, under CLP); this was based largely on information from the EU RAR, supplemented
by limited additional information (ECHA 2009). DBP was further reviewed in a background
document prepared in support of its inclusion in Annex XIV (ECHA 2009), again drawing on the
EU RAR together with data submitted by COWI, IOM and Entec and RCOM.
Since DBP met the criteria in Article 57(c) and, according to available information, it was possible
to determine a toxicological threshold, it was noted that if the risks to human health from the use of
the substance arising from its toxicity to reproduction were to be demonstrated to be adequately
controlled in accordance with Section 6.4 of Annex I and that this was documented in the
applicant’s chemical safety report (CSR), an authorisation would be granted in accordance with
Article 60(2) (‘adequate control route’); if not, an authorisation would be granted in accordance
with Article 60(4) (‘socio-economic route’).
Alongside the Authorisation process, the Danish authorities submitted in 2011 a proposal for a
restriction (together with the justification and background information documented in an Annex XV
dossier) on the placing on the market and use of certain articles containing four classified phthalates
(DEHP, benzyl butyl phthalate (BBP), dibutyl phthalate (DBP) and diisobutyl phthalate (DIBP)) in
articles that are intended for indoor use, or in articles that come into contact with skin or mucous
membranes, on the grounds of the aforementioned Toxic to Reproduction, Category 1B CLP
classification.
The Annex XV report conforming to the requirements of the REACH Regulation was made
publicly available by ECHA on 16/09/2011. The final opinions of the ECHA Committees (i.e. the
Committee for Risk Assessment (RAC), and the Committee for Socio-Economic Analysis (SEAC))
were reached, by consensus, on 12/06/2012 and 05/12/2012, respectively. These are summarised
below:
“RAC considers that the proposed restriction is not justified because the available data do
not indicate that currently (2012) there is a risk from combined exposure to the four
ANALYSIS OF ALTERNATIVES
2
phthalates. The regulatory requirements and consequent reduction in use are further
reducing the risk, as will the authorisation requirements imposed on these phthalates in the
next few years” (ECHA, 2012c).
and
“Taking into account RAC’s conclusions that the proposed restriction is not justified
because the available data do not indicate that currently (2012) there is a risk from
combined exposure to the four phthalates and that the regulatory requirements and
consequent reduction in use are further reducing the risk, as will the authorisation
requirements imposed on these phthalates in the next few years, SEAC has no basis to
support the proposed restriction” (ECHA, 2012c).
This Application for Authorisation takes into consideration and expands upon the discussions held
at the time of the scrutiny of the Danish restriction proposal. It must be noted, however, that the
scope of this Application is significantly different as it covers only the industrial use of DBP in
closed system.
1.1.2. The role of plasticizers
A plasticiser is a substance which when added to a material, usually a plastic, produces a product
which is flexible, resilient and easier to handle. They are an important additive to ceramic slurry
and the majority of ceramic sheet products are plasticised. In modern applications plasticisers are
produced by complete solubility in a toluene/ethanol solvent mix with an acid such as phthalic
anhydride, adipic acid, terephthalic acid, trimellitic mellitate, etc. They are developed to satisfy
demanding technical and economic requirements and, due to their technical performance, versatility
and cost- effectiveness, phthalate-based plasticisers are the most widely used type within the EU
and globally.
Plasticisers are liquids of low or negligible volatility or low molecular weight solids and, in addition
to the processability, end-product softness, flexibility and extensibility (Sen, 2008) of a material,
they deliver a series of other concomitant effects. These include lowering of the glass transition
temperature (Tg) and softening temperature, reduction of strength, and increased impact resistance.
A plasticiser acts by lowering the intermolecular forces between the polymer chains and should be
compatible with the polymer or exudation will occur (Sen, 2008).
1.2. Summary of Issues Considered When Determining the Approach to the AoA
The key factors considered by the applicant, when determining how to assess substance function
and, hence, the overall feasibility and suitability of potential alternatives are summarised below.
Importantly, for an alternative to be suitable it must be technically and economically
feasible from the applicant’s (DEZA, a.s. and downstream users perspective). In terms
of technical feasibility, it must be technically possible for the applicant to manufacture
the alternative taking into account their existing plant or the potential for investment in
new plant, taking into account any constraints on moving to a new technology as a result
of patent restrictions or the availability of the precursor raw materials in sufficient
quantities. In addition, manufacture of the alternative must be economically feasible for
the applicant (especially for downstream users), taking into account requirements for
returns on new investments and the size of the downstream market for an alternative
plasticiser.
ANALYSIS OF ALTERNATIVES
3
The size of the downstream market will be determined by the technical and economic
feasibility of alternatives for downstream users. These aspects therefore must be
considered from the perspective of the applicant’s supply chain, as well as in terms of
more general considerations.
In terms of assessing the substance’s function, the technical requirements for the use of
an alternative plasticiser in an industrial setting have been combined with the
performance requirements of the substance. This increases the complexity of the
technical criteria each alternative must meet before it is considered a feasible alternative.
The scope of what a company further down the supply chain are limited a potentially
feasible alternative considered as technically or economically feasible from the
perspective of the applicant as well.
2. ANALYSIS OF SUBSTANCE FUNCTION
2.1. Background of the use of DBP in the manufacture of ceramic sheets and printing pastes
Plasticizers containing phthalates, such as DBP, are commonly used in small amounts (≤ 6%) for
the fabrication of ceramic components. This plasticizer is used to make ceramic sheets and printing
pastes from which the ceramic sensor elements for lambda sensor elements are produced. With
DBP it is possible to produce tapes which are more flexible, allowing it to be handled in
manufacturing operations with less mechanical damage. After the ceramic article is fabricated, it
undergoes a lengthy high temperature firing process (>1200°C) that eliminates all the organic
materials including the plasticizer. Because of the temperatures required to eliminate the organics,
phthalate is thermally decomposed, so no phthalate compound is discharged to the atmosphere.
Likewise, the final ceramic product after firing contains no phthalate.
The final products - ceramic sheets and printing pastes are used also for the manufacturing of
capacitors.
Capacitors are devices that store energy in the form of an electric field. They can also be used to
filter signals of different frequencies. The capacitance value is an indicator of how much electrical
charge the capacitor can hold.
This trend is attributed to the fact that large-scale high density multilayer ceramic capacitors relies
on the performance of ceramic types and high reliable multilayer ceramic capacitors are easily
realized using ceramic sheets and printing pastes. Conductive layers of multilayer ceramic
substrates are made by printing and connected through fine through holes. Chip capacitors made by
laminating green sheets need fine printing technique. The firing shrinkage of ceramic sheets
depends not only on the characteristics of ceramic powder but rather on the void generated in the
green sheets in the manufacturing process. When insufficient mixing causes non-uniform
distribution of ceramic powder, many voids are created because the ceramic powder in green sheets
remains as an agglomerated particle. These voids lower the density of green sheets and increase the
firing shrinkage, resulting in less dimensional reproducibility. Therefore, in order to obtain high
precision ceramics, it is important, other than quality of ceramic materials and powder
characteristics, to use green sheets to uniform mixture of ceramic powder, binder and solvent,
having little void in it. Using this technique, agglomerated particles can be pulverized to primary
particles without mechanical destruction. This technique is available to manufacture good quality
ceramic sheets with little pore (Ueyama at all, 1986).
ANALYSIS OF ALTERNATIVES
4
2.2. Descriptions of the use of DBP
Current use of DBP is in the manufacture of ceramic sheets and printing pastes for production of
capacitors and lambda sensor elements. The principle of manufacture by downstream user is
described in confidential annex.
Additional confidential information is presented in: Confidential Annex AoA Use3, Section 2: 2.1,
pages 1 - 3.
According to literature research is described the principle of manufacture in non-confidential part of
AoA, mentioned below.
Figure 1: Description of production ceramic chip capacitors-part 1 (Johanson Dielectrics)
Figure 2 Description of production ceramic chip capacitors-part 2 (Johanson Dielectrics)
ANALYSIS OF ALTERNATIVES
5
According to literature research were also published another types of this manufacture, see figure
below.
Figure 3: Description of production ceramic chip capacitors (Lee, 2008)
Frequently ceramic multilayer capacitor materials are based upon BaTiO3. Many titanates have the
perovskite structure. Titanates show a phase transformation at the temperature about 125°C. Above
this temperature the material is cubic and paraelectric. Below this temperature the material is
tetragonal and ferroelectric. In almost all cases substitutions are made to control the Curie
temperature. Also additives are used which modify the dielectric and electric behaviour. The
dielectric permittivity versus temperature is highly dependent on the microstructure, that is, main
composition, second phases and grain size (distribution) of the material. It is probably superfluous
to state that these materials have been largely optimized with respect to their functional behaviour
without considering their structural behaviour. Finally, it is important to note that the tetragonal and
cubic phases have different thermo-physical properties, e.g. thermal expansion coefficient, specific
volume and elastic constants (With, 1993).
One of the most critical material processing parameters is the degree of homogeneous mixing of
additives in the slurry. The binder distribution in the ceramic sheet is investigated to produce high
density, defect free layers. The degree of surface roughness is becoming a more serious problem
with thinner dielectric sheets. The roughness of 5 µm thick sheets must be controlled to less than
0.5 µm to provide a smooth contact surface with the inner nickel electrodes. This is very important
ANALYSIS OF ALTERNATIVES
6
factor in avoiding the concentration of electric field at asperities, where the charge emission from
the electrode is accelerated, resulting in short failure. For the same reason, the nickel metal powder
for the electrode paste must also be very fine, typically less than 0.5 µm and well dispersed in the
paste (Sakabe, 1997).
Figure 4: The principle of ceramic slurry preparing
The process of making ceramic capacitors involves following steps (Lee at all, 2006; Johanson
Dielectrics, 2013)
Manufacture of Dielectric Paste
Ceramic powder is mixed with binder and solvents to create the slurry; this makes it easy to process
the material.
Barium titanate and other metal oxides are dispersed into a toluene/ethanol solvent blend and mixed
thoroughly (step1) to produce low viscosity slurry. In step 2, high molecular weight binders are
added to increase the viscosity of the slurry and approximately 5-6% by weight, of DBP is added to
add plasticity. DBP has the correct properties to:
a) Dissolve effectively into the slurry mixture and
b) Provide the correct level of plasticity to allow further processing.
Sheet Formation
The slurry is poured onto conveyor belt inside a drying oven, resulting in the dry ceramic tape. This
is then cut into square pieces called sheets. The thickness of the sheet determines the voltagerating
of the capacitor.
Figure 5: Manufacture dielectric paste and sheet formation (TDK, 2008)
ANALYSIS OF ALTERNATIVES
7
Internal Electrode Printing
The electrode ink is made from a metal powder that is mixed with solvents and ceramic material to
make the electrode ink. The electrodes are now printed onto the ceramic sheets using a screen
printing process. This is similar to a t-shirt printing process. After that the sheets are stacked to
create a multilayer structure.
Sheet Layering and Pressing
Pressure is applied to the stack to fuse all the separate layers, this created a monolithic structure.
This is called a bar.
Figure 6: Electrode printing and sheet layering (TDK, 2008)
Cutting Multilayer Sheets and Chip Formation
The bar is cut into all the separate capacitors. The parts are now in what is called a ‘green’ state.
The smaller the size, the more parts there are in a bar.
Sintering
The parts are fired in kilns with slow moving conveyor belts. The temperature profile is very
important to the characteristics of the capacitors.
ANALYSIS OF ALTERNATIVES
8
Figure 7: Cutting and sintering
Application of Terminal Electrode Paste, Baking and Plating
The termination provides the first layer of electrical and mechanical connection to the capacitor.
Metal powder is mixed with solvents and glass frit to create the termination ink. Each terminal of
the capacitor is then dipped in the ink and the parts are fired in kilns. Using an electroplating
process, the termination is plated with a layer of nickel and then a layer of tin. The nickel is a
barrier layer between the termination and the tin plating. The tin is used to prevent the nickel from
oxidizing.
Inspection and Packaging
The parts are tested and sorted to their correct capacitance tolerances. At this point the capacitor
manufacturing is complete. The parts could be packaged on tape and reel after this process or
shipped as bulk.
Figure 8: Application of terminal electrode, inspection and packaging (TDK, 2008)
The structure of final ceramic capacitor is viewed below:
Figure 9: The structure of ceramic capacitor (With, 1993; He, 2004)
After the ceramic article is fabricated, it undergoes a lengthy high temperature firing process that
eliminates all the organic materials including plasticizer. Because of the temperatures required to
ANALYSIS OF ALTERNATIVES
9
eliminate the organics, any phthalate is thermally decomposed, so no phthalate compounds are
discharged to the atmosphere. Likewise, the final ceramic product after firing contains no DBP.
Off-gases from the clean-rooms where the phthalates are handled during manufacturing are cooled,
and the organics are separated from the air.
Gases from production equipment - ovens, dryers, etc. are burned in the incinerator.
The use of ceramic capacitors is very large, especially in automotive industry.
One of the most uses is in manufacture of oxygen sensors. An oxygen sensor (or lambda sensor) is
an electronic device that measures the proportion of oxygen (O2) in the gas or liquid being
analyzed. The original sensing element is made with a thimble-shaped zirconia ceramic coated on
both the exhaust and reference sides with a thin layer of platinum and comes in both heated and
unheated forms.
The planar-style sensor entered the market in 1998 (pioneered by Bosch) and significantly reduced
the mass of the ceramic sensing element as well as incorporating the heater within the ceramic
structure. This resulted in a sensor that started sooner and responded faster. The most common
application is to measure the exhaust gas concentration of oxygen for internal combustion engines
in automobiles and other vehicles.
It is necessary to mention that TechNavio's analysts forecast the Global Multilayer Ceramic
Capacitor market 2011-2015 to grow at a CAGR (Compounded Annual Growth Rate) of 17.23
percent over the period 2011-2015. One of the key factors contributing to this market growth is the
increasing demand for MLCCs in smartphones. The availability of cost-effective MLCCs is also
contributing to the growth of the Global Multilayer Ceramic Capacitor market.
2.3. Conditions of DBP use
The following table summarises the role of DBP in the manufacture of ceramic types and provides
an overview of how the substance has to be used in the manufacture of ceramic types.
ANALYSIS OF ALTERNATIVES
10
Table 1. Parameters for DBP use in the manufacture of ceramic types
Task(s)
performed
by the
substance
Plasticizer to make an intermediate ceramic slurry
Physical
form of
product
Liquid
Concentratio
n of
substance in
the product
DBP is used as a processing aid and is not detectable routine manufacturing quality control
methods in the final product
Critical
properties
and quality
criteria it
must fulfil
Key properties of DBP include:
1. Boiling point
2. Solubility in organic solvents
3. Vapour pressure at the temperatures used
4. Thermal stability
The most important effect is the behaviour of the tapes and pastes in the process. The diluents
influence the green and sinter density of the tapes. In the same way, the type and amount of
porosity is influenced. The diluents system must be the same in pastes and tapes and
influences the behaviour of the tapes, the printing shrinkage during the several printing steps
(up to 30). Too much porosity leads to less mechanical stability à insufficient life time. To
much more to less sinter shrinkage leads to bad functional values.
Function
conditions
(frequency of
use and
quantity
used)
Continuous use; Exposure Scenario covers daily exposures up to 8 hours per shift; operation
365/days/y
Consumption of DBP is variable, depending on the slurry output of the plant. Design
conditions allow for a consumption of < 6% (maximal use of DBP < 20 tonne/year)
Process and
performance
constraints
Temperature at which the lean solvent is introduced into the absorption step is below 75°C,
ideally 30-40 °C, to minimize overhead losses of the solvent
Conditions
under which
the use of the
substance
could be
eliminated
Use of DBP could only be eliminated if a suitable substitute could be used or the plant using
DBP converted to an alternative ceramic type manufacturing technology. The functionality of
DBP cannot be eliminated, the ceramic type manufacturing needs to have plasticizer of this
property. The only known potential alternative substances which currently find commercial
application are not suitable. Currently available alternative technologies are considered far
inferior in technical, commercial, economic and environmental impact terms.
Customer
requirements
associated
with the use
of the
substance
DBP user: for the user of DBP, the critical properties referred to above apply.
Ceramic type user: DBP is not incorporated into sintered ceramic type and is not detectable
according to routine manufacturing quality control testing. Thus the use of DBP in the
manufacture of ceramic type is of no consequence to downstream users.
Industry
sector and
legal
requirements
for technical
acceptability
that must be
met and
function
must deliver
Downstream industry is largely oblivious to use of DBP as it is generally absent from the
final product and does not affect its performance.
ANALYSIS OF ALTERNATIVES
11
2.3.1. Technical requirements for DBP and alternative substances
The technical requirements are described in confidential annex.
Additional confidential information is presented in: Confidential Annex AoA Use 3, Section 2: 2.2,
page 4.
3. IDENTIFICATION OF POSSIBLE ALTERNATIVES
3.1. Description of efforts made to identify possible alternatives
3.1.1. Research and development
Activities of downstream users of DBP
As downstream users formulate their products for a particular function and thus choose an
appropriate plasticiser to achieve that effect, they are not tied to a particular substance unless it is
the only one that is suitable in terms of its customers’ requirements and/or provides qualities that
other substances do not.
There is, therefore, an incentive for flexible slurry compounders to trial alternative substances in
order to leverage potential improvements in product properties or savings in processing or purchase
price. Developing more cost-effective compounds for their customers should provide a relative
market advantage. Downstream users therefore are not allied to a particular substance and hence
manufacturer (the applicants in this case).
It is clear from the responses to the consultation carried out to support this application that most
companies that carry out formulating and compounding activities have tried and tested a range of
plasticisers. It is also clear that those companies that produce ceramic sheets and printing pastes
have also tested alternatives to DBP. As a result, these downstream users have a good
understanding of whether the alternatives that they have tested (and perhaps others that they have
researched) are capable of delivering the properties that they or their customers require.
In the past was processed a development of change DBP for alternative substance, which could be
technically suitable, more information in confidential annex.
Additional confidential information is presented in: Confidential Annex AoA Use 3, Section 3:
3.1.1.1, pages 4 - 5.
In recent months one of DBP downstream users has indicated an alternative material, which is
compatible with their solvent, more information in confidential annex. The alternative material was
not yet tested in real production, so it is unknown whether it could replace DBP in short period.
Additional confidential information is presented in: Confidential Annex AoA Use 3, Section 3:
3.1.1.2, pages 5 - 6.
3.1.2. Data searches
A literature review by compiler was undertaken for potential alternatives. The open literature has
been searched for information on both potential alternative substances of manufacture of ceramic
ANALYSIS OF ALTERNATIVES
12
types using keywords as “ceramic types”, “ceramic green sheet” and “ceramic chip capacitors”.
Once some information had been collected, the data searches were expanded to include additional
relevant keywords.
Information was sought on:
the identities of potential alternative substances (including acronyms, EC numbers and CAS
numbers for substances, where available);
information on technical parameters of alternative technologies, in particular information
from those licensing or using the available technologies; and
information on the technical feasibility, economic feasibility and human health and
environmental impacts profile of alternative substances and technologies.
The table below provides the main sources of information used, although as new leads were being
found a much larger number of individual Internet sites were visited when looking for information.
Table 2. Key information sources used in the identification of potential alternatives
Source Details Description
Google https://www.google.com Search engine
Science direct http://www.sciencedirect.com Scientific articles
Google Books http://www.google.com/advanced_book_search Books
With regards to the characteristics and properties of potential alternative substances, a range of
specialist websites have been systematically consulted. The following Table gives an overview of
some of the most important information sources that were used in the preparation of this analysis of
alternatives.
Table 3. Key information sources used in the collection of information on the properties of potential alternatives
Source Details Description
Google https://www.google.com Search engine
Scirus http://www.scirus.com Scientific search
engine
Science direct http://www.sciencedirect.com Scientific articles
ESIS http://esis.jrc.ec.europa.eu Chemical substance
inventory
ChemIDPlus http://chem.sis.nlm.nih.gov/chemidplus Chemical substance
inventory
US EPA Substance
Registry Services
http://semanticommunity.info/EPA/EPA_Substance_Registry_System Chemical substance
inventory
TOXNET http://toxnet.nlm.nih.gov Human health and
environmental data
ChemSpider http://www.chemspider.com Properties of
chemical substances
ChemNet http://www.chemnet.com Properties of
chemical substances
Chemical Book http://www.chemicalbook.com Properties of
chemical substances
TRC http://www.trc-canada.com/index.php Properties of
chemical substances
NIOSH http://www.cdc.gov/NIOSH Properties of
chemical substances
ECHA http://echa.europa.eu/web/guest/information-on-chemicals/registered-
substances
Properties of
chemical substances
Pubchem http://pubchem.ncbi.nlm.nih.gov Properties of
chemical substances
Sigma-aldrich http://www.sigmaaldrich.com Properties of
chemical substances
ANALYSIS OF ALTERNATIVES
13
The core of the literature research was undertaken in the period May 2013 – June 2013.
3.1.3. Consultations
Consultation with the manufacturer of DBP
DEZA was asked to indicate whether it manufacturers any of the identified potential alternatives
that are either commercially proven or at the research and development stage. The company has
provided information on:
whether it manufactures any of the substances identified;
whether specific plans exist to start the manufacture of any substance;
if DEZA was theoretically able to start the manufacture of any substance, what tonnage
could potentially be placed on the market; and
if DEZA was unable to manufacture any substance, what were the key reasons and
difficulties behind this.
A questionnaire was prepared and submitted to DEZA in 2.5.2013 aimed at collecting the
information described above.
Consultation with current user of DBP
Consultation had been undertaken with - in confidential annex.
Additional confidential information is presented in: Confidential Annex AoA Use 3, Section 3:
3.1.2, page 7.
Written questionnaires: a questionnaire was originally used for the collection of information. This
was prepared by compiler and submitted to users in 2.5.2013. The aim of the questionnaire was to
collect information on:
the use of DBP in the manufacture of ceramic types and the downstream applications;
the importance of DBP in this use;
the most important disadvantageous characteristics of DBP;
the most important advantageous characteristics of DBP;
the alternative substance(s) possible for substitute;
the technical suitability and economic feasibility of alternative substances.
Responses started being submitted 3.6.2013 and several additional questions were subsequently
added as the questionnaire evolved into a living document that facilitated the exchange of
information between compiler and companies (mentioned above).
Face-to-face meetings: several meetings were held with DEZA in preparation of this work on the
Application for Authorisation.
Email corresponding: when necessary, email conversations were held.
3.2. List of potential alternatives
The table presents alternative substances which are commonly referred to in the literature but are
only a few out of the thousands of potential alternatives investigates by current users. Although this
cannot be considered to be a shortlist of the best or most suitable potential alternatives, it provides a
useful overview of the families of substances that might be considered as possible for the selection
of suitable alternatives, i.e. phthalates, adipates.
ANALYSIS OF ALTERNATIVES
14
Table 4. Identities and REACH registration status of alternative substances
Alternative substance CAS No. EC No. REACH registered
2,2,4-trimethyl 1,3-pentanediol diisobutyrate 6846-50-0 229-934-9 Yes
Acetyl tributyl citrate 77-90-7 201-067-0 Yes
Alkylsulphonic phenylester 91082-17-6 293728-5 Yes
Butylated hydroxytoluene 128-37-0 204-881-4 Yes
Di - isobutyl phthalate 84-69-5 201-553-2 Yes
Di – isononyl adipate 33703-08-1 251-646-7 Yes
Di - isononyl phthalate 28553-12-0 249-079-5 Yes
Di (isononyl) cyclohexan 1,2-dicarboxylate 166412-78-8 431-890-2 Yes
Di(2-ethyl hexyl) adipate 103-23-1 203-090-1 Yes
Di(2-ethylhexyl) phosphate 298-07-7 206-056-4 Yes
Di-butyl adipate 105-99-7 203-350-4 Yes
Di-butyl sebacate 109-43-3 203-672-5 Yes
Diethylene benzyl benzoate 120-55-8 204-407-6 Yes
Diisobutyl adipate 141-04-8 205-450-3 No
Dioctyl adipate 123-79-5 204-652-9 No
Dioctyl sebacate 122-62-3 204-558-8 Yes
Dioctyl terephthalate 6422-86-2 229-176-9 Yes
Dipropylene Glycol Dibenzoate 27138-31-4 248-258-5 Yes
Epoxidized soybean oil 8013-07-8 232-391-0 Yes
Glycerides, Castor-oil-mono-, hydrogenated, acetates 736150-63-3 451-530-8 Yes
Glyceryl triacetate 102-76-1 203-051-9 Yes
O-toluene sulfonamide 88-19-7 201-808-8 Yes
Tri(2-ethylhexyl) phosphate 78-42-2 201-116-6 Yes
Tri-2-ethylhexyl trimellitate 3319-31-1 222-020-0 Yes
For each of the selected potential alternatives listed in Table below boiling point, flash point values
and solubility are presented. On the other hand, for solubility in slurry, a relative value in
comparison to DBP is generally given. The data in the Table have largely been provided by
literature research.
The following points must be noted:
values given in red colour indicate that the selected potential alternative substance does not
meet the relevant technical performance criterion;
for vapour pressure, for which a specific threshold has not been set, only values that are well
above the vapour pressure of DBP are marked in red colour;
the Table also contains (on the ride side) commentary on specific shortcomings of the
selected substances.
The Table clearly demonstrates that each of the selected solvents under investigation fail one or
more of the technical criteria established for DBP and therefore cannot be considered technically
feasible and, hence, realistic alternatives, at least at the present time.
ANALYSIS OF ALTERNATIVES
15
Table 5. Comparison of selected potential alternative substances against key technical comparison criteria
Solvent
name
CAS
No EC No
Boiling
point
(°C)
Vapour
pressure
(kPa)
Flash
point
(°C)
Solubility
in organic
solvents
Comments
Dibutyl
phthalate
84-74-2 201-
557-4 340
9.7 * 10-6
at 20°C 191 Yes
Optimal combination of
properties from physical-
chemical perspective
Dibutyl
sebacate
109-43-
3
203-
672-5 344.5
4.69 * 10-6
at 25°C 178 Yes
Not optimal only within flash
point.
Di(2-
ethylhexyl)
adipate
103-23-
1
203-
090-1 417 3*10
-7 196 Yes
Optimal only within solubility
and flash point.
Diisononyl
phthalate
28553-
12-0
249-
079-5 341 6 * 10
-5 236 Yes
Optimal only within boiling
point and solubility.
DINCH
166412
-78-8
431-
890-2 397 2.2*10
-7 224 Yes
Optimal only within
solubility.
Di-isobutyl
adipate
141-04-
8
205-
450-3 280 0.00563 ?? Yes Optimal only within solubility
DOTP
6422-
86-2
229-
176-9 375 <0.001 212 Yes Optimal only within solubility
Di-butyl
adipate
105-99-
7
203-
350-4 183 0.021 113 Yes Optimal only within solubility
Dibutyl phthalate: CSR
Dibutyl sebacate: HSDB: http://toxnet.nlm.nih.gov/cgi-bin/sis/search/f?./temp/~Wxy7yi:1
Chemspider.com
http://www.chemicalbook.com/ChemicalProductProperty_EN_CB8737502.htm
Di(2-ethylhexyl) adipate: ECHA Dissemination Portal
http://apps.echa.europa.eu/registered/data/dossiers/DISS-a134506c-6383-58e2-e044-00144f67d031/DISS-
a134506c-6383-58e2-e044-00144f67d031_DISS-a134506c-6383-58e2-e044-00144f67d031.html
Ministry of Economy, Trade and Industry http://www.meti.go.jp/english/report/downloadfiles/gED0311e.pdf
Diisononyl phthalate: ECHA Dissemination Portal
http://apps.echa.europa.eu/registered/data/dossiers/DISS-828e025b-9dd6-1b22-e044-00144fd73934/AGGR-
cb83eb9f-a441-4d41-9102-00d52b67b510_DISS-828e025b-9dd6-1b22-e044-00144fd73934.html#AGGR-cb83eb9f-
a441-4d41-9102-00d52b67b510
Australian Government Internet site:
http://www.nicnas.gov.au/Consultations/Draft%20PEC%20Assessment%20Report_DINP.pdf
Di-butyl adipate: NIOSH http://www.cdc.gov/niosh/ipcsneng/neng1705.html
IUCLID http://esis.jrc.ec.europa.eu/doc/IUCLID/data_sheets/105997.pdf
NIOSH http://www.cdc.gov/niosh/ipcsneng/neng1705.html
IUCLID http://esis.jrc.ec.europa.eu/doc/IUCLID/data_sheets/105997.pdf
National Centre for Biotechnology Information http://www.ncbi.nlm.nih.gov/pubmed/16835133
ANALYSIS OF ALTERNATIVES
16
4. SUITABILITY AND AVAILABILITY OF POSSIBLE ALTERNATIVES
The use of DBP is this case is unique, so no potential alternative can be disclosed to the public. The
number of companies producing the same or similar articles worldwide is very low, so even
disclosure of the name of alternative can harm downstream users of Applicant and could break the
position of these companies on the market
4.1. ALTERNATIVE 1
Alternative 1 is described in confidential annex.
Additional confidential information is presented in: Confidential Annex AoA Use 3, Section 4.1:
4.1.1 – 4.1.6, pages 8 – 15.
4.2. ALTERNATIVE 2
Alternative 2 is described in confidential annex.
Additional confidential information is presented in: Confidential Annex AoA Use 3, Section 4.2:
4.2.1 – 4.2.6, pages 15 - 18.
4.3. ALTERNATIVE 3
Alternative 3 is described in confidential annex.
Additional confidential information is presented in: Confidential Annex AoA Use 3, Section 4.3:
4.3.1 – 4.3.6, pages 19 – 21.
4.4. ALTERNATIVE 4
Alternative 4 is described in confidential annex.
Additional confidential information is presented in: Confidential Annex AoA Use 3, Section 4.4:
4.4.1 – 4.4.6, pages 22 – 24.
4.5. ALTERNATIVE 5
Alternative 5 is described in confidential annex.
Additional confidential information is presented in: Confidential Annex AoA Use 3, Section 4.5:
ANALYSIS OF ALTERNATIVES
17
4.5.1 – 4.5.6, pages 25 - 27.
4.6. ALTERNATIVE 6
Alternative 6 is described in confidential annex.
Additional confidential information is presented in: Confidential Annex AoA Use 3, Section 4.6:
4.6.1 – 4.6.6, pages 28 – 31.
Overview table of desired properties for potential alternatives
Desired property Range, figure Comment
Physical state, melting point,
boiling point
Liquid, working temperature:
-35°C to 200°C
Handling and transport in winter
in country of origin, transit and
target destination for low limit
Process operation for high limit
Density (at 20°C) 0,98 – 1,1 g/cm3 Handling, pumping, analysis
Vapour pressure (20°C) Lower than 10e-5 kPa Safety requirement
Flash point >180°C Safety requirement
Affinity to metallic oxide powders
and precious metal powders
Process requirement
Solubility in organo metallic
substances
Process requirement
Water solubility 10,7 – 12,1 mg/L Needed for processing of the
mixture
Long-term stability at 20°C More than 6 months Needed for storage, handling
Note: all properties should be met for one potential alternative
5. OVERALL CONCLUSIONS ON SUITABILITY AND AVAILABILITY OF POSSIBLE
ALTERNATIVES FOR USE 3
Six commercially proven alternatives have been considered in this analysis: the alternative
substances.
ANALYSIS OF ALTERNATIVES
18
5.1. Conclusion on the technical feasibility of commercially proven alternatives
Six commercially proven alternatives cannot be considered technically feasible for downstream
users, some of them also not for applicant. In terms of technical feasibility for the downstream user
they are not useful because of deficiency in the process. The deficiencies are described in
confidential annex.
Additional confidential information is presented in: Confidential Annex AoA Use 3, Section 5: 5.1,
page 32.
Technically, neither of eight alternatives can match the performance of DBP-based ceramic sheet
and the need for prolonged, complex and costly plant modifications render these alternatives
technically unfeasible and unrealistic for the applicant and the downstream user, particularly given
that the CSR has demonstrated that risks to workers health are adequately controlled.
5.2. Conclusion on the economic feasibility of commercially proven alternatives
Six commercially proven alternatives are not available to the downstream users of DBP (the
manufactured of ceramic sheets and printing pastes) from the perspective of technical feasibility.
The refused authorisation would have impacts for downstream users in loss of production, loss of
annual turnover etc.
From the perspective of the downstream user, the economic impact of loss DBP in production is
summarised in confidential annex.
Additional confidential information is presented in: Confidential Annex AoA Use 3, Section 5: 5.2,
pages 32 - 33.
The estimated annualised costs represent a very substantial proportion of the turnover of the
downstream users. Under either alternative, the cost of conversion is prohibitive, thus rendering
these alternatives economically unfeasible and entirely unrealistic, particularly since exposure of
workers to DBP is strictly controlled below the effects threshold.
5.3. Conclusion on risk reduction potential of commercially proven alternatives
In terms of risk reduction, it is important to consider the key premise of this Application for
Authorization: exposure of workers at the DEZA and downstream user’s plant is kept well below
the effect threshold. Adequate control of risk is demonstrated in the CSR, thus there is no
unacceptable risk for the endpoint of concern (reproductive toxicity). Therefore, the replacement of
DBP by an alternative substance would not confer any discernible benefit to workers health.
The information on alternative substances was taken from REACH registration dossiers. These
substances are not dangerous for human health and environment. The externalities of the release
because of using alternative substances were not established.
5.4. Overall conclusion
It is clear that DEZA and downstream users of DBP for the manufacture of ceramic sheets and
printing pastes for production of capacitors and lambda sensor elements would have very little
incentive to switch to either of the two commercially proven alternatives. These alternatives:
would not confer any discernible benefit to workers health as the risks from exposure to
DBP are adequately controlled as demonstrated in CSR;
ANALYSIS OF ALTERNATIVES
19
can be detrimental to the quality of ceramic sheets product;
would require plant conversions which modification of the plant, would require very long
downtime of 48 months. It is estimated that additional 24 months would be required for
obtaining agreement of the company owners/ shareholders, drawing up of engineering plans,
cost estimation and raising capital and another 24 months to get EIA, certification of the
product etc.;
would be accompanied by much poorer economics that would make the manufacture of
ceramic types unprofitable.
In general terms, alternative substances cannot be considered to be available. Some of them could
not be produced by the Applicant. From the downstream user’s perspective, alternative substances
are unlikely to be available at the required tonnage.
The availability of commercially unproven alternatives has not been examined in detail. DEZA was
asked about its ability to manufacture and supply any of the theoretical alternative substances that
have been identified in the open literature. In general terms, DEZA manufacturers some phthalates
and adipates but has no knowledge or expertise in the manufacture of potential alternatives that
belong to other group of substances. Downstream users are not currently involved in the
manufacture or import of any of the identified potential alternative substances. It is expected that
availability will vary amongst the substances.
Making the commercially proven alternatives suitable is considered impossible with the current
level of knowledge. Indeed, it is considered unwise to invest time, effort and funds in attempting to
make the alternative. Any effort concentrated on them would be a backward step towards inefficient
processes with worse economics, which the applicant and the downstream users would not consider.
It is more realistic and practical to focus instead on the development of a suitable new alternative,
which even if commercially unproven at present, it can be properly researched and adapted to the
downstream technology of manufacture of ceramic types.
Downstream user is committed continuing its research and development work with the aim of
identifying and developing technical suitable and economically feasible alternatives which can be
obtained from the market in sufficient quantities.
ANALYSIS OF ALTERNATIVES
20
APPENDIXES
Annex 1: List of data sources
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ANALYSIS OF ALTERNATIVES
21
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ANALYSIS OF ALTERNATIVES
22
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24
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dioic%20Acid%201,10-
Dibutyl%20Ester;%20Decanedioic%20Acid%20Dibutyl%20Ester;%20Sebacic%20Acid%2
0Dibutyl%20Ester;%20Bis%28n-butyl%29%20Sebacate;%20DBS;%20Di-n-
Butyl%20Sebacate;%20Dibutyl%20Decanedioate;%20Ergoplast%20SDB;%20Kodaflex%2
0DBS;%20NSC%203893;%20PX%20404;%20Polycizer%20DBS;%20Reomol%20DBS;%
20Sebacic%20Acid%20Di-n-butyl%20Ester;%20Staflex%20DBS;%20Uniflex%20DBS
ANALYSIS OF ALTERNATIVES
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