Your guide to EU Commission Regulation 2020.878

The European Chemicals Agency (ECHA) recently published and enforced regulation 2020.878. This is an amendment to Annex II concerning REACH (Registration, Evaluation, Authorisation and Restriction of Chemicals) regulations. EU REACH regulations, which have been in place since 2007, have required suppliers and manufacturers of chemical substances to provide Safety Data Sheets.

The amendment to Annex II of REACH came into effect on the 1st of January 2021. This means that all new SDSs, issued from this date, must adhere to the new requirements. The revision is the first time in which dust explosion data will need to be submitted to an SDS under EU law and will require an immediate response from businessess.

This guide will explain everything you need to know about the EU Commission Regulation 2020.878 and how it affects dust and powder explosion legislation. This guide will also look at how this legislation will change the business landscapes for companies in the chemical production and safety industry.

Introduction

The avoidance of ignition sources is one of the most common measures for the protection against dust and powder explosions. Although there is a high probability that dust explosions may potentially occur when combined with the presence of another potentially hazardous chemical, dust explosion hazards are not classified as a characteristic under REACH. Previously, in the Material Safety Data Sheet (Chapter 2.3 of Annex II), dust explosion hazards were simply cited as ‘may form explosible dust-air mixture if dispersed’.

Although the above statement may be considered sufficient, it does not allude to the potential that a dust may have as an explosive hazard. Moreover, it does not consider the associated risks concerning the material. As a result, the first question that should be asked is, is my material a combustible dust?

To answer the above question, ‘combustible dust’ must first be defined. Most materials capable of being oxidised can combust, so most organic materials will be capable of combustion. The propensity for this combustion/oxidation reaction is related to the particle size of the solid particles. The HSE state that ‘a dust explosion involves the rapid combustion of dust particles that releases energy and usually generates gaseous reaction products.’ Generally, powders that have an average particle size distribution below 500 micrometres are usually capable of propagating combustion. However, if a material with an above average particle size distribution contains ‘fines’ that have been created during operations, they can suspend in the air for an extended period of time.

Therefore, distribution, rather than particle size, should be investigated in a risk assessment. Undertaking a range of suitable dust and powder tests are therefore necessary to both determine and confirm combustibility in a work environment.

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