CLASSIFICATION AND LABELLING, LEGAL STATUS

Hazard statements (CLP)

H228, H301, H315, H317, H319, H330, H335, H350i, H372, H400

Code

Statements

H228

Flammable solid

Environmental hazards

21 Beryllium and Functions of Be Examples on the Examples of the Concentration its component level EEE-relevant estimated compounds Applications strength, • EMC EEE devices, that 30 http://www.ngk-alloys.com/NGK_Berylco_Design_Guide_En.pdf; http://beryllium.eu/wp- content/uploads/2016/07/Beryllium-Production-and-Outlook-Roskill-Mineral-Sevices.pdf 32 https://www.ajato.com.tw/product/spring-contact/

Contains

electromag- (Electromagnetic need to be sealed typically netic shielding compatibility) against EMI (and 1.6%-2% Be gaskets31 dust), depending on 30 their design • High • SMD (Surface • Antenna contacts • High conductivity mounted devices) (used in the conductivity contact springs; smartphone)32 alloys • Golden Brick • Battery contacts containing contact and electric clamps, 0.2%-0.6% • Wire clampers for used in almost all Be PCB EEE devices, such • Grounding contact as washing machines, clothes • Conductive dryers, dish connectors, used washers, to make contacts microwaves, air and connectors, con-ditioners, relays, switches printed circuits and shielding boards, televisions, computers, etc.33 Beryllium-nickel • high strength • mechanically and • “Test & Burn-in”34 • Commoditi- alloys and high thermally highly sockets for stress sed NiBe temperature stressed springs, testing electronic alloys stability contacts, and devices (i.e. chips); contain Be connectors. • high temperature in the range commercial lighting of 2 wt%. fixtures (e.g. e.g. “Alloy halogen lamps)35 360” 1.85%- 2.05% Be in weight36 31 https://www.evaluationengineering.com/home/article/13014317/emc-gaskets-sealing-against-emi-and-the-

Remarks

References ppm mg/m³ ppm mg/m³ Austria 0.002 0.008 TRK AT GKV (2011) Belgium 0.002 0.01 8 hrs TGG (TWA) BE KB (2014) Denmark 0.001 DK BEK (2011) Germany BGV (BAR): 0.05 μg/l Drexler and Hartwig (2012) (DFG) beryllium/L urine Finland 0.0001 0.0004 STEL = 15 min. average FI MSAH (2012) France 0.002 VME = TWA 8 hrs FR INRS (2012) (INRS) France 0.00001 Skin notation FR ANSES (2010) (ANSES Ireland 0.0002 IE HSA (2011) Sweden 0.002 Total dust SE SWEA (2015) UK 0.002 TWA GB HSE (2011) 72 BeST (2019): Contribution submitted on 7 November 2019 during the stakeholder consultation conducted from 26 September 2019 until 07 November 2019 in the course of the study to support the review of the list of restricted substances and to assess a new exemption request under RoHS 2 (Pack 15) 31 • BAR [Biologischer Arbeitsstoff Referenzwert] = biological reference value • TWA = Time-Weighted Average (usually 8 hours average). • STEL = Short Term Exposure Limit (usually 15 minutes average). • TGG [TijdGewogen Gemiddelde] = TWA. • TRK [Technische RichtKonzentration] = indicative concentration. • REL = Recommended Exposure Limit (NIOSH) • TWAEV = Time-Weighted Average Exposure Value = TWA • PEL = Permissible Exposure Level (OSHA) • VME [Valeur Moyenne d’Exposition] = TWA. Source: Scientific Committee on Occupational Exposure Limits SCOEL (2017); COM (2018) 171 final73 Table 3-2: Overview of existing OELs for beryllium and beryllium compounds in non- EU countries (expressed as Be) EU TWA (8hrs) STEL (15min) References ppm mg/m³ ppm mg/m³ Australia 0.002 TWAEV AU SWA (2011) CA (Ontario) 0.002 0.01 TWA CA OML (2013) CA (Québec) 0.002 Canada (2016) Japan 0.002 JA JSOH (2015) New Zealand 0.002 NZ HS (2013) Norway 0.001 NO NLIA (2011) Switzerland 0.002 inhalable aerosol CH SUVA (2015) USA (OSHA) 0.002 0.005 PEL US OSHA (2006) USA (NIOSH) 0.0005 REL US NIOSH (2016) USA (ACGIH) 0.00005 TLV-TWA US ACGIH (2012) Source: Scientific Committee on Occupational Exposure Limits SCOEL (2017); COM(2018) 171 final In the U.S., OSHA has established a permissible exposure limit (PEL) for beryllium of 0.2 μg/m3 (8- Hr TWA) and 2.0 μg/m3 as the short-term exposure limit, over a 15-minute sampling period.74 Internationally, the beryllium industry has launched the “Be Responsible” voluntary product stewardship programme in March 2017.75 The Recommended Exposure Guideline (REG) endorses an exposure limit of 0.6 µg/m³ (inhalable), measured as an 8-hour time weighted average (TWA). The “Be Responsible” Programme seeks to continuously improve workers safety during the production and processing of beryllium-containing material and is continually evaluating its effectiveness.76 73 Opt. cit. Scientific Committee on Occupational Exposure Limits SCOEL (2017) 74 Occupational Safety and Health Administration (OSHA) (2019): Final Rule to Protect Workers from Beryllium Exposure. https://www.osha.gov/berylliumrule last viewed 2.3.2020 75 www.berylliumsafety.eu, last viewed 2.3.2020 76 BeST (2019): Contribution submitted on 7 November 2019) during the stakeholder consultation conducted from 26 September 2019 until 07 November 2019 in the course of the study to support the review of the list of restricted substances and to assess a new exemption request under RoHS 2 (Pack 15) 32 4 ENVIRONMENTAL HAZARD PROFILE Very few environmental assessments studies for beryllium or beryllium compounds could be found in the body of publicly available literature, nor were such studies mentioned by stakeholders during the consultation. BAUA (2014) did not assess environmental hazards during the CORAP substance evaluation for beryllium. The entries in the ECHA database on registered substances for beryllium and beryllium oxide do not contain eco-toxicological information. Taylor et al (2003) report the results of a review study of beryllium in the environment. The authors state that “Beryllium contamination of soils, surface water, groundwater, and air in close proximity to facilities where beryllium has been manufactured, machined, and tested is not well documented” (neither in the U.S. nor outside the U.S.). Geologic background concentrations of beryllium in water bodies vary depending on the occurrence of geochemically mobilised beryllium minerals. Acidic, organic-rich continental river waters exhibit a higher level of beryllium than ocean water and the beryllium concentration in groundwater tends to be higher than in surface waters. “The beryllium content of ocean waters (104 to 101 mg/l for the Pacific Ocean) is approximately three orders-of-magnitude less than that of river waters” (ibid). In soil, “Natural beryllium concentrations range from a mean of 0.1 mg/kg to 40 mg/kg at locations around the world” (ibid). Coal contains beryllium typically range from 1.46 to 1.52 mg/kg (data for the U.S.). The combustion of coal in power plants contributes to widespread environmental beryllium pollution if emission controls are insufficient. Taylor et al (2003) state that in the U.S. “an estimated 80% of all beryllium emissions in the US originate from coal-fired vessels.” Data on the impacts of beryllium on biota is lacking. However, the substance may have effects on organisms in the aquatic environment. There are a few notifiers that classify beryllium for being hazardous to the aquatic environment (Aquatic Acute 1 - H400, Very toxic to aquatic life). 4.1.1 Endpoints of concern, NOAECs, acute, chronic There are no data available. 4.2 Potential for secondary poisoning and bioaccumulation There are no data available. 4.3 Guidance values (PNECs) There are no data available. 33 5 WASTE MANAGEMENT OF ELECTRICAL AND ELECTRONIC EQUIPMENT 5.1 Description of waste streams Waste electrical and electronic equipment (WEEE) is recycled or disposed of as solid waste. A certain amount of end of life EEE products are likely to be shipped outside the boundaries of the EU as second-hand goods. Between 2015 and 2016, the amount of EEE put on the EU market increased by 2.9% from 9.8 million tonnes to 10.1 million tonnes. The amount of collected WEEE varies across EU Member States. In 2016, eighteen EU Member States achieved or surpassed the 44.9% collection target for WEEE. Large household appliances accounted for 55.6% of the total collected WEEE. IT and telecommunications equipment (14.8%) and consumer equipment and photovoltaic panels (13.5%) are the second and third largest categories for WEEE collection in the EU, accounting for 669 thousand tonnes and 610 thousand tonnes respectively. Small household appliances contributed with 408 thousand tonnes, accounting for 9.0% to WEEE collection. The remaining seven categories together totalled about 325 thousand tonnes, or 7.2% of WEEE collected in the EU in 2016.77 Figure 5-1: Rates of WEEE collected per EU country in 2016 Source: Eurostat (2019) Hence, roughly 40% of the beryllium contained in the WEEE can be expected to enter a WEEE recycling process whereas the remaining 60% are disposed of together with WEEE as part of (municipal) solid waste. An unknown amount of beryllium is probably exported as second-hand EEE to non-EU countries. If disposed of as part of municipal solid waste, treatment in waste incineration plants (MSW) is the most likely disposal channel, whose endpoints are bottom ash and fly ashes from waste gas treatment. Beryllium and BeO that is liberated from WEEE during incineration may end up in both fractions. Some metal alloy parts (e.g. CuBe and NiBe) will likely pass the incineration process and could be recovered from the bottom ash. Fly ashes from MSWs are normally to be 77 Eurostat (2019) https://ec.europa.eu/eurostat/statistics-explained/index.php?title=Waste_statistics_- _electrical_and_electronic_equipment&oldid=445263