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Exposure controls / personal protection

Documentation of the strictly controlled conditions (SCC) for an on-site intermediate at ZSCHIMMER & SCHWARZ Lahnstein (ZSL)
1. Substance Identification
EC number: 308-020-4
EC name: Phosphoric acid, mono- and di-C12-14-alkyl esters
CAS number: 97808-97-4
Classification & Labeling according CLP regulation:
Skin Corr. 1B
H314
GHS05
Danger
H314
P101
P280
P302+352
P305+351+338
P309+311
2. Risk management measures and technical controls in place to confirm compliance with SCC during processing
2. 1 Manufacturing (synthesis) including reaction, distillation, filtration and drying
The reaction occurs in permanently tightly closed equipment, whose tightness is checked regularly by an external inspection authority. The tightness is furthermore checked at defined time intervals by our own personal. The outcomes of these inspections are documented.
To achieve the necessary gas exchange during the production the gas phase is transferred to an absorption device with an acidic and an alkaline purification step. The effectiveness of this equipment in checked at defined time intervals by an external inspection authority.
To operate the reactor an operating instruction is available.
The personal conduct regularly inspections tours, which are specified in a corresponding operating instruction and whose outcomes are documented.
2.2 Sampling and analysis
The sampling is achieved by means of a separate pipe, which is only dedicated for this purpose. The reactor is not opened for this purpose. The sampling is conducted by means of a dead-man’s safety system. The adjustment operations occur at a man way opening.
Gases or vapours arising during this step are exhausted by the ventilation of the reactor and let to the alkaline absorption device described under point 2.1.
2.3 Unloading / loading
The intermediate is cooled down to 60 °C and filled in IBC containers. The filling of the intermediate in the reactor for further processing occurs by means of vacuum exhaustion.
2.4 Storage
The intermediate is stored in IBC containers in our high bay warehouse.
2.5 Use of intermediate
The reaction occurs in permanently tightly closed equipment, whose tightness is checked regularly by an external inspection authority. The tightness is furthermore checked at defined time intervals by our own personal. The outcomes of these inspections are documented.
To achieve the necessary gas exchange during the production the gas phase is transferred to an absorption device with an acidic and an alkaline purification step. The effectiveness of this equipment in checked at defined time intervals by an external inspection authority. To operate the absorption device a corresponding operating instruction is available.
The personal conduct regularly inspections tours, which are specified in a corresponding operating instruction and whose outcomes are documented.
The filling of the intermediate in the reactor for further processing occurs by means of vacuum exhaustion
3. Procedures and/or control technologies used during cleaning and maintenance operations and in case of accidents
3.1 Equipment used for manufacturing (synthesis) including reaction, distillation, filtration and drying
The equipment is cleaned with warm water and the resulting waste water is released to our own sewage treatment plant.
Prior a maintenance operation a permit is filled in, wherein the measures to be implemented are specified by the operating engineer. The implementation of these measures is documented.
Maintenance operations are conducted exclusively by experts, who are licensed in accordance to the stipulations in article 3 paragraph 2 of the VAwS regulation.
In case of an accidental loss, the loss of containment is accumulated in a tank, where the vapours are purged to the atmosphere.
In case of an accident special operation instructions are available.
3.2 Equipment used for unloading / loading
The equipment is cleaned with warm water and the resulting waste water is released to our own sewage treatment plant.
Prior a maintenance operation a permit is filled in, wherein the measures to be implemented are specified by the operating engineer. The implementation of these measures is documented.
Maintenance operations are conducted exclusively by experts, who are licensed in accordance to the stipulations in article 3 paragraph 2 of the VAwS regulation.
In case of an accident special operation instructions are available.
In case of an accidental loss, the loss of containment is accumulated in a tank, where the vapours are purged to the atmosphere.
3.3 Equipment used for storage
The equipment is cleaned with warm water and the resulting waste water is released to our own sewage treatment plant.
Maintenance operations are conducted exclusively by experts, who are licensed in accordance to the stipulations in article 3 paragraph 2 of the VAwS regulation.
In case of a leakage during storage the loss of containment is collected in a catching device.
In case of an accident special operation instructions are available.
3.4 Equipment used for the use (consumption) of the intermediate
The equipment is cleaned with warm water and the resulting waste water is released to our own sewage treatment plant.
Maintenance operations are conducted exclusively by experts, who are licensed in accordance to the stipulations in article 3 paragraph 2 of the VAwS regulation.
In case of an accidental loss, the loss of containment is accumulated in a tank, where the vapours are purged to the atmosphere.
In case of an accident special operation instructions are available.
4. Waste water treatment
The intermediate is manufactured about 20 times per year in batches of 6 tons.
Release fraction to waste water: max. 0.5 %
Waste inlet to our own STP: 6000000 g * 0.005 = 30,000 g
Waste outlet calculated according the ECETOC STP model: 2598 g assuming the following parameters:
Molecular weight: 280.35
logKow: 5.18
Vapor pressure: 0.124 Pa
Water solubility: 1.271 mg/l
Biodegradability: Readily biodegradable according OECD 301F
Elimination rate: 100 * (1 - 2,598/30,000) = 91.34 %
In fact the elimination rate is even higher, since in our own STP the actual residence time is about 10 d.
5. Properly trained and authorized personnel handling the substance
All the relevant instructions related to operating and CLP regulation issues are instructed at defined time intervals and the outcomes of these instructions are documented accordingly.
The Safety Data Sheet is made available to any staff member by means of our AS 400 database. Furthermore a set of files containing all the instructions related to the CLP regulation are made available to all the staff members in each manufacturing unit.
Lahnstein 5 September 2012
Dr. H. Dobbelstein

Stability and reactivity

Disposal considerations