HA oils

REPLACEMENT OF HA OILS IN COVERS
This document is the updated version of the original FAQ developed by ETRMA (formerly BLIC) and reflects the latest regulatory developments.
Directive 2005/69/EC Directive 2005/69/EC
(REACH) Regulation 1907/2006 Annex XVII.50 Annex XVII.50

1 – HIGHLY AROMATIC OILS
Q1. What are highly aromatic oils? Why are they used in tires?
Highly aromatic oils are derivatives of the petrochemical industry. Aromatic oils do not – contrary to their name – have the function of providing a pleasant scent on the tire. They appear in the manufacture of tires because they are needed to facilitate the mixing of the rubber. They are also an essential component for the technical performance of the tire and in particular for its road grip properties. They therefore contribute directly and play a role in the quality of the tire and the road safety of the tire.

Q2. What is PAH? Where does it come from?
PAHs are present in the environment mainly as a result of human activity, but can also come from nature through e.g. forest fires, volcanic eruptions and other burning of organic material. PAHs are produced by all kinds of consumption. Garbage burning, the iron and steel industry, barbecuing, vehicle exhaust, house heating, cooking, tobacco smoking … are examples of things that have PAH content.
PAHs are also found in aromatic oils produced by refining crude oil, e.g. plasticizing oils used in tyre manufacturing. PAHs themselves are not necessary to make tires. They are present in the air, water and soil. PAH emissions from tire wear particles are minimal (2%) in relation to total PAH emissions to air, water and soil (according to the opinion of the European Commission’s Scientific Committee on Toxicity, Ecotoxicity and the Environment (CSTEE) in November 2003.

Q3 Are the PAHs carcinogenic?
The European Union has classified eight PAHs as carcinogenic.
They are only harmful to human health in case of chronic exposure (uninterrupted exposure and very long time), according to EU directives regulating exposure.
Tests with mixtures of HA oil bound (vulcanization) in rubber compounds show no carcinogenic effects.
As long as PAHs are physically bound in wear particles from tires, they are not available in the environment and they have no carcinogenic impact.

Q4 Are free-form PAHs used as a material in tires?
No, PAHs are not used in free form in rubber compounds. However, the process oils purchased for tire production contain traces of PAHs.

Q5. What is the purpose of using highly aromatic oils?
HA oil is added to the rubber compound during the manufacturing process in the factory. Alternatively, the oil may be added to improve the preparation of the rubber purchased directly from the manufacturer. In addition to this, the tread rubber is known to have improved wet grip and also affects other performance such as service life.

Q6. In which types of tires were highly aromatic oils used before the restriction came into force?
In all tire types.

Q7 There have been reports that highly aromatic oils in tires are toxic. Is this true?
Some highly aromatic oils as such are classified as carcinogenic, because when tested according to method IP (so-called IP 346) show values exceeding 3%. However, there are finished rubber products such as synthetic rubber and rubber compounds in tires produced with HA oil that are not classified as carcinogenic materials by the EU.

Q8. What do PAHs become when released into the environment? Do they pose a risk to the environment?
In the environment, PAHs degrade more or less quickly depending on the specific environmental conditions. This degradation occurs naturally with chemical oxidants, ultraviolet light and micro-organisms.
All humans are exposed to PAHs in water, air and food. PAHs from tire wear, on the other hand, do not dissolve in water or other materials normally found in the environment.
In November 2003, the Scientific Committee on Toxicity, Ecotoxicity and the Environment (CSTEE) concluded that tire debris contributes only marginally to total PAH emissions (2%) and that reducing PAHs in tires will insignificantly reduce overall levels in the environment.
We would also like to mention that tire management is not a concern for consumers, employees and workers in factories and tire shops.

Q9. What is the contribution of PAHs in tire emissions compared to other sources?
PAHs from tire debris represent only 2% of total PAH emissions to air as stated in the opinion of the Scientific Committee on Toxicity, Ecotoxicity and the Environment (CSTEE) in November 2003.
By making a direct source to source comparison, the proportions are illustrated in a concrete way. In a typical air emission measurement, PAH emissions are expressed in BaP concentration. Benzene pyrene (BaP) is one of the eight regulated PAHs and is chemically detected as a representative species. Tire wear contributes 0.015 ng/m3 of BaP concentration in the air. This is a value most recently determined by the German Environment Agency in Berlin.
For example, smoking a cigarette generates 22 ng BaP. In a medium-sized room of 15 m2 where someone smokes a cigarette, the exposure to BaP in the air is at a concentration of 0.66 ng/m3. This is a concentration 44 times higher than that from tire wear.
This is an example to illustrate proportionality. The tire industry is sticking to its precautionary principle and has committed to replace the highly aromatic oils by 2010-01-01.
ng = nanogram = 1 ppm 1 milligram

Q10. Are staff handling these oils protected in the workplace?
As a result of safety measures implemented in workplaces more than 20 years ago, these oils do not pose a risk to workers manufacturing and handling tires.
2 – Legal environment in Europe

Q11. What is the legal situation in Europe?
Since January 1, 2010, extender oils shall not be placed on the market (sold or distributed to) for use in the manufacture of tires if they contain:
– more than 1 mg/kg (0.0001% by weight) of polycyclic aromatic hydrocarbons; or
– more than 10 mg/kg (0.001% by weight) of the sum of all listed polycyclic aromatic hydrocarbons:
o Benzo[a]pyrene (BaP) CAS # 50-32-8
o Benzo[e]pyrene (BEP) CAS# 192-97-2 oils
o Benzo[a]anthracene (BAA) CAS# 56-55-3
o Chrysen (FHS) CAS # 218-01-9
o Benzo [b] fluoranthene (BbFA) CAS # 205-99-2
o Benzo [j] fluoranthene (BjFA) CAS # 205-82-3
o Benzo [k] fluoranthene (BkFA) CAS # 207-08-9
o Dibenzo [a, h] anthracene (DBAhA) CAS # 53-70-3
This restriction applies to tires manufactured within the EU and tires imported into the EU.
This restriction, originally adopted by the European Commission through Directive 2005/69/EC, is now incorporated in EU Regulation 1907/2006 (REACH), Annex XVII, entry 50.

Q12. What are the tire categories covered by the ban?
“Entry 50” of Annex XVII adopted by Commission Regulation 552/2009 restricts the use of PAHs in tires for “vehicles covered by Directive 2007/46/EC establishing a framework for the approval of motor vehicles and their trailers”. Article 2 of Directive 2007/46 defines the scope:
 Point 1 includes vehicles intended for use on roads.
 Point 3 of Article 2 lists the following vehicles: vehicles designed and constructed for use principally on construction sites, in quarries, in ports or at airports,
 vehicles designed and constructed for use by the armed forces, civil defense, fire brigades and forces responsible for maintaining public order;
 mobile machinery,
 Point 4 of Article 2 lists the following vehicles: vehicle combination, intended exclusively for road racing
 Prototype vehicles used on the road under the responsibility of a manufacturer to carry out a specific test program provided that it is specific.
The restriction in Entry 50 covers tires for vehicles listed in Article 2(1), (3) and (4) of Directive 2007/46/EC with a maximum design speed exceeding 25 km/h. Therefore, tires for mobile machinery with a maximum speed exceeding 25 km/h shall also be covered by the restriction.

Q13 Are retreaded tires affected by the ban?
Yes, the new tread must be made with ‘clean’ oils that meet the new requirements.

Q14. Are inner tubes in the scope of the ban?
No, hoses are not affected by the marketing restrictions listed in entry 50 of Annex XVII of REACH.

Q15. Are original equipment tires on new vehicles manufactured in or imported into the EU covered by the ban?
Yes.

Q16. Are reference tires covered by the ban?
“Standard reference” tires are manufactured and imported only for the purpose of being provided as a performance reference for other newly developed tires. They are not sold on the market and are not intended to be fitted on vehicles intended for end-users. These tires are therefore not covered by the restriction provision of entry 50 of Annex XVII.

Q17. –

Q18. Are there testing methods for the correct implementation of the proposed Directive?
Yes, tests are available for testing both oils and the finished product (vulcanized rubber):
Oils in compliance with IP346: Limit values shall be considered to be met if the polycyclic aromatic compounds (PCA) extract constitutes less than 3% by weight as measured by Institute of Petroleum standard IP346: 1998 (Determination of PCA in unused base lubricating oils and asphaltene free petroleum fractions – Dimethyl sulfoxide extraction refractive index method), provided that compliance with the limit values for BaP and listed polycyclic aromatic hydrocarbons, and the correlation of the measured values with the PCA extract, is verified by the manufacturer or importer every six months or after any major operational change, whichever occurs earlier.
Tires in compliance with ISO 21461: The soft rubber compounds shall not exceed 0,35% Bay protons measured and calculated according to ISO-21461 (vulcanized rubber – determination of aromatic oil in vulcanized rubber compounds).

Q19 What does “part of a tire” mean?
The definition of the term “part of a tire” can be referred to the EU type-approval legislation on tires 2 , which defines certain parts as a “part of a tire”, i.e.: carcass, tread and sidewalls 3 .
2 Directive 92/23 on tires for motor vehicles and their trailers, Official Journal of the European Union
L 129 (1992), p. L 129 (1992), p. 25 (as amended). 25 (as amended).
3 See Annex II (Requirements for tyres), section 2 (Definitions), points 2.4, 2.7, 2.8 and 2.9.

Q20. What the tire/rubber industry about this restriction?
They entered into a voluntary commitment from European tire manufacturers to ensure a common level in June 2003.
A switch from PAH-rich oils to alternative oils (e.g. oil extended polymers) was a major challenge for the industry in particular as tire grip, and thus car braking distances and road safety, could have been negatively affected. This in itself required significant efforts including chemical re-engineering, extended laboratory testing, full tire compliance testing, and important changes in the manufacturing process. This was in order to maintain wet performance, rolling resistance and noise levels despite the new legislation.
3 – Definitions
a. Plasticizers, often referred to as “process or extender oils”, are added to rubber compounds in the tyre production process along with other substances to achieve acceptable processability of the rubber. These special oils may also affect certain properties of the final product.

b. Highly aromatic (HA) oils, also called distilled aromatic extract (DAE) oils, are oils with a high amount of aromatic carbon structures and are classified as carcinogenic. These oils contain a higher amount of polycyclic aromatic hydrocarbons and can thus also be called PAH rich oils.

c. Polyaromatic hydrocarbons (PAHs): a group of over 100 chemical substances with the poly-aromatic structure, commonly found throughout the environment and consisting of both natural and industrial processes. Eight PAHs have been identified as carcinogenic, and are regulated by EU legislation.

d. Treated distilled aromatic extract (T-DAE): mineral oils, which are not classified as carcinogenic, because they contain a DMSO extract IP346 lower than 3% and thus a reduced PAH content, usually by a factor of 20-50 lower than HA oils.

e. IP346 is a standardized test method developed by the Institute of Petroleum and is applicable to the various oils used in the tire industry. The method consists in the extraction of three to seven rings of polycyclic aromatic compounds through a special liquid “DMSO Dimethyl sulfoxide”. The extract obtained by IP 346, includes the eight PAHs specified by EU legislation, but is not limited to these. IP346 has been accepted as a suitable indicator of the carcinogenic potential of oils used in the tire industry and is thus globally accepted by regulators as an aid to classification and labeling oils. Oils with IP346 extracted content below 3% are not classified as carcinogenic

f. ISO 21461 is a standardized method for the selective determination of polyaromatic oil in soft rubber compounds. The method is based on nuclear magnetic resonance (NMR) spectrometry.