COMMENTS ON AN ANNEX XV DOSSIER FOR IDENTIFCATION OF A SUBSTANCE AS SVHC AND RESPONSES TO THESE COMMENTS

Substance name:	 Diboron trioxide	
CAS number:	1303-86-2	
EC number:	215-125-8	

The substance is proposed to be identified as meeting the following SVHC criteria set out in Article 57 of the REACH Regulation: CMR

Disclaimer: Comments provided during public consultation are made available in this document as submitted by the webform. It was in the “interested parties” own responsibility to ensure that no confidential information was included in the comments. The European Chemicals Agency is not responsible for the content of this document. The Response to Comments table has been prepared by the competent authority of the Member State preparing the proposal for identification of a Substance of Very High Concern. RCOM has not been agreed by the Member State Committee nor has the document been modified as result of the MSC discussions. 

PART I: Comments and responses to comments on the SVHC proposal and its justification

General comments on the SVHC proposal
Number	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
15	2012/04/12	International NGO
ClientEarth
Belgium	ClientEarth supports the identification as SVHC of all substances that have a harmonised classification as CMRs category 1 and 2. No further justification for such inclusion is needed.	Thank you for your support.	
13	2012/04/12	International NGO
WWF European Policy office
Belgium	WWF supports the inclusion of this substance in the candidate list owing to its classification as toxic to reproduction category 1 B. 	Thank you for your support.	
12	2012/04/12	Industry or trade association
European Borates Association
Belgium	We, as EBA, the European Borates Association, hereby submit comments in exercise of our procedural rights granted by Article 59(4) REACH Regulation.

It is well noted that the basic justification for a/m proposal is the harmonised classification which was first official by the 30th ATP (2008/58/EC) to Directive 67/548/EC.  However, by the time boron oxide was classified as such, the existence of available epidemiological studies was deemed, by the European Commission, to be insufficient.  It must be for this reason that, it was clearly stated in the recital 2 of 30th ATP that "The classification and labelling of the substances listed in this Directive should be reviewed if new scientific knowledge becomes available".  As the peer-reviewed results of recent Chinese and Turkish worker studies are fully available now, we, as the EBA, would like to take this opportunity to prepare a brief position paper from the new scientific knowledge, and put it through this official procedure.

By this position paper, we would like to make authorities aware of the new scientific knowledge which was:
•	Not available when diboron trioxide was initially classified.
•	Not completed when we submitted our comments in the consultation procedure of boric acid and disodium tetraborates while they were being included in the candidate list which will:

•	Be the base for Poland’s reclassification dossiers. 
•	Be outlined in detail in our REACH registration dossiers currently being updated.	Thank you for your comment.
The current harmonised classification is included in Annex VI, Part 3, Table 3.1 of Regulation (EC) No 1272/2008 as amended and adapted to technical and scientific progress by Regulation (EC) No 790/2009 and confirmed by the Court (Fourth Chamber) of 21 July 2011 (OJ C 269, 10.9.2011, p. 10–10, European Court reports 2011 Page 00000, http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:62010CJ0015:EN:NOT ).	
			See also:
Comment 12 attachment (New Repro studies.zip.zip).zip		
11	2012/04/12	Company
Switzerland	In the semiconductor European industry we have identified 2 relevant uses 
1) boron trioxide as substance. 
2) inclusion of boron trioxide glass in articles.   
 On the basis of the extensive section of EU legislation that regulates semiconductor manufacturing operations, ST Microelectronics believes that any potential future nomination or inclusion in the candidate list of boron trioxide for semiconductor usage should identify an exemption for the semiconductor sector from the authorization process.
	Thank you for your information on uses of diboron trioxide.
An exemption from the authorization process according to Art. 58 (2) REACH will only play a role in the next step which has to be decided on later in the process.	
10	2012/04/12	Member State
Austria	The Austrian Competent Authority supports the proposal to include diboron trioxide in the candidate list of substances of very high concern. The substance is classified as Repr. 1B and meets the criteria according to Article 57(c) in REACH. As other boron compounds, diboron trioxide forms boric acid under physiologically relevant conditions, which is the active toxic species responsible for the reproductive toxicity of these substances. The inclusion of diboron trioxide into the candidate list ensures that any possible substitution of other boron compounds with diboron trioxide is avoided.	Thank you for your support.	
9	2012/04/12	Industry or trade association
Glass Alliance Europe
Belgium	Germany submitted to ECHA an Annex XV dossier for the identification of boron trioxide as a SVHC to be included in the candidate list for authorisation. The rationale for this identification is the classification of boron trioxide as toxic for reproduction category 1B in Regulation N°1272/2008.Although perfectly in line with the REACH Regulation, the glass industries believe that the introduction of boron trioxide on the candidate list for authorisation could lead to future misunderstanding as there are a lot of discussions going on at EU and international level on the correct classification of boron trioxide.	Thank you for your comment.
The current harmonised classification is included in Annex VI, Part 3, Table 3.1 of Regulation (EC) No 1272/2008 as amended and adapted to technical and scientific progress by Regulation (EC) No 790/2009 and confirmed by the Court (Fourth Chamber) of 21 July 2011 (OJ C 269, 10.9.2011, p. 10–10, European Court reports 2011 Page 00000, http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:62010CJ0015:EN:NOT ).	
			See also:
Comment 9 attachment (GaE REACH Position Paper on Boron Trioxide.docx).docx		
7	2012/04/11	Member State
Sweden	The Swedish CA agrees that diboron trioxide, being classified as Repr. 1B, meets the criteria according to Article 57(c) in REACH and is thus eligible for identification as a substance of very high concern. Furthermore, we agree that in order to ensure consistency all classified boron compounds should be treated equally.	Thank you for your support.	
6	2012/04/11	Member State
Norway	The Norwegian CA supports that diboron trioxide should be identified as a substance of very high concern and should be included in the Candidate List.	Thank you for your support.	
4	2012/04/06	Member State
Belgium	Belgium supports the identification of Diboron trioxide as SVHC according to article 57 (c)	Thank you for your support.	

Specific comments on the justification
Number	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
12	2012/04/12	Industry or trade association
European Borates Association
Belgium	We, as the EBA, have elaborated the following arguments to support the position that diboron trioxide should not be added to the candidate list:

1- Borates have been used safely for generations and people’s greatest exposure to borates is through a healthy diet. Recent research has demonstrated several benefits associated with boron exposure in humans including bone health, cell membrane function, psychomotor skills and cognitive processes, control of inflammatory disease, enzyme regulation, energy metabolism, and potential anticarcinogenic properties. A more detailed discussion of this research had already been presented in our previous comments submitted during the consultation procedure of boric acid and disodium tetraborates.

2- The main source of disagreement over the appropriate level of classification of diboron trioxide is related to the way effects found in animal studies were extrapolated to humans. Industry acknowledges that there is a reproductive effect from borates in animals that have been force-fed large quantities of boric acid (thus, diboron trioxide) on a daily basis for a long period of time. However, industry has always argued that the Member States and the European Commission have not demonstrated that the classified borate substances have intrinsic properties which give rise to a risk of reproductive toxicity in humans during normal handling and use, as required by law (Annex VI of the Dangerous Substances Directive).  At this very point, may we recall the paragraph 1.1 of Annex VI stating that:

“The object of classification is to identify all the physico-chemical, toxicological and eco-toxicological properties of substances and preparations which may constitute a risk during normal handling or use.”

It does not simply say “all substances”.  There is a definition of substances to be classified; and that is, if there may be a risk under normal handling or use. Therefore, dose and the exposure route should have been components of “normal handling and use” concept; as, besides, this is further expressed in Section 4.2.3.3 of Annex VI which clearly states that:

“.....  Even when clear effects have been demonstrated in animal studies, the relevance for Humans may be doubtful because of the doses administered, for example, where effects have been demonstrated only at high doses, or where marked toxico-kinetic differences exist, or the route of administration is inappropriate.  For these or similar reasons it may be that classification in category 3, or even no classification, will be warranted.”

3- Recital (2) of the 30th ATP which added certain borates to the Dangerous Substances Directive as a Category 2 toxicant and which was inserted by the European Commission, states that “special attention should be paid to further results of epidemiological studies on the Borates concerned by this Directive including the ongoing study conducted in China.”. This study among workers in a borates mine has now been completed and peer-reviewed and confirms that there is no reproductive effect in men, which indicates even at very high exposures the effect in humans is different than the effect on laboratory animals. In the light of this Recital and since the Chinese study (results of which was further confirmed by the recent Turkish worker study)  has not yet been evaluated by ECHA or Member States experts, adding diboron trioxide to the candidate list now simply does not make any sense (as adding boric acid and disodium tetraborates have not).

4- Exposures in China and Turkey were very high and describe the upper end of exposures to be expected in to date production processes of boron containing products which clearly yield to a conclusion that possible human exposures are quantitatively not sufficient to evoke reproductive toxicity effects.

5- As clearly stated in our REACH registration dossiers, instead of the current harmonised classification (Repr. 1B; H360FD), based on the argumentation above the following classification is deemed applicable for diboron trioxide regarding reproductive toxicity: 

•	Category 2 (H361d: Suspected of damaging the unborn child) according to CLP (REGULATION (EC) No 1272/2008 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL) as implementation of UN GHS in the EU.

Conclusion:
New scientific evidence from studies conducted on Chinese and Turkish borate mine workers with the highest exposures demonstrate that borates are safe and biologically important. The new data justify a change of classification for the boron compounds currently assigned with a Category Rep 1B classification.

The EBA recalls that in Recital 2 of 30th ATP (2008/58/EC) to Directive 67/548/EC, which embodies borates’ current Category 1B classification, EU Member States and the European Commission acknowledged that these new data had not been evaluated as part of the decision and that ‘the Directive should be reviewed if new scientific knowledge becomes available.’ In the same Recital, there is specific reference to the Chinese study, which has now been reviewed and is one of two new studies on workers which underpin our request to change the classification. The second study is a 2011 study on Turkish workers which confirms the findings of the Chinese study.

The scientific argumentation can be concluded by taking all the fundamentals together that, boron is an essential nutrient on the one hand. On the other hand, even extreme human worst-case exposures (i.e., those noted for the Chinese cohort) do not lead to quantitative uptakes that meet the experimental NOAELs for developmental toxicity or fertility. This quantitative consideration supports the findings by Robbins et al. (2010) of an absence of adverse effects on semen parameters, even in most extremely boron-exposed humans. These conclusions are further seconded by the very recent worker study on boron-exposed workers in Turkey.

In essence, it can be stated that there is now a solid scientific database to evaluate the risks of human boric acid (thus, diboron trioxide) exposures, under any exposure conditions feasible for normal or reasonably foreseeable conditions of use. Taking both the experimental and human data together, it follows that possible human exposures are quantitatively not sufficient to evoke reproductive toxicity effects. 

The intended identification of the substance as an SVHC is not justified and should therefore be withdrawn.	Thank you for your comment.
The current harmonised classification is included in Annex VI, Part 3, Table 3.1 of Regulation (EC) No 1272/2008 as amended and adapted to technical and scientific progress by Regulation (EC) No 790/2009 and confirmed by the Court (Fourth Chamber) of 21 July 2011 (OJ C 269, 10.9.2011, p. 10–10, European Court reports 2011 Page 00000, http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:62010CJ0015:EN:NOT ): Examination of the questions referred for a preliminary ruling has disclosed no factor of such a kind as to affect the validity, first, of Commission Directive 2008/58/EC of 21 August 2008 amending, for the purpose of its adaptation to technical progress, for the 30th time, Council Directive 67/548/EEC on the approximation of the laws, regulations and administrative provisions relating to the classification, packaging and labelling of dangerous substances and, second, of Commission Regulation (EC) No 790/2009 of 10 August 2009 amending, for the purposes of its adaptation to technical and scientific progress, Regulation (EC) No 1272/2008 of the European Parliament and of the Council on classification, labelling and packaging of substances and mixtures, in so far as that directive and that regulation classified certain borate substances as reprotoxic in category 2.	
			See also:
Comment 12 attachment (New Repro studies.zip.zip).zip		
9	2012/04/12	Industry or trade association
Glass Alliance Europe
Belgium	Recital (2) of the 30th ATP writes: "special attention should be paid to further results of epidemiological studies on the borates concerned by this Directive including the ongoing study conducted in China".
Moreover, this proposed classification would have a negative impact on the downstream production chain.	Thank you for your comment.
The current harmonised classification is included in Annex VI, Part 3, Table 3.1 of Regulation (EC) No 1272/2008 as amended and adapted to technical and scientific progress by Regulation (EC) No 790/2009 and confirmed by the Court (Fourth Chamber) of 21 July 2011 (OJ C 269, 10.9.2011, p. 10–10, European Court reports 2011 Page 00000, http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:62010CJ0015:EN:NOT ).	
			See also:
Comment 9 attachment (GaE REACH Position Paper on Boron Trioxide.docx).docx		
8	2012/04/11	Member State
Ireland	Diboron trioxide is classified as Repr. 1B according to Regulation EC No. 1272/2008, and therefore the Irish CA agrees that the substance meets the criteria for identification as an SVHC in accordance with Article 57 (c) of REACH.

We note a specific concentration limit (Repr 1B; H360FD: C ≥ 3.1%) applies for diboron trioxide and should be carried forward to the candidate list entry for this substance.	Thank you for your support.
The specific concentration limit is given in the support document.	
2	2012/03/30	Member State
United Kingdom	We agree that diboron trioxide meets the hazard criteria for inclusion on to the Candidate List.

However we are unclear as to why this substance has been proposed for the Candidate List at this time given that the outcome of the third prioritisation exercise for disodium tetraborate and 4 other boron compounds was not to prioritise these compounds until the impacts of the new restriction on consumer uses and the registrations in accordance with the classification as “Repr 1B” had been assessed. 

We think the same outcome would be obtained on prioritisation as the other boron compounds on the third prioritisation list.	Thank you for your comment.
The other boron compounds were also not prioritised due to grouping considerations. ‘From the grouping perspective, it should further be noted that there are some additional boron compounds which are classified as toxic for reproduction (cat 1B) which are not on the Candidate List.’ All boron compounds which are classified as toxic for reproduction (cat 1B) might then be prioritised together at a later time point.	

PART II: Comments and responses to comments on uses, exposures, alternatives and risks

Specific comments on use, exposure, alternatives and risks
Number	Date	Submitted by (name, Organisation/MSCA)	Comment	Response	
14	2012/04/12	Individual
China	Diboron trioxide is widely used in glass. It's a important composition of the glass and glass fibre. Many companies do not find a substance to replace it.	Thank you for your comment. The question of alternatives needs to be addressed when an application for authorisation becomes necessary.	
12	2012/04/12	Industry or trade association
European Borates Association
Belgium	SECTION 1.1: 
o	The use of boric oxide in consumer uses has been restricted through Annex XVII (Regulation (EU) No 109/2012), therefore, it does not seem relevant to include the consumer exposure estimates in this dossier. Further a specific concentration limit of greater than equal to 3.1% has been assigned and this is deemed to be a safe level to protect workers and consumers.
o	The reported uses taken from the ECHA Dissemination Dossier are inaccurate and are being refined by the 2010 registrants. A more representative list is:
Glass production
Refractories
Use of borates in metallurgy
Nuclear
Catalysts
Intermediates for non oxide ceramics
Gallium arsenide
Reagent chemicals
Crystal growth
Use of substance for production

SECTION 1.2: 
o	Comment on the exposure measurement by Garabrant in section 1.2 Information on Occupational Exposure
The concentration of total particulate matter measured by the 37 mm cassette as reported by Garabrant (1.2 to 8.5 mg/m3 with a mean of 4.1 mg/m3) under estimated the actual exposures. Several studies have demonstrated that the 37-mm total dust sampler equipment under samples suspended particles by factors ranging from 1.2 to 4.0 compared to the IOM sampler. A conversion factor of 2.5 for under sampling bias has been suggested for converting “total” personal exposure measures from industries similar to the borate mining and processing facility to equivalent inhalable aerosol exposures (Werner et al. 1996; Vincent 2007).  Inhalable particulate exposure is best estimated by applying the 2.5 conversion factor to the total dust sampler results giving IOM levels of 3 mg/m3 to 21.25 mg/m3 with a mean of 10.25 mg/m3.  In a 7 year follow-up study by Wegman et al. 1991 of the same facility, a 7-year exposure to dust in the work environment examined was not associated with long-term health effects.

o	Exposure to diboron trioxide is limited to the manufacturing stage only in many of the uses above. Diboron trioxide converts to another substance (e.g. glass, catalysts such as BCl3) and is thus considered a transported intermediate. Within the workplace diboron trioxide is subject to regulation under a range of downstream EU legislation, intended to protect workers and consumers
1.	Eco-Label Award Scheme Regulation (1980/2000/EC)
2.	Directive on the safety of toys (2009/48/EC)
3.	Regulation on Cosmetic Products (RECAST) (1223/2009)
4.	Food Supplements Directive;
5.	Medicinal Products Directive
6.	Waste Framework Directive (2006/12/EC) 
7.	Detergents Regulation (648/2004/EC) 
8.	Regulation on the export and import of dangerous chemicals (689/2008)
9.	Biocidal Products Directive  (98/8/EC)
10.	Water Framework Directive (2000/60/EC)
11.	Directive on integrated pollution prevention and control (2008/1/EC)
12.	 ADR and RID Framework Directive (Transport of Dangerous Goods) (2000/61/EC)
13.	Chemical Agents Directive (2007/30/EC)
14.	Pregnant and Breastfeeding Workers Directive (92/85/EEC)
15.	Young Workers Directive (94/33/EC)
16.	Signs at Work Directive (92/58/EEC)
17.	Personal Work Equipment Directive (2007/30/EC)	Thank you for your information on uses of diboron trioxide.

Thank you for your comments on the sampling methods used by Garabrant. We will check the provided information and references and will comment if necessary in the next few weeks.	
			See also:
Comment 12 attachment (New Repro studies.zip.zip).zip		
11	2012/04/12	Company
Switzerland	P11,13,14 
In the semiconductor European industry we have identified 2 relevant uses 
1)	Identified uses for boron trioxide as substance. 
The substance is completely transformed into a new substance to be included into an article, the so called the semiconductor device.  The reaction takes place on the article’s surface; all available boron trioxide is consumed and no un reacted boron trioxide can be found. In the semiconductor device the boron is embedded into the silicon matrix therefore boron trioxide cannot be found any more.   
Sector of use (SU) SU 3	Industrial manufacturing  SU 16 Manufacturing of computer, electronic and optical product, electrical equipment
Chemical product category (PC)	PC 33	Semi-conductor PC 15Non-metal-surface treatment products
Process category (PROC)	PROC 2 	Use in closed, continuous process with occasional controlled exposure (e.g. sampling) - Industrial setting ; 
PROC 13 Treatment of articles by dipping and pouring 
Article category (AC)	  	Not applicable 

Quantity used in Europe 183kg in 2011
The highly sophisticated and detailed risk management measures employed in manufacturing environment at our premises in Europe for this substance alongside ie the highly controlled workplace environment, the relevant industrial hygiene measurements used in the our manufacturing plants and the rigorous waste management in place ensure a rigorous and strictly managed usage of boron trioxide.
Industrial hygiene measurements performed in all working areas showed all values below 0.038 mg/m3 

2)	Identified uses for inclusion of glass in articles. 
Glass conventionally made of boron trioxide is used in the semiconductor manufacturing industry to produce a new article, the semiconductor device, only.  
Glass is a substance of variable composition, which for simplicity is expressed by convention in terms of oxide of the constituent elements (SiO2, Na2O, CaO, B2O3, etc). Although conventionally, glass compositions are expressed as oxides of the different components, glass is a non-crystalline or vitreous inorganic macromolecular structure, which does not contain the chemical components of the different raw materials, ie boron trioxide is embedded into the glass matrix. 
Under REACH glass is classified as a UVCB substance (substance of unknown or variable composition, complex reaction products or biological materials). It is exempted from the REACH  registration requirement  under the conditions laid down in Annex V.
 
Sector of use (SU) SU 3	Industrial manufacturing SU 16 Manufacturing of computer, electronic and optical product, electrical equipment
Chemical product category (PC)	PC 33	Semi-conductor	PC 15	Non-metal-surface treatment products
Process category (PROC)	PROC 2 	Use in closed, continuous process with occasional controlled exposure (e.g. sampling) - Industrial setting ; 
PROC 13 	Treatment of articles by dipping and pouring 
Article category (AC)	AC 2 	Electrical  and electronic articles 

Quantity used in Europe in semiconductor industry  2600 kg of glass articles
Maximum nominal concentration of boron trioxide in incoming articles 30 % accounting for a total of 800 kg of boron trioxide 
Maximum nominal concentration in finished semiconductor devices being used in Europe or exported from Europe  15 %  
On the basis of the extensive section of EU legislation that regulates semiconductor manufacturing operations, ST Microelectronics believes that any potential future nomination or inclusion in the candidate list of boron trioxide for semiconductor usage should identify an exemption for the semiconductor sector from the authorization process.
	Thank you for your information on uses of diboron trioxide.

An exemption from the authorisation process according to Art. 58 (2) REACH will only play a role in the next step which has to be decided on later in the process.	
5	2012/04/11	Industry or trade association
German Refractory Association
Germany	Diboron trioxide is very important as binder for special shaped and unshaped refractory products. The refractory industry is looking for alternative substances, however it will not possible to replace Diboron trioxide completely. In the moment, the only possible alternative substance is Boric acid. 
Not using Diboron trioxide it would have enormous consequences for the environment.
Due to the shorter life time of refractory materials without Diboron trioxide, customers would have to replace more frequently the refractory products, with the consequence of a lot more raw materials are required (in a time of limited available resources). This means a higher environmental pollution by transport, higher energy consumption for the calcination of raw materials and baking of the refractory products, a higher CO2-production detrimental to the targets to Europe’s in its Climate Change Programme (ECCP), more waste and last but not least supports the transfer of workplaces to counties outside of European Countries.

Refractory products with Diboron trioxide are used in the Steel-, Glass-, Cement- and Aluminium-Industry. The authorisation of Diboron trioxide also would therefore have severe consequences to those industries.
	Thank you for your information on uses of diboron trioxide. The requirements for inclusion of diboron trioxide in the Candidate list are met by the hazard criteria of REACH Art. 57c. Further criteria according to Art. 58 REACH will only play a role in the next step which has to be decided on later in the process. The question of alternatives needs to be addressed when an application for authorisation becomes necessary. An exemption from the authorisation process according to Art. 58 (2) REACH might be granted if the risk is properly controlled.	
3	2012/04/05	Company
Germany	In the manufacture of crystalline silicon solar cells n-type cells gain a strong and increasing attention. This is because recent studies have shown that the efficiency of crystalline silicon solar cells can be increased significantly if n-type silicon instead of p-type silicon is used as starting material. These n-type cells normally have a boron-diffused emitter. The boron-diffused emitter is manufactured by diffusion. Diffusion may take place on the one hand in furnace tubes using boron trichloride or boron tribromide. On the other hand diffusion may take place by less cost-intensive printing processes. The latter make use of boron-containing mixtures. Diboron trioxide, boric acid or related boron compounds are reactants in the production of these mixtures. 	Thank you for your information on uses of diboron trioxide.	
2	2012/03/30	Member State
United Kingdom	Section 2 – the information given relates more to the use of diboron trioxide as a replacement for other boron compound rather than what could be used as a replacement for the substance itself. This information would be helpful to come to a view on the practicality of the alternatives for boron trioxide.	This information was given to substantiate the argumentation - to avoid potential replacement of other boron compounds with diboron trioxide having a similar hazard potential. No further information on alternatives could be found but using boric acid instead of diboron trioxide.	
1	2012/03/30	Company
United Kingdom	ANNEX XV – IDENTIFICATION OF SVHC
13
The substance has also been registered in a number of preparations listed in the SPIN (Substances in
Preparations in Nordic Countries; 2011) - online database. Assigned use categories include:
· paints, lacquers and varnishes,
· glazing materials,
· welding and soldering agents,
· construction materials,
· fireproof cement,
· protective chemicals,
· photo-chemicals,
· others.
Diboron trioxide is a fire resistant additive for paints and electronics (HSDB 2010). 	Thank you for your information on uses of diboron trioxide.

With regard to the attachment we would like to refer to the national Control of Substances Hazardous to Health (COSHH) regulations in the UK. Appropriate practical advice on safe systems of work when using the end product may be found in the COSHH Essentials control guidance sheets. http://www.hse.gov.uk/pubns/guidance/index.htm	
			See also:
Comment 1 attachment (Diboron Trioxide March 2012.doc).doc		

Attachments

Comment number	Public attachment	
1	
Comment 1 attachment (Diboron Trioxide March 2012.doc).doc	
9	
Comment 9 attachment (GaE REACH Position Paper on Boron Trioxide.docx).docx	
12	
Comment 12 attachment (New Repro studies.zip.zip).zip