Registration requirements for two lubricant and grease components, dicyclohexylamine and morpholine, took effect in Japan Jan. 1, due to an amendment to the list of Poisonous and Deleterious Substances, according to a statement by the Ministry of Health, Labor and Welfare.
The amendment states that dicyclohexylamine and preparations including up to 4 percent of itand morpholine and preparations of up to 6 percent of it must comply with Japans Poisonous and Deleterious Substances Control Law. The law requires registration with the Ministry of Health, Labor and Welfare and local governments. Downstream users are required to store these substances in locked cabinets with proper records, to provide compliant safety data sheets and labels, and to comply with stipulated transport standards.
Dicyclohexylamine and morpholine have Chemical Abstract Service registry numbers of 101 83 7 and 110 91 8, respectively.
The law provides a three-month transitional period for companies to come into compliance. If the companies comply with the new regulations, then there should not be any problems in continuing to use them since they are not totally banned but just being regulated more strictly, said Ethen Zheng, regional manager for the industrial chemical sector of Chemical Inspection and Regulation Service Group USA Inc.
The safety data sheet for Castrols Red Rubber Grease indicates it contains 0.1 to 1 percent of dicyclohexylamine, and Suzukis brake fluid contains less than 1 percent. Morpholine is used as a corrosion inhibitor found in heat treatment oils and other products.
Other parts of Asia have already included these substances in their regulated lists. For China, these two substances are listed in the Hazardous Chemical list. Hazardous registration, compliance with Chinese safety data sheets and labeling, provision of a local 24-hour emergency phone number and related licenses is required before the production or importation of these chemicals, said Zheng.
For Korea, the new [Act on the Registration and Evaluation of Chemical Substances] regulation came into force in Jan. 1 this year. So, before production or importation of those two substances, K-REACH registration will be required, he added.