Joshua Baptist, Mathias Schopf, Francisco Hernandez

International Chemical Regulatory and Law Review, Volume 7 (2024), Issue 1, Page 17 - 22

The purpose of this paper is to introduce a newly proposed operating principle for the heat transfer use sector, which originates in an ECHA restriction proposal on partially hydrogenated terphenyls.1 Heat transfer fluids are substances that enable processes to maintain desired temperature ranges accurately and are used in nearly every manufacturing sector. Heat transfer fluids achieve this through their thermal stability properties, and when operated in a closed system, can provide manufacturing processes with years of function with little maintenance. A new operating principle focused on this theme of closed system operation is called Strictly Controlled Closed Systems (SCCS). The SCCS will serve to standardise safe operation of heat transfer systems in the European Union by limiting exposures to workers and releases to the environment. The SCCS is a combination of several safety standards, principles, and guidelines from inside and outside the heat transfer use sector. This combination of resources has resulted in a novel inspection checklist that should aid in industrial compliance and review of enforcement agencies. In addition, SCCS should provide a regulatory path for hazardous heat transfer fluids to follow as a class. SCCS will allow even hazardous heat transfer fluids to have cradle-to-the-grave standardised management aimed at minimisation of environmental and human exposures. It is our expectation that adoption of this standard will be a role model to ensure the continued use of important chemistries in applications and manufacturing that drive the EU economy.