Regulatory demands and their potential impact on zirconDr Keven Harlow - ZIA

17th Mineral Sands Conference | Perth, Australia | 15-16 March 2017

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Disclaimer

This presentation is intended for information purposes onlyand is not intended as promotional material in any respect.The contents are not intended as an offer or solicitation for thepurposes of sale of any financial instrument, are not intendedto provide an investment recommendation and should not berelied upon. The contents are derived from published sources,together with personal research. No responsibility or liabilityis accepted for any such information or opinions or for anyerrors, omissions, misstatements, negligence or otherwise forany other communications, written or otherwise.

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Overview

1. NORM (Naturally Occurring Radioactive Material)

2. Maritime bulk shipping

3. Chemical regulation

4. Way forward

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Regulations: the new paradigm

SAICM1

REACH2

GHS3

Global initiatives drive regulatory growth

• Hazard based

• Risk based

• Focus on high tonnage substances

1. SAICM: strategic approach to international chemicals management

2. REACH: Registration, Evaluation & Authorization of chemicals

3. GHS: Globally Harmonized System of classification & labelling

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Why are regulations increasing?

Accidents and disastersNew technologies

= uncertainty (e.g. nanos)

Political motivation (green agenda)

NGO / consumer group pressure

Too many chemicals…

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Naturally Occurring Radioactive Materials (NORM)

The zircon industry needs to anticipate the threats and manage the impact on:-

✓ Production (worker and community exposure)

✓ Transport (including cross-border)

✓ Recycling and waste

FACT: The radioactive nature of zircon has not changed, but the way in which radioactivity is viewed has

FACT: The levels at which a substance is classified as ‘radioactive’ have progressively reduced

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Radiation is regulated worldwide

• IAEA – the major reference worldwide

• Local regulations may adopt the IAEA guidelines

• Europe: EURATOM 2013 - effective early 2018

For the first time, ‘Zircon and zirconium’ included in the Annex list of industrial sectors involving NORM…

… data are needed

• ZIA survey of EU-based zircon milling operations

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Zircon milling survey - traffic light summary

STORAGEStrict control of access to storage area - for essential access only

PROCESSINGFloor sweeping to be avoided in favour of vacuuming.Look to measure zircon levels in stacks/chimneys

WASTE MGTMaximise recycling of spillage and dust collection in air cleaning equipment.Develop arrangements with landfill operators

H&S

Introduce formal worker Radiation Protection ProgramRisk assessment of operations Use radiation badges at high(er) risk locationsMeasure exposure to public around the site

FINAL PRODUCTEnsure paper sacks are protected and secure on palletIntroduce emergency procedure for road/rail transport

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NORM- main messages

1. Zircon industry is mature and experienced in handing the demands of NORM.

2. Zircon / zirconia is on the regulator’s radar, albeit at a low priority

3. Latest exposure data are always needed

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Maritime shipping codes:

• Driven by internationally-agreed codes managed by the IMO*- MARPOL recently updated by alignment with GHS

• Others updated as evidence arises on cargo characteristics that may affect safety of a vessel and/or of the crew.

• Know your cargo – data needed*IMO – International Maritime Organization (United Nations)

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Maritime transport: IMSBC

Bulk cargoes fall into three groups:

• Group A – cargoes that may liquefy (ilmenite is group A)• Group B – cargoes with a hazard that could endanger vessel or crew• Group C – other cargoes that can still be hazardous.

A

B

C

Zircon is group C

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Other current issues

• Ilmenite: recent Group A cargo (liquefaction) - moisture content to be measured for each cargo.

• Zircon: may need to test to pre-empt an unjustified Group A cargo schedule

• Also, an inaccurate reference to ‘sand’, with the known long-term health effects associated with silica, may mean that others mineral sands are classified as harmful (zircon sand, rutile sand, ilmenite sand…)

• Materials hazardous in bulk: corrosivity to metals tests ongoing – mandatory from Jan 2017

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Chemical regulations: the challenges

• Shifting the burden-of-proof (of safe use) to industry

• Precautionary principle - a driver for regulatory decisions

• Lack of robust, admissible data

• Hazard, rather than risk, used to prioritise chemicals for regulatory scrutiny…

…so what?

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TiO2 classification proposal

Why is the zircon industry interested?

• Zircon with >0.1% TiO2 carries the same classification.

classification GHSCat 1B carcinogen

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Also…

• USA Occupational Safety and Health Administration(US-OSHA) amended standards for occupationalexposure to respirable crystalline silica, reducingthe permissible exposure limit (PEL) to 50μg/m3.

• Of more concern, European authorities areconsidering a proposal to classify crystalline silicaas a carcinogen

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Other REACH-like derivatives

• Asia (S. Korea, China, Japan): updating regulations in sympathy with REACH

• Cataloguing, leading to prioritisation of chemical registrations e.g. S Korea

• REACH-like, but some important differences do exist (e.g. annual reporting in South Korea)

• GHS* is not (yet) harmonised. Scientifically unjustified classifications exist and these need to be addressed with reliable data

*GHS- Globally Harmonised System for classification and labelling

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Conclusions:

• NORM – understood and well managed in the industry. Keep ahead of the next regulatory cycle

• Maritime: needs close monitoring and appropriate lobbying at local maritime authorities.

• Chemical: vigilance needed. Over precautionary approach and unjustified classifications can catch industry unawares

REGULATORY COMPLIANCE = BUSINESS CONTINUITY

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Final takeaway

• Our industry is facing a dynamic, rapidly changing and more demanding system of regulation

• Data, data, data..!

The regulatory burden will grow

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and finally… ZIA’s Technical Handbook

1. Introduction2. Material properties3. State of the art applications4. Emerging R&D5. References

Available at

www.zircon-association.org

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Thank you

Dr Keven Harlow | Executive Director, ZIA

Email: kharlow@zircon-association.orgWebsite: www.zircon-association.org

Zircon Industry Association Limited is registered in England No. 08187233 with

its registered office at Grenville Court, Britwell Road, Burnham, Bucks, SL1 8DF