REPLACEMENT OF HIGHLY AROMATIC OILS IN TYRES FREQUENTLY ASKED QUESTIONS

Updated October 2004

1. 2. 3.

Definitions Highly aromatic oils Substitution

4. Industry plans 5. 1.

Legal situation in Europe

Definitions
Extender oil , also often referred to as process or softening oil, is added to rubber compounds in the production process for tyres and other rubber goods to achieve an acceptable processability. The specific oil may also have an impact on certain performance characteristics of the final product. Highly Aromatic (HA) oils, also referred to as distillate aromatic extract oils (DAE), are oils with a high amount of aromatic carbon structures and are classified as carcinogenic. These oils contain an increased polycyclic aromatic hydrocarbon content and can thus also be called PAH rich oils. (reason for change: Take out PAH content as reason for DAE carcinogenic classification) Poly-Aromatic-Hydrocarbons (PAHs): a group of over 100 chemical substances of poly-aromatic structure, that are widely found throughout the environment and formed by both natural and industrial processes. Eight PAHs have been identified as carcinogenic and are regulated by EU legislation. Mild Extract Solvates (MES): mineral oils, not classified as carcinogenic, as they contain a DMSO extract IP346 inferior to 3% and consequently a reduced PAH content, typically by factor 2050 lower than HA oils. Treated Distillate Aromatic Extracts (T-DAE): mineral oils, not classified as carcinogenic, as they contain a DMSO extract IP346 inferior to 3% and consequently a reduced PAH content, typically by factor 20-50 lower than HA oils. IP346 is a standardized test method developed by the Institute of Petroleum and is applicable to the range of oils used in the tyre industry. The method consists in the extraction of three to seven ring polycyclic aromatic compounds through a specific solvent "DMSO Dimethylsulfoxide". The thus obtained extract through IP346, includes the eight PAH's specified by EU legislation, but is not limited to these. IP346 has been accepted as a suitable predictor of the carcinogenic potential for oils as used in the tyre industry and is thus globally accepted by legislators as a tool for classifying and labeling oils. Oils with an IP346 extract content below 3% are not classified as carcinogenic

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REPLACEMENT OF HIGHLY AROMATIC OILS IN TYRES

2.

Highly aromatic oils

Q1 - What are highly aromatic oils? What are they used for in tyres?

Highly aromatic oils are derivatives of the petrochemical industry. Aromatic oils do not have - contrary to their name - the function of conferring a pleasant smell to the tyre. They enter into the composition of tyres because they are required to facilitate the processing of the rubber compounds. They are also an essential component for the technical performance of the tyre and in particular for its road adherence (or grip) properties. They therefore contribute and directly play a part in the quality of the tyre and user safety.

The presence of polycyclic aromatic hydrocarbons( PAHs) in the environment is primarily due to human activity but can also have a natural origin (forest fires, volcanoes and other combustion of organic materials in nature). PAHs are produced by all combustion phenomena: waste incineration, iron and steel production, home barbecues, motor vehicle exhaust, open chimney fires, tobacco smoking, gas cooking... Cigarette smoke, for example, contains PAH, just like cooking and frying smoke. PAHs are also present in aromatic oils produced by oil refining including in extender oils, and thus also end up as a consequence in tyres. PAHs as such are not a purposeful addition to tyres. PAHs are present in the air, water and ground. Emissions of PAHs coming from abraded tyre particulates are minor (2%) relative to total PAH emissions in air, water and ground (according to the Opinion from the European Commission Scientific Committee on Toxicity, Ecotoxicity and the Environment (CSTEE) in November 2003).

Q2 - What are PAHs? Where do they come from?

The European Union has classified eight PAHs as carcinogenic. They are only harmful to human health in the case of chronic exposure (continuous and very long term), according to the EU Directive which regulates exposure. Tests with blends of HA oil incorporated into rubber compounds show no carcinogenic effects. As long as PAHs are physically bound in abraded tyre particles and they are not available in the environment, they have no carcinogenic effect.

Q3 - Are PAHs carcinogenic?

No, PAHs are not used as direct material in the compound, but the process oils purchased for tyre production contain traces of PAHs.

Q4 - Are PAHs used as a direct material in tyres?

In all tyre categories.

Q5 - In which categories of tyres are highly aromatic oils used?

Highly aromatic oils are added to the rubber compound in the factory during the manufacturing process or added to purchased rubbers to improve the processability of the compounds. Additionally, the tread rubber compound achieves improved performance characteristics, m ainly wet grip but also other characteristics like wear and endurance. Wear has an additional direct impact on the environment as it influences the lifetime of the tyre and reduces used tyres arisings to be treated.

Q6 - What is the purpose of highly aromatic oil use?

REPLACEMENT OF HIGHLY AROMATIC OILS IN TYRES

Q7 - How many grams of highly aromatic oil and PAH do one tyre have?

It depends on the size. For example, in the 195/65R15 tyre size a typical passenger car tyre size in Europe for a Volkswagen Golf or Peugeot 406- there is a content of 200 to 600g of highly aromatic oil per tyre. As a result, the PAH content in that tyre varies between 0.1g to 0.3g (supposing 500 ppm PAH as typical value in highly aromatic oil).

Certain highly aromatic oils as such are classified carcinogenic because when tested according to IP method (so called IP346, see Definitions) show values exceeding 3%. However, finished rubber products such as synthetic rubber and tyre compounds that were produced using aromatic oils are not categorised by the EU as carcinogenic materials (see also Q9).

Q8 - There have been reports saying that highly aromatic oils in tyres are toxic. Is this true?

Once the tyre is vulcanised in the factory and placed on the market as a finished product for sale to consumers, the product presents no danger for the user, whether during physical handling of the tyre, during its road use or at end of life of the tyre. Several studies (Pasteur Institute, Biolab) have confirmed the impossibility for aromatic oils contained in tyres or in blends to be released in their initial chemical state, under test conditions existing in nature. They are closely bound into the mass of the tyre.

Q9 - Are highly aromatic oils dangerous once they are incorporated into the tyre and placed on the market?

In the environment, PAHs degrade more or less quickly according to the specific conditions of the environment. This degradation takes place naturally under the joint action of chemical oxidizers, ultraviolet light and microorganisms. Everybody should be concerned by exposure to or ingestion of PAHs present in water, the air or in food. However, PAHs in tyre debris are not extracted by water or other materials that are normally present in the environment. In November 2003, the Scientific Committee on Toxicity, Ecotoxicity and the Environment (CSTEE) concluded that tyre debris contributes marginally to total PAH emissions (2%) and that a reduction of PAHs in tyres will insignificantly reduce overall concentrations in the environment1.

Q10 - What do the PAHs become when diffused in nature? Do they present a risk for the environment?

Q11 What is the contribution of PAHs in tyre emissions versus other sources?
PAH from tyre debris only represents 2% of the total PAH emissions in the air as demonstrated in the Opinion from the Scientific Committee on Toxicity, Ecotoxicity and the Environment (CSTEE) in November 2003. Making a direct source-to-source comparison illustrates the proportions on a concrete example. Typically in air emission measurement PAH emissions are expressed in BaP concentration. Benzo a pyrene (BaP) is one of the eight regulated PAH's and is chemically detected as a representative species. Tyre wear contributes with 0.015 ng/m3 of BaP concentration in air. This is a value determined most recently by the German Environmental Agency in Berlin.

We also want to remind that the handling of tyres presents no concern for consumers, employees, and workers in factories and tyre shops.

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For example, smoke of one cigarette generates 22 ng BaP. Entering a medium size room of 15 m2 where somebody smokes one cigarette, the exposure to BaP in the air is at concentration of 0.66 ng/m3. This is an air concentration 44 times higher than the one from tyre wear. This is an example to illustrate the proportionality. The tyre industry sticks to its precautionary approach and is committed to replace the highly aromatic oils by end of 2009, the earliest possible phase-out date to guarantee safety and environmental performances of tyres. ng = nanogram = 1 millionth of 1 milligram

Q12- Are the workers handling these oils protected at the workplace?
As a result of safety measures implemented at the workplace for more than 20 years, these oils present no risk for the workers who make and handle the tyres.

3.

Substitution
Q13 - Is it true that alternative oils are being developed?

Alternative extender oils are under investigation by oil producers and the tyre industry is actively involved. According to petroleum companies in Europe, there are mainly two alternative oils available: MES and TDAE. There are, however, still problems with availability of these oils, depending on the geographic area in question. Moreover, to date, the use of these alternative oils is technically possible in some tyre segments, but in some others the industry has still to invest substantial development to compensate for the loss of performance, mainly wet skid performance. This means that some extensive testing is still required before broad use is possible.

This is under active investigation but technical adjustments are definitely needed in order to safeguard tyre performance. At this stage, we have concerns regarding both: wet grip: breaking distance of cars and road safety can be negatively affected ; and tyre durability: in this case, the quantities of used tyres to be treated would increase significantly.

Q14 - Which type of influence do these new oils have on tyre performance?

Alternative mineral oils are not classified as carcinogenic provided that the IP346 extract is below 3% (see Definition). In addition thresholds are being defined for the total of the 8PAH's regulated by the EU and for Benzo (a) Pyrene, (BaP).

Q15 How are alternative oils defined?

In fact, all tyre producers in the BLIC membership have been able to introduce some tyres with low aromatic oils in the tread. Certain types of tyres (e.g. truck tyres) or tyres designed for certain climatic regions or characteristics (e.g., winter tyres) can be more easily produced at lower volumes using low aromatic oils. For the broader range of tyre lines, however, and in particular for the large volume production of passenger car tyres covering summer use when the wet grip performance of the tyre is more acute, the timeline of the development process and broad availability of adequate oils within the EU and exporter countries reflects the projections that have been presented by BLIC. That is, the requested regulatory deadline represents the point in time when it is reasonable to achieve that all types of tyres placed on the EU market will have to be compliant. Between now and then, however, BLIC is confident that strong competitive forces will ensure that there will be increasing numbers of tyres on the EU roads with low aromatic oils as soon as the development procedures, standards and safety/performance assessment permit.

Q16- It seems that a tyre producer is able to complete the substitution earlier. Is this true? If so, why the others cannot do the same?

REPLACEMENT OF HIGHLY AROMATIC OILS IN TYRES

4.

Industry plans
Q17 - Is there any plan to switch from aromatic oil to alternative oil?

In 1995, BLIC set up a working group to consider technical specifications / solutions for replacing highly aromatic oils in all tyre segments while maintaining tyre performance, safety whilst improving its environmental impact. All European tyre manufacturers were involved. As a first step, criteria were established (see Q15) on what was regarded as a toxic substance BLIC members have ever since been monitoring independently the levels of cancer cases in their plants and conducting various lab tests (such as modified Ames test for mutagenicity), and no cancer was detected. BLIC started discussions with oil producers to identify alternatives meeting t he BLIC oil technical specifications and the following BLIC requirements: availability in sufficiently large quantities sourcing from various suppliers. BLIC initiated discussions some years ago with the elastomer producers and obtained technical agreement on a new spec definition (oil extended elastomers). BLIC members have been running tests since 1996 with HA oil-free tyres and have switched several tyre segments to HA oil-free tyres ((mainly truck tyres and passenger winter tyres)

TDAE and MES were raised as candidate alternatives but there are still concerns regarding overall availability. Moreover, there are still concerns in BLIC about the safety of tyres made with the test alternative oils, since same grip and wear levels are not always achievable and especially for some categories of summer tyres. The European tyre producers publicly announced in June 2003 to pursue a precautionary approach and committed to phase out use of the PAH-rich extender oils. This substitution started several years ago, is a very complicated process and cannot be completed before December 2009.

Q18 - The decision to phase-out high aromatic oils was taken by BLIC tyre members in 1995. How do you explain that this process requires 15 years to be completed?
The substitution process is very complex as it involves tyre producers, oil suppliers, synthetic rubber producers and vehicle manufacturers (as it can be seen in the attached road map). The alternative oils are very different from the highly aromatic oils and if they were used without important formulations corrections road safety would be negatively affected. As a matter of example, it has been demonstrated that the breaking distance of a tyre using alternative oils (without the fundamental corrections) is increased by couple of meters compared to a tyre made with highly aromatic oils. Therefore substitution is a tremendous technical challenge, which requires long research and close monitoring of the performances during tyre life (which could take up to 3 years of tyre usage under normal driving conditions).

The tyre producers already for several years have been examining the many issues involved in substituting high aromatic oils. This is not a matter of simply adapting machinery on the tyre production line. It depends on definition, development and testing of new extender oil formulations and related standards and also on complex supply factors that the synthetic rubber and international oil industries must address for their part, too. Downstream, tyres made using the new formulas must be tested and accepted by the car industry. Further, each element in the plan of substitution has a specific time frame and can happen only once other elements are in place. That is, there are logical technical and supply steps that must occur at the proper time in order for the substitution to work and apply broadly. Equally important, the tyre producers must ensure that the tyres using

Q19- Why does it take so long for the producers to achieve the substitution?

REPLACEMENT OF HIGHLY AROMATIC OILS IN TYRES

the new, low-PAH oils, which give different performance characteristics (e.g., braking distance), are entirely safe and provide equal or better performance as tyres already on the road. The tyre industry has carefully weighed all these technical and supply factors in active discussion with the other industry parties involved, projected the time necessary to achieve as fast as possible each stage in the substitution process and has arrived at the 2010 deadline that has been recommended by the industry and which would be consistent with the EU's own assessment of health and environment risk.

Q20- Is the retreading industry concerned with the substitution?

The retreaded tyres are currently not within the scope of the proposed DRAFT Directive (COM(2004)98). However, BLIC is proposing an amendment recommending that only the tread be covered by the future ban. Movement of end of life tyre carcasses cannot be controlled. The whole retreading industrys viability could be threatened if they were not allowed to continue using the existing carcasses on which they place the new treads using the new oils.

Q21 What happens to the existing tyre stocks in tyre distribution network at/after the phase out date?
Nothing is foreseen in the proposed directive. This is the object of a specific amendment requested by BLIC. The time needed to sell off the tyres is 2 years, which is an ordinary practice in this type of modification.

Q22 Could tyre producers outside the EU continue importing tyres containing high aromatic oils after the ban?
No. In the interest of consistency of standards across the EU market and contributing to international harmonisation, there should be a test for the oils in imported tyres.

5.

Legal situation in Europe

Q23- What is the legal situat ion in Europe?

So far, there is no country in Europe where a ban on HA oil use in tyres has been imposed. On 13 February 2004, the European Commission adopted a proposal aimed at banning the use and marketing of PAH-rich extender oils used in tyre production from 31 December 2008. As per the co decision procedure, the proposal will now be submitted to the other EU institutions.

BLIC supports the European directive. It is following from a voluntary commitment of the European tyre manufacturers in order to secure a level playing field. But, BLIC remains concerned about the timing of December 2008 of the Commission proposal. A transition from PAH-rich oils to alternative oils (including oil extended polymer production) is a great challenge for industry especially as the grip performance of tyres, and therefore the breaking distance of cars and road safety, can be negatively affected. This entails significant efforts including chemical re-engineering, extended laboratory tests and complete tyre tests and homologation, and important changes to the manufacturing process. A shortening of the timeline by one year is highly critical to industry, for these reasons. The European tyre industry will not be able to eliminate entirely use of PAH-rich extender oils in tyres before December 2009, and hopes that the Commissions proposal will evolve to reflect the challenges ahead for both the oil and the tyre industry. The European tyre producers need a European directive enforceable and controllable in its application.

Q24- What does BLIC think about this proposal?

REPLACEMENT OF HIGHLY AROMATIC OILS IN TYRES

Not yet. A pre-condition for proper implementation of this proposed directive demands measuring method for the identification of the PAH-rich oil in tyre compound, which is under development within ISO. The method (consisting of measurement of bay protons by NMR) has been successfully validated in a multiple lab crosscheck and has been submitted to the ISO committee in charge for acceptance as an ISO standard.

Q25- Are there test methods available for a proper implementation of the proposed Directive?

Q26 Are original equipment tyres fitted on new vehicles manufactured or imported within EU concerned with the substitution?
Yes.

Q27 How would the tyres equipping new vehicles imported within EU be checked?
See above Q25

-----------------------------------------------------------------------------------------------------------------------------------------For further information, please contact: Mrs F. Cinaralp, BLIC Secretary General, info@blic.be