First tier modeling of consumer dermal exposure to substances in consumer articles under REACH: A quantitative evaluation of the ECETOC TRA for consumers tool

► Comparison of ECETOC TRA dermal model with physics-based exposure model. ► ECETOC TRA did not provide conservative estimates in the scenarios considered. ► Diffusion-based model is proposed as a first tier risk evaluation model in REACH. The demonstration of safe use of chemicals in consumer products, as required under REACH, is proposed to follow a tiered process. In the first tier, simple conservative methods and assumptions should be made to quickly verify whether risks for a particular use are expected. The ECETOC TRA Consumer Exposure Tool was developed to assist in first tier risk assessments for substances in consumer products. The ECETOC TRA is not a prioritization tool, but is meant as a first screening. Therefore, the exposure assessment needs to cover all products/articles in a specific category. For the assessment of the dermal exposure for substances in articles, ECETOC TRA uses the concept of a ‘contact layer’, a hypothetical layer that limits the exposure to a substance contained in the product. For each product/article category, ECETOC TRA proposes default values for the thickness of this contact layer. As relevant experimental exposure data is currently lacking, default values are based on expert judgment alone. In this paper it is verified whether this concept meets the requirement of being a conservative exposure evaluation method. This is done by confronting the ECETOC TRA expert judgment based predictions with a mechanistic emission model, based on the well established theory of diffusion of substances in materials. Diffusion models have been applied and tested in many applications of emission modeling. Experimentally determined input data for a number of material and substance combinations are available. The estimated emissions provide information on the range of emissions that could occur in reality. First tier tools such as ECETOC TRA tool are required to cover all products/articles in a category and to provide estimates that are at least as high as is expected on the basis of current scientific knowledge. Since this was not the case, it is concluded that the ECETOC TRA does not provide a proper conservative estimation method for the dermal exposure to articles. An alternative method was proposed.