After a procedure that took more than five years, the European Commission has finally authorised five of the six uses submitted of chromium trioxide (CrO3, EC 215-607-8; CAS 1333-82-0) by the CTACSub Consortium.
WHICH COMPANIES ARE AUTHORIZED FOR NEW USES
The members of the consortium have been granted this authorisation:
- Chemservice GmbH
- Atotech Deutschland GmbH
- Boeing Distribution Inc.
- Prospere Chemical Logistic OÜ
- CROMITAL S.P.A.
- Elementis Chromium LLP
- MacDermid Enthone GmbH
WHAT ARE THE AUTHORIZED USES OF CHROMIUM TRIOXIDE
Basically, the authorised uses for chromium trioxide are:
- Use 1: Formulation of Uses 2, 4, 5 and 6
- Use 2: Hard Chrome Plating
- Use 4: Surface treatment other than use 2 or use 3, specific for aerospace industry
- Use 5: Surface Treatment other than Passivation of Tin Plated Steel – Other Industries
- Use 6: Tin Steel Passivation (ETP)
These include missing Use 3 related to functional plating with decorative character for which additional information has been requested, resulting in a delay in the permitting process that will hopefully come in the next few months.
OBLIGATIONS AND DEADLINES
Downstream users wishing to benefit from this authorisation, must first identify their supplier and their use among those authorised. Once the exposure scenario has been retrieved from the supplier, it must be verified that the conditions indicated are met. At this point, and within three months from the first supply in 2021, you must notify ECHA on the REACH-IT portal that you want to benefit from the authorisation granted to your supplier. Very important is then to complete this request with experimental data on the exposure of their workers to CrVI and the presence of CrVI in discharges and emissions. This should be done within six months and then renewed annually until the permit expires in 2024. Evidence of the correct application of the exposure scenarios and the monitoring carried out in the workplace must be included in a report that must be sent to ECHA and that must remain available in the company in case of controls by local authorities.
TEAM mastery is a leading Italian expert with a history of 4 Authorisations and a review dossier and can assist all users involved in accurately identifying their use and completing the necessary declarations for ECHA!