COMMENTS BY FRENCH ASSOCIATION OF SURFACE TREATMENT
(U.I.T.S.) ON THE SUBJECT OF ALTERNATIVES TO CHROMIUM TRIOXIDE
FOR AN APPLICATION FOR AUTHORISATION UNDER THE REACH REGULATION
Uits is the French trade association representing firms involved in metal and plastic finishing. Membership comprises mainly SMEs involved in electroplating, heat treatment, painting and supply companies to these industries.
Membership represents between 50 to 95% of global turnover of these sectors.
This sector represents 3% of the global turnover of mechanical industry, first industrial sector in France. Mechanic can’t work without metal finishing, every part of a car, plane, electronic products,domestic equipment and so on is treated. There is no any sector not impacted by metal finishing.
Metal finishing insures high level performance and is a major contributor of sustainable development. Metal finishing saves raw materials (aluminum, steel, titanium and other metal, plastics…) and energy, increasing life expectancy of the treated parts.
For these results metal finishing uses process including substances of very high concern, but these are always used in a controlled environment by industry and official experts. Process used allows very high protection of workers, consumers and environment.
Statistics published by French environment industry through the BARPI (bureau of accident, repression and industrial pollution) shows that metal finishing has a very poor impact (less than 2%) on accident and pollution. Statistics shows also that the number of recorded cases of occupational disease caused by CMR substances are very poor. In case of chromium six, number of recognized lung cancer since 50 years is widely below back ground level.
That point (article 58.2) and other consideration (synthesis intermediary) not taken into account, normally would have avoided this authorization procedure.
Analysis of alternatives and regulation in France.
Alternatives have been clearly described by others contributors, i.e. SEA.Uits agrees their documents.
Replacement of chromium six have been taken in account since many years in France as in other countries. Research program begun in 70’, none succeeded.
UITS carried several R and D program, at French, European and Worldwide level.
The main program is “Echochrom” (IMS). The result obtained are not really satisfying. Even it is possible to plate parts with chromium 3 instead of chromium 6 for decorative purpose, physical properties didn’t met all the requirements.
“Chromatex”, program of evaluation of alternatives for passivation, concern ELV and RoHs directives. The transposition to aeronautic industry is not satisfying, depending of the grade of the substrate.
“Ionmet”, evaluation of new electroplating system lowering the concentration of substances, uses very toxic solvent.
To face this technical and financial impossibility for substitution in 99% of cases, a very strong regulation is set up for safety and environment, for the use of chromium six compounds.
Every plant is checked once a year by nominated agents of different ministry.
DREAL (ministry of environment) checks air and water effluents, emission values are very low.
CRAM (ministry of health), health and safety executive (ministry of labor) checks level of concentration of substances into the factory and exposure level to the workers. In France authorized professional limit value is maximum 1 microgram by cubic meter since July 2014, (previously it was 50). Every year blood and urine tests are underway on the workers, whatever the size of the company.
Statistics carried out by Uits on 35 companies (in house and job shop platers) confirm that.
All these regulations ensure that high level of security.
In conclusion use of chromium six under control allows the development of modern industrial manufacturing. This is very important for European development that authorization is granted. If not, all mechanical using chromium six will be relocated outside.