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European surface treatment update
Thursday, 27 April 2006 00:00

Dr Paul Lansdell provided the following report of the CETS meeting in September 2005. This article first appeared in 'transactions' of the IMF

BREF document

This document s now complete and was published n October 2005: available at http //elppcb.jrc.es/pages/ FActivities.htm or via the link on the IMF website

Although the IPPC legislation is already enacted and companies had to register under its provisions during 2004 the guidance document is now complete. The relative health and safety plus environmental authorities across Europe are now looking to implement the recommendations contained in the document. The introduction of BAT (Best Available Techniques) outlined in the BREF document is planned to be complete by 2007

In Italy and The Netherlands the metal finishing companies affected by the IPPC legislation are holding pro-active discussion meetings with their relevant enforcement bodies over the interpretation of the BREF guidelines. It is the intention, through the SEA, to try to set up similar talks with interested parties in the UK.

Hexavalent chromium reclassification

The change in classification of hexavalent chromium as T+ `very toxic' has reduced the total amount of chemical required on site to bring the operation within tire COMAH legislation, from 20 tonnes of hexavalent chromium material to 5 tonnes. This has required a number of businesses in all European countries to register and comply with the lower tier COMAH requirements.

Under the control legislation for very toxic materials, if specific data are not available there is a default dilution level which is applied to solutions of the specific chemical under consideration, and dilutions down to this level will be presumed to be very toxic; unless specific studies have demonstrated otherwise. This dilution level has been set at 7% in the case of very toxic chemicals. Thus, all chromic acid plating solutions in theory should be regarded as `very toxic'.

However, the French, through Airbus, have carried out toxicity trials on plating solutions at up to 400 g L-1 concentrations. These tests have shown that through inhalation these preparations are only toxic, not 'very toxic', even at the high levels of chromium content. This is thought to be due to the chemical change when the anhydrous Cr2O3 Is dissolved in water. Thus, the automatic presumption that dilutions of this chemical down to 7% would continue to be 'very toxic' is not correct.

EU legislation states that this study information should be used to set the status of the material where hard data are available, instead of following the simple dilution rules. Although the French government is prepared to change its requirements, at present no other EU government is prepared to take the information on board, and a number are demanding further studies before they will consider a change.

The French metal finishing industry, through Airbus, is continuing the work to establish the true position of hexavalent chromium plating solutions.

REACH

Much political lobbying going on at the moment, and some significant changes in the approach to metals under REACH are currently being proposed. There is a UK Metals Industry REACH Group, for which the Non-Ferrous Alliance (i.e. Annelli) provides the secretariat; the chairman is Dr Ivor Kidman, who is president of the Nickel Institute, and also co-chairman of the Eurometaux REACH Project Team This lobbying was expected to be complete by the end of 2005; once a better understanding is gained of exactly what is expected of the metals industry under REACH, it will be easier to identify what the consequences will be.

All affected industries must lobby their respective trade associations to get involved in REACH and its impact on their businesses. It is imperative that MEPs understand the issues with regard to categorisation of metal alloys under the present proposals.

It is also important to get across the message that potentially there will be a significant loss of expensive, complex chemical substances for which there are no viable alternatives; these will riot be registered under REACH because the returns from small quantity, expensive production runs will riot justify the cost of registration. Their absence will have a cascade effect downstream either on the viability of secondary processes reliant on these materials, or on the safety risks of others because control chemicals are now not available

Infinite recyclability

The Italian metal finishing industry (Association Galvanica) has set up a registration scheme that allows businesses to sign up for the right to use a recognisable recyclability logo for their products. The logo demonstrates that the materials used in the manufacture of an article are recyclable and do not deplete the world's resources, and also that the product was manufactured using processes best suited to maintaining the best environmental conditions.

The acceptability of this logo is increasing in Italy and a further report on the growing success of the initiative will be given at the next meeting

Continued use of PHOS

Despite the representations of the UK Health and Safety Executive and the Environmental Agency to UK legislators on the continued use of PHOS as a mist suppressant in chromium plating baths, the EU Commission has decided that the importance of this decision is such that it alone will be able to make the definitive decision for the EU. As such, it has informed the UK Government that a decision will be made at some date in the future on the continued use of PHOS. There is no indication when this will be.

Trichloroethylene solvents

The UK legislators have concluded that current legislation with regard to this material is sufficient to manage its ongoing use, and are not proposing further control measures.

Risk reduction strategy for hexavalent chromium

A huge amount of work has been carried out by the SEA, the manufacturers of chromium chemicals, and various representatives of the chromium user industries to ensure a full understanding of how current chromium users are legislated, controlled by emissions limits and policed.  This has all culminated in a recognition of just how much control goes into the legitimate use of these chemicals

The report on the environmental impact commissioned by the UK Government through DEFRA, forwarded to the EU legislators during November, is seen as a final draft on the situation. The report has moved to stage 4 of the process and recommends that current controls for the manufacturing of hexavalent chromium chemicals and their subsequent use in manufacturing processes are adequate for managing the environmental impact of this material.

Information on these activities is available on the DEFRA website (www.defra.gov.uk )

Nickel risk assessment

Over the last few years a considerable amount of research has been carried out with regard to the potential effect of nickel and nickel compounds on the human body. This has been led by the Danes, who are the European Rapporteur for nickel metal.

The outcome of all this work was presented to interested industrial bodies at a seminar held in London during September. The information presented was effectively the detailed outcome of the studies and forms the basis of the recommendation going forward from the Danish authorities to the EU It is from these data that the regulators are expected to draft legislation relative to the control of exposure to such substances for use in industry.

The classifications and an explanation of the risk and safety phrases used in the document are summarised in Table 1.

The outcome is that the forms of nickel important to the plating industry, found in daily use for decorative nickel and chromium finishes, are now classified as:

• Toxic by inhalation

• Toxic if swallowed

• Skin sensitisers and irritants

• Respiratory sensitiser

• Chronic toxicant

• Class 1 carcinogens

• Class 2 reproductive toxicants

• Class 3 mutagens.

Nickel chloride is identified as the most dangerous, but information from the tests has indicated that nickel sulphate very nearly fell into the same categories as nickel chloride, and as such each should be treated with the same caution. Nickel hydroxide, which is produced in waste water treatment plants, was not found to be so dangerous, but nonetheless should be treated with caution. Metallic nickel is still seen as a skin sensitiser but does not produce the same problems as the soluble salts of nickel.

The effect of this is that plating plant operations will have to review the operation of all processes, develop new methods of operation and minimise the risk of exposure. This will result in alternative means of operating in some instances and will require a positive change to some maintenance activities, particularly with regard to chemical additions.

Although this will not become legislation before the end of next year, changes should be implemented as soon as they have been identified and ratified and the new risk assessments for the operations completed

Furthermore, because the toxic classification of the soluble nickel salts extends down to very low concentrations, the drag as well as the plating solutions are classified as toxic. Thus, plating and drag-out solutions will have to be considered with any other materials covered by the COMAH legislation.

Under this legislation, anyone with more than 50 tonnes of nickel plating solution and drag out will automatically classify in the lower tier of COMAH. Unfortunately, it is not this easy, as the COMAH legislation encompasses a range of materials: advice or information should be sought from the legislation guidance notes or the SEA as to how to calculate the proportionate amount of each material that combines, to stipulate how much of the various materials on site add up to the total COMAH liability.

 

 
 

Finishing Classifieds