REACH Authorization from a formulators perspective. December 2 nd, 2013

Transcription

1 REACH Authorization from a formulators perspective December 2 nd, 2013

2 Preparation for REACH authorization of SrCrO 4 by a paint formulator Content: 1. Introduction and some history 2. Preparation for the authorization 3. Practical considerations 4. The use in our own facility: formulation of paint 5. Downstream use 6. Summary and conclusions 2

3 Introduction In the coatings industry strontium - and zinc chromate have been used for many years as pigments in anticorrosive paints. Because of their health hazard, replacement projects have been carried out since the late 80-s In spite of a significant decline in the number of such products, there appears to be some uses where replacement is not possible Under REACH, strontium - and zinc chromate qualify (Article 57) for inclusion in the list of SVHC s This means that the use of such materials will in the end be restricted under an Authorization or Restriction, or these chromates will disappear from the EU 3

4 History Chromate containing primers were used in many sectors where metal surface needs protection against corrosion Some sectors which have used chromates: Automotive paints, Automotive refinish, Coil coating, Can coating, Aerospace coatings, Protective Coatings In most sectors there appear to be alternatives. Some took over completely; in other sectors a mix can be found of chrome-free and chrome containing, But for Aerospace Coatings there have not been any replacements so far, that generally meet the specifications set by the industry. 4

5 Preparation for the authorization At the end of 2012 it became clear that Cr (VI) compounds were included in Annex XIV of REACH. Consortia were created to prepare for the authorizations (CTAC, CCST, etc.) The problem for formulators of Aerospace Coatings was that the uses that the consortia had defined, were so broad that the chances on authorization would decrease (availability of alternatives in some segments) By April 2013 this was clarified and all EU formulators of anticorrosive primers for Aerospace constructions joined the consortium CCST 5

6 REACH Authorization in a supply chain Some practical considerations 6

7 Supply chain considerations (3/3) M/I (applicant) M/I = immediate supplier without use M/I = supplier without use Formulator 1 Formulator 1 (applicant) Formulator 1 Formulator 2 Formulator 2 Formulator 2 (applicant) End-user End-user End-user 18 December 2013 echa.europa.eu 7

8 Preparation for the authorization For Strontium chromate two uses are defined in CCST Use A: the application of the products (iii) application of paints, primers, sealants, lacquers and coatings (including as wash primers) containing Strontium chromate in the construction of aerospace and aeronautical parts, including aeroplanes / helicopters, space craft, satellites, launchers, engines, and for the maintenance of such constructions. Use B: the manufacturing (formulation) of the products (iv) formulation of mixtures for Use (iii) except on-site formulation for Use (iii) which is considered to be covered by Use (iii). The manufacturing of the chromate pigment as such doesn t require authorization; the use downstream does. 8

9 Todays strontium chromate situation M/I (applicant) M/I = immediate supplier without use M/I = immediate supplier with use M/I = supplier without use Formulator Formulator (applicant) Formulator (applicant) Formulator DU Painter DU Painter DU-painter DU-painter (applicant) (applicant) Formulators may or may not have included their DU Some DU s may go for Authorization, but they don t know what their supplier does 9

10 Uses under the REACH Authorization Use (iv) The Paint Manufacturing Process 10

11 The paint manufacturing process The paint manufacturing steps are: Receipt of raw materials, warehousing and delivery to the plant Premixing of powders in a mixture of binders (polymers) and solvents Milling. Closed bead mill for de-agglomeration of wetted pigment powders into fine dispersions Letdown. Addition of more binders solvents and additives to the dispersions. Filtration and filling into containers Cleaning of the equipment 11

12 The chromate unit for formulators Raw material storage, premixing or wetting unit. double locked workplace Small group of trained workers Disposable protective clothing Exit through the shower 12

13 Bead milling device Formulators have supplied information on the exposure during the manufacturing process in the various sub-steps Details on the Risk Assessments have been provided For the Analysis of Alternatives, the participating formulators have supplied their information Details needed for Socio Economic Analysis have been submitted Details on the supply chain have been collected 13

14 Uses under the REACH Authorization Use (iii) The Application of the Coatings for Aerospace constructions 14

15 The Application of the Coatings for Aerospace constructions For the application of paints, primers, sealants, lacquers and coatings (including as wash primers) containing Strontium chromate in the construction of aerospace and aeronautical parts, including aeroplanes / helicopters, space craft, satellites, launchers, engines, and for the maintenance of such constructions, coatings manufacturers may not have all the detailed information required for the authorization but from the 29 participants in the consortium there should be enough information becoming available to get that use authorized as well. 15

16 Summary and Conclusions 16

17 Summary and Conclusions The preparation for the submission of Authorization applications for strontium chromate, used as an anticorrosive pigment in coatings for the aerospace construction industry, is well underway. IP, BCI and Competition compliance can be set up quite well in a consortium and an external consultant that does the work Chances that the Authorization will be obtained look pretty good. Disruptions in the supply chain should not happen. Having an own DU authorization may not be enough. The DU should know what their suppliers (formulators) are preparing 17

18 Thank you for your attention.