REACH - Chromates authorization decisions : Which impacts and solutions for the end user?

Decisions for REACH authorization of several uses of Chromium have been adopted. Explanation on this note.

The full content of these decisions can be viewed on the commission's website : here.

The regulation situation at a glance:

The European Commission has added substances containing chromates to the list of substances subject to authorization in Annex XIV to the REACH Regulation. The placing on the market and use of these substances will be banned passed the "sunset date" unless an authorization granted for a limited period on the uses specifically defined.

Manufacturers or importers in Europe have grouped into 3 consortia to defend uses reported by end users and have submitted authorization files. the European Commission's decisions were published in the EU Official Journal, they grant a derogatory term of 7 years from the Sunset Date in respect of the uses covered by authorization dossiers.

WHAT SUBSTANCES ARE COVERED?

Chromium trioxide (n° CAS : 1333-82-0)
Sodium dichromate (n° CAS: 7789-12-0 ; 10588-01-9)
Potassium dichromate (n° CAS : 7778-50-9)
Strontium chromate (n° CAS: 7789-06-2)
Tri(chromate) de dichrome (n° CAS : 24613-89-6)
Pentazinc chromate octahydroxide (n° CAS : 49663-84-5)
Potassium hydroxyoctaoxodizincatedichromate (n° CAS : 11103-86-9)

WHAT TO DO AS A END USER?

Given the lack of qualified alternative solutions, a business user of any substance or mixture containers, will be covered by these authorizations and will have to:

Comply with the exposure scenarios provided in the extended Safety Data Sheets updated by their chemical suppliers within 3 months of the authorization decisions.
Notify ECHA of their authorized use in accordance with Article 66 of REACH within 3 months of the first delivery of the substance / mixture after the publication of the authorization decisions.
Initiate first employee exposure measures no later than 6 months after the date of the authorization decision and submit these results to ECHA annually.
Perform measurements on environmental releases and submit these results to ECHA annually.

To go further, please find the detailed information note from GIFAS: click here

Tips and best practices:

E-CHEMICALS - THE ONLINE TOOL THAT CAN HELP YOU THROUGH THE PROCESS

Clic here to know more about your free access to the platform and discover the entire functionalities.

How to know which product is affected by the substance included in Annex XIV?

Access the list of all substances included in regulatory lists, including Annex XIV.

Find out which product of your portfolio is impacted by these substances and on which sunset date.

Measurements and traceability of occupational exposure?

1- Traceability of occupational exposure :

Materialize the tree structure of your entity and associate the products used in it.

You will thus have the overview of all the places where products containing substances listed in Annex XIV are used and you will be able to easily link the operators who are exposed to them.

2- Prevention measures:

With our Simplified Safety Data Sheet editing tools, display the safety and health measures to be taken at operator's workstations when handling products impacted by a substances listed in Annex XIV.

Where to find the exposure scenarios?

End users must comply with the exposure scenarios described by the manufacturers in the Safety Data Sheets of products containing substances included in regulatory lists.

You will find all of the SDSs in your product catalog on the platform. In addition, Gaches Chimie sends alert emails to each new version of the SDS and highlights the modifications made by the manufacturers.

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YOU CAN RELY ON GACHES CHIMIE SUPPORT

Gaches Chimie as distributor distributes the updated SDS to you with:

adding authorization numbers,
updates to the Exposure Scenarios in accordance with the risk control measures taken from the authorization files.

We will also relay communications from suppliers to you, and will remain at your disposal to complete any questionnaires of commitment to "use the products in accordance with the Exhibition Scenarios" of manufacturers who may require the return of the questionnaire before agreeing to deliver the products concerned.

Gaches Chimie, agrees to share with its customers the steps to be taken for certain product uses that would be common with its customers.