COMMENTS ON AN ANNEX XV DOSSIER FOR IDENTIFCATION OF A SUBSTANCE AS SVHC AND RESPONSES TO THESE COMMENTS

Substance name:	strontium chromate	
CAS number:	7789-06-2	
EC number:	232-142-6	

Reason of the submission of the Annex XV: CMR
Disclaimer: The European Chemicals Agency is not responsible for the content of this document. The Response to Comments table (RCOM) has been prepared by the competent authority of the Member State preparing the proposal for identification of a Substance of Very High Concern. The comments were received during the public consultation of the Annex XV dossier. RCOM has not been agreed by the Member State Committee nor has the document been modified as a result of MSC discussions.

PART I: Comments and responses to comments on the SVHC proposal and its justification

General comments on the SVHC proposal
Number	Date	Submitted by (name, Organisation/
MSCA)	Comment	Response	
22	2011/04/07	Industry or trade association
Luxembourg	remark: this second message corrects a typo left in comment reference number 858f0f2c-3f0e-4cf0-b60a-b6f73a8c4b47. Please disregard that previous comment and consider the current one.	Please refer to the response provided in part II of this document	
19	2011/04/07	Industry or trade association
Fédération Française de l'Acier
France	The answer commonly prepared by the French Steel Federation (FFA) and the European Coil Coating Association (ECCA) has been submitted by FFA to the French Authorities on September 30th, 2010 in response to the July 29th call. As this answer was mostly based on ECCA data and statistics, it would be preferable to attribute the quotes on page 17, page 25, and page 30 (§7.5.2, 7.6 and 8.2.4 respectively) to ECCA instead of FFA in the definitive version of the Annex XV dossier, even if FFA continues to support these points.
 
This comment is endorsed by both ECCA and FFA.
	Thank you for this information. The current annex XV dossier is the definitive version.	
18	2011/04/07	International organisation
Health and Environment Alliance
Belgium	We support the inclusion of strontium chromate on the candidate list, on the basis of information in the Annex XV dossier.	Thank you for your support	
17	2011/04/07	Industry or trade association, GIFAS
France	See file attached	Thank you for this information. This has already been stated in the annex XV dossier. Volume of strontium chromate used by the European aerospace industry is estimated around 450 tons per year. The delay of substitution has been estimated around 5 to 7 years by the aerospace industry itself, except for running programs that may require more time (in depth discussion with industry may be useful on this topic).	
14	2011/04/07	Company
France	See also:
Comment 14 attachment (Strontium Chromate ANNEX XV  IDENTIFICATION OF THE SVHC FORMAT.pdf).pdf	Thank you for these clarifications on the physicochemical properties which however don’t affect the purpose of the annexe XV dossier.
Regarding comments on uses : 
-	it is already stated in the dossier that the use of strontium chromate in the transportation sector only concerns industrial vehicles (ELV Directive);
-	hazard and risk of alternatives to strontium chromate quoted in the dossier are not assessed; most of them are indeed still under development or assessment and their real implementability is not fully known;
-	strontium chromate is indeed not used for its colouring and hiding properties but nevertheless exhibits such properties; it could thus act as a substitute to lead chromate ;
-	both lead chromate and strontium chromate are used as anticorrosive pigments and may be thus substituted, but not with same efficiency due to their different solubility and properties; 	
11	2011/04/07	International NGO
WWF European Policy Office
Belgium	WWF supports the inclusion of this substance in the candidate list owing to its classification as carcinogen category 1B.	Thank you for your support	
10	2011/04/06	Member State
Norway	The Norwegian CA supports that strontium chromate should be identified as a substance of very high concern and should be included in the Candidate list.	Thank you for your support	
9	2011/04/06	Member State
Netherlands	The NL-CA supports the proposal to include strontium chromate in the candidate list of substances of very high concern.
It can be clearly understood from the Annex XV report that the main concern for workers is at the formulation of strontium chromate in primers for prevention corrosion. Those primers are mostly used in the aerospace industry and for coil coated galvanised steel. Strontium chromate had been used for more applications (paints, boating industry). However, for these uses alternatives were developed and are incorporated nowadays.

The description of the industrial use process should be clearer in the Annex XV report. Focuses on the alternatives for those uses for which no alternatives are available yet and mention the uses already phased out very shortly. It is preferred to add a conclusion at the end of each chapter. 	Thank you for your support. 
As described in the dossier, main concern for workers is not only at the formulation of mixtures (primers, sealants, etc) but also when the mixture is applied on the substrate (painting, brushing, etc.) as well as during the maintenance (sanding, etc. before repainting) especially when such processes are manually implemented (this may exclude modern and well managed coil coating systems if implemented in strictly closed and controlled conditions). 
	
6	2011/04/06	National Authority
Allgemeine Unfallversicherungsanstalt
Austria	We want to establish a grouping concept within the authorisation process and we prefer including the different chromates into the authorisation regime at once. There is no need to differ between each chromate salt within this process. Furthermore there is a great variety of substitutes to Cr(VI) salts on the market. Partly already proven as a suitable less dangerous alternative.

In EU the strontium chromate use may rise because other Cr(VI) salts are already on the candidate list. Thus to reduce the consumption and use of chromates and dichromates in total strontium chromate shall be regulated as soon as possible.
	Thank you for your support. 
We also support a grouping approach between Cr(VI) salts but we highlight the need to group them regarding their physicochemical properties and their uses, that is to say according to their ability to be efficiently substituted for each others. 	
5	2011/04/05	Member State
Belgium	Belgium supports the identification of Strontium chromate as SVHC according to article 57(a). 	Thank you for your support. 
	
4	2011/04/05	Member State
Sweden	The Swedish CA agrees that strontium chromate, being classified as Carc. 1B, meets the criteria according to Article 57(a) in REACH and is thus eligible for identification as a substance of very high concern.	Thank you for your comment. 
	
2	2011/04/04	Member State
Germany	The German CA supports the inclusion of the substance into the candidate list.

Comments to the IUCLID File:

- 1.2 composition: No Smiles and InChI code is given for the reference substance strontium chromate. 
- 1.2 composition: Sodium is stated as an impurity. However, it can be assumed that not elemental sodium is present as an impurity, but the sodium ion (Na+). Furthermore, the given Smiles and InChI codes are for NaH and not for Na or Na+. 
- 1.2 composition: Bariumchromate is stated as an impurity. No molecular weight, Smiles or InChI code is given in the IUCLID file.
- 4 physical and chemical properties: Next to the pure value for the physical chemical property no further information (like reference source, reliability, guideline, whether a study was conducted or whether the results were calculated or taken from literature) is given. Without any further information the data cannot be evaluated. Please add all information about e.g. reference, method, if available. 
	Thank you for your support and for these comments. 

1	2011/03/15	Trade union
European Trade Union Confederation
Belgium	ETUC supports the identification of strontium chromate as a SVHC.	Thank you for your support. 

Specific comments on the justification
Number	Date	Submitted by (name, Organisation/
MSCA)	Comment	Response	
14	2011/04/07	Company
France	see file attached	Please refer to the response provided in the previous chapter. Comments do not affect the identification of strontium chromate as SVHC. 	
			See also:
Comment 14 attachment (Strontium Chromate ANNEX XV  IDENTIFICATION OF THE SVHC FORMAT.pdf).pdf		
9	2011/04/06	Member State
Netherlands	It should be noted, that in the Annex XV report relevant toxicological information is based on the hexavalent chromate compounds. Specific information about strontium chromate is not available. Because strontium chromate belongs to the Cr(IV) compounds this is accepted.	Thank you for your comment. 	
3	2011/04/04	Member State
Ireland	Strontium chromate is classified as Carc. 1B according to Regulation EC No. 1272/2008, and therefore the Irish CA agrees that the substance meets the criteria for identification as an SVHC in accordance with Article 57 (a) of REACH.	Thank you for your support. 
	
1	2011/03/15	Trade union
European Trade Union Confederation
Belgium	Strontium chromate is included in the Trade Union Priority List for REACH authorisation.
See http://www.etuc.org/a/6023	Thank you for your comment.	

PART II: Comments and responses to comments on uses, exposures, alternatives and risks

Specific comments on use, exposure, alternatives and risks
Number	Date	Submitted by (name, Organisation/
MSCA)	Comment	Response	
22	2011/04/07	Industry or trade association

Luxembourg	Coil coating use of strontium chromate

In addition to the comments that FFA and ECCA have sent during this consultation, we can highlight some of the advantages of the use of strontium chromate pigments that were not reflected in the Annex XV dossier:
* the longer in-use lifecycle of coated products with strontium-chromate containing primers allow for a reduced need for repainting the coated products, hence a reduction in the global use of chemicals and emissions of volatile organic compounds. The longer lifecycle of the coated products also results on a reduced pressure on natural resources used to manufacture the metallic underlying product.
* the steel coated products lifecycle is closed - those products are remelted in steel shops and during those operations, the hexavalent chromium compounds still contained in the primers are reduced to metallic and trivalent chromium which is incorporated in the recycled steel matrix.

The adverse effects on human health and the environment linked with the use of this substance or its presence in finished products are well controlled:
* R&D lixiviation studies on steel sheets coated with strontium chromate containing primers and protected by a top coat finish exposed to rain have demonstrated the very low levels of hexavalent chromium releases and effective barrier effect of the top coat in those paint systems. Those results have been published and presented at congresses.
* Existing national and european occupational health regulation are already strictly governing the use of hexavalent chromium substances and worker exposure in continuous processes as coil coating is minimized through series of procedural and technical means.  
	Thank you for your comment and the additional information. 

Regarding the specific comment on the adverse effects: as stated in the annex XV dossier, exposure to strontium chromate concerns more workers than consumers or the environment. 	
20	2011/04/07	Industry or trade association
Aerospace Industry Association
United States	This letter of comments replaces the document sent at 12:03 today.	Thank you for these comments which complete the substitution state of play carried out within the United states aerospace sector and which underline the main remaining issues.

We highlight however the difficulty to get within the aerospace sector a well explained and detailed picture of the substitution progress for main applications (main success, main failures, etc. especially regarding the so called safety specifications required).

We may understand from your contribution that 
-	substitution succeeds case by case in some applications but also fails for some others, for instance adhesive bond primers for aluminium applications; 
-	substitution in exterior primers seems to be on a good way and may be available in around 5 years (as a minimum)
-	substitution in interior primers is not and won’t be available at short term.	
			See also:
Comment 20 attachment (AIA Comments on Strontium Chromate Dossier.pdf).pdf		
15	2011/04/07	Industry or trade association
European Coil Coating Association
Belgium	p. 28 “Substitution solutions are not universal and shall be developed on a case by case basis. But generally most issues raised by industry appear to be due to additional costs, delays of implementation / industrialisation, testing, certification of new alternatives, etc. than to a real technical impossibility to substitute.”

Complementary comment:
We do not agree that substitution of chromates would be mainly a cost issue. Substitutes are indeed available, but their performance is currently not at the same level as with strontium chromate. For High Performance building markets where the lifetime expectations are up to 40-50 years, chromates are still vital in order to be able to guarantee the desired performance. For these types of applications, coated products containing chromates will most probably still be specified and hence continue to be used in the future resulting in European suppliers losing markets to the benefit of (articles) importers into the EU. European produces will also lose export markets as the producers will be unable to meet the similar demanding applications outside the EU.	Thank you for your comment.

We highlight the difficulty to get within the coil coating sector a well explained and detailed picture of the substitution program and progress for main outdoor applications which appears to be the remaining issue (main success, main failures, time line and expected time for complete substitution, etc.).	
9	2011/04/06	Member State
Netherlands	It is clear from the Annex XV report that research program are running for alternatives in the aerospace industry and for coil coating applications, but are not yet finished. The possible risks of these alternatives are not described or mentioned.	Thank you for your comment.
 	
8	2011/04/06	Industry or trade association
United Kingdom	There is significant disagreement with the notion that Strontium Chromate has alternatives for any current use. Many safety critical uses do not have safe alternatives in the Aerospace , space and defence industries.	Thank you for your comment.

We may understand from your contribution that remaining issues concern basic primers and bonding primers. 

We highlight however the difficulty to get within the aerospace sector a well explained and detailed picture of the substitution progress for main applications (main success, main failures, etc. especially regarding the safety specifications required), including an estimated time line for complete substitution. 
	
			See also:
Comment 8 attachment (ADS Response to SrCr dossier.pdf).pdf		
7	2011/04/06	Industry or trade association
European Coil Coating Association
Belgium	p. 27 “These chrome-free primers have performed well during accelerated corrosion testing, as well as real world exposure conditions. They have demonstrated their ability to perform comparably to chromated primers over currently used military conversion coatings, anodized films, and aluminium alloys”

Comment: To our knowledge, there is still no accelerated corrosion test that would reliably predict the performance of a coating system in real world conditions. Therefore, extensive outdoor testing is required in order to prove the level of corrosion protection of a certain paint system. Moreover, each combination of substrate, pre-treatment, and paint is unique and no universal conclusions can be drawn based on testing of one system. Before being able to draw such a conclusion, it is important to have more information on what kind of outdoor testing has been performed; in what kind of environment and for how long.

p. 27 “The present commercial arsenal of corrosion inhibitor pigments shows that a non-toxic alternative to strontium chromate may be of low cost and as effective”

Comment: This might be true for many applications and markets in Europe, but not for all and certainly not for the most demanding outdoor building applications. In certain coastal areas having a very corrosive environment there are no substitutes that would match the performance of chromates in corrosion protection. Moreover, low-cost for one industry does not necessarily mean that it’s low cost for all the other industries.

p. 28 “Substitution solutions are not universal and shall be developed on a case by case basis. But generally most issues raised by industry appear to be due to additional costs, delays of implementation / industrialisation, testing, certification of new alternatives, etc. than to a real technical impossibility to substitute.”

Comment: We do not agree that substitution of chromates would be mainly a cost issue. Substitutes are indeed available, but their performance is currently not at the same level as with strontium chromate. For High Performance building markets where the lifetime expectations are up to 40-50 years, chromates are still vital in order to be able to guarantee the desired performance. For these applications, chromates will most probably continue to be used in the future, meaning that the European suppliers will lose markets to the benefit of (articles) importers.

p. 28 Chapter 8.2.2 Economic Issue

Comment: Cost savings on safety measures gained by elimination of chromates are overstated. Since chromates can still be found in building materials all over Europe, all waste and recycled material will still have to be treated as if they contained chromates. Buildings can be constructed of mixed materials (chromate-containing and chromate-free), older buildings or those built with imported material in the future will still contain chromates. Thus, the safety measures will need to be extensive even if the total amount of chromates was reduced at European level. Moreover, coil coating lines in Europe are very well controlled and the exposure of employees to chromates is pretty much prevented. Getting rid of chromates is not likely to lead to lower safety measures since the substitutes are also chemicals and require specific handling. It is highly unlikely that any cost savings possibly generated from converting to chromate-free substitutes e.g. by reducing safety measures would be passed on to private or commercial sectors.
It should also be taken into account that the long lifetime of chromate containing building materials will lead to less repainting and repairing, thus saving money and natural resources which is beneficial for the environment.

p. 30 “On the basis of current technology, substituting to chromate-free primers into outdoor used coil coated products which need high corrosion protection may reduce their life expectancy, possibly causing premature failures, reducing the long-term value of buildings on which these products are used.”

Comment: Substituting chromates in the premium exterior products WILL for sure reduce the life-time expectancy of buildings. 

p. 30 “According to RPA (2005), strontium chromate use in coil coatings was successfully abandoned in the mid 1990s and now practically all coil coating lines in Italy do not use primers containing the substance”.

Comment: This is true for the Italian market, but the technical requirements and commercial practices in one area are not applicable nor feasible all over Europe	Thank you for your comment.

We highlight the difficulty to get within the coil coating sector a well explained and detailed picture of the substitution program and progress for main outdoor applications which appears to be the remaining issue (main success, main failures, time line and expected delay of complete substitution, etc.).	
6	2011/04/06	National Authority
Allgemeine Unfallversicherungsanstalt
Austria	Having a look into the listed registered substances PROC 5 (Mixing or blending in batch processes for formulation of preparations and articles (multistage and/or significant contact)), PC 1 (Adhesives, sealants) and PC 9a (Coatings and paints, thinners, paint removes) are part of an identified use. This indicates wide and dispersive use for this substance.

p20, para 3, Annex XV dossier
Strontium chromate can also be used in less exposing forms than powders. This shall be kept in mind if any authorisation is granted. If any, only uses as a paste, slurry or dispersion shall be granted.

p24, para 4, Annex XV dossier:
“Strontium chromate is one of the components of an artist paint called “baryte green” which is manufactured and sold by a French company. This paint contains barium chromate, strontium chromate and phtalocyanine. However, according to CEPE, the German artist colour manufacturer VDMI (Verband der Mineralfarbenindustrie) doesn’t use strontium chromate.”
We cannot see the different requirements between German or French artists. Thus we support that there shall be no exemptions or granted authorisations concerning artists paints.

p32, 9.2 Risk assessment from scientific committees on occupational exposure limits, Annex XV dossier
Here a study is cited that states that even a cancer risk of 1 to 100 is very difficult to under-run at the workplace using chromate salts. This shows the urgency of changing to suitable alternatives!
	Thank you for your comment. 	
2	2011/04/04	Member State
Germany	Exposure information:
The German CA appreciates the inclusion of recent occupational exposure data.	Thank you for your comment.	
1	2011/03/15	Trade union
European Trade Union Confederation
Belgium	Strontion chromate is among the substances or group of substances related with recognised occupational diseases.
See page 36 of the guide to diagnosis of occupational diseases published by the EU Commission:
http://www.beroepsziekten.nl/sites/default/files/documents/Information-Notices-2009.pdf	Thank you for your comment.	

Attachments

Comment number	Public attachment	Confidential attachment	
8	
Comment 8 attachment (ADS Response to SrCr dossier.pdf).pdf		
12	
Comment 12 attachment (20013-2011- ECHA_Gifas-Strontium chromate.pdf).pdf		
14	
Comment 14 attachment (Strontium Chromate ANNEX XV  IDENTIFICATION OF THE SVHC FORMAT.pdf).pdf		
17	
Comment 17 attachment (20013-2011- ECHA_Gifas-Strontium chromate (4).pdf).pdf		
20	
Comment 20 attachment (AIA Comments on Strontium Chromate Dossier.pdf).pdf