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The European Chemicals Agency (ECHA) has included Sodium chromate, Potassium chromate and Potassium dichromate in the candidate list of Substances of Very High Concern (SVHC), effective from 18 June 2010.
Sodium dichromate is already a listed candidate as SVHC material since 28th October 2008.
Inclusion in the candidate list is relevant to the following products of our delivery program:
| 060601 | SIL AFT Salt |
| 090303 | METAPAS Concentrate olive |
| 090301 | METAPAS Salt yellow |
| 065328 | Umicore ANTITARNISH 328 make up salt |
The stated substances are used for the manufacture of chromating solutions for post treatment of Silver Zinc or Zinc alloy coatings. During the chromating reaction chromates are integrated in the chromate layer. It is therefore necessary to check whether there is a duty of notification according to article 33 of Directive 1907/2006/EC (REACH Directive). We must point out there are a variety of Cr(VI) free post treatment processes which are available, and in most cases are substitutes for the Cr(VI) containing processes.
There is the duty of notification when the manufactured item contains 0.1% by weight or more of a SVHC product. Chromated layers can have a layer of weight up to 2 g/m² and contain up to 20% by weight of chromate, calculated as Chrome trioxide. As the limit value of 0.1% by weight refers to the whole manufacture item and not to the chromate layer on its own, it is difficult to predict whether the limit value of 0.1% by weight is reached or exceeded.
A sheet plate of steel with a dimension of 1000 x 1000 x 2 mm has a volume of 2000 cm³ and thus a mass of 15,720 g and a surface of 2.008 m². The weight per unit area of the chromating layer is therefore approx. 4 g and the proportional chromate is 0.8 g. Calculating to the total weight this corresponds to a share of 0.005% by weight. The limit value of 0.1% by weight is not reached. It would only be reached when the sheet thickness was only 0.1 mm instead of 2 mm and all other dimensions remain unchanged.
The inclusion of these substances will not create any new obligations for the Schloetter group. These substances were already classified before in Directive 67/548/EWG, Annex 1 with T+, R 45, R 46 and R 60-61. Their inclusion in the SVHC list will not demand any change in the Material Safety Data Sheet.
| T+ = | Very Toxic |
| R 45 = | May cause cancer |
| R 46 = | May cause heritable genetic damage |
| R 60 = | May impair fertility |
| R 61 = | May cause harm to the unborn child |