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Consultation on the draft opinion of the Committee of Socio-economic Analysis (SEAC)

Substance name
Certain chromium(VI) oxides, oxyacids and salts

EC Number
-

CAS Number
-

Scope
Restricting the use of certain chromium (VI) substances.

Before completing the form, please read the Consultation Guidance and the SEAC draft Opinion. Further documents related to the restriction proposal, including the RAC Opinion, the draft Background Document and the Response to comments on the restriction report (R-COM), can be found here. These documents may not be available immediately at the start of the 60-day consultation.
Link to the Consultation Guidance
Link to SEAC draft opinion

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* I have read the Consultation Guidance and SEAC draft opinion Required
All non-confidential comments will be made publicly available once a month during the duration of the consultation.

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Section I.Personal information

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Section II.Organisation

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Section III.Non-confidential comments

It is necessary to provide supporting evidence to allow SEAC Committee to take your comments into account. Please provide your non-confidential comments below. (maximum 63 999 characters)

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General Comments (non-confidential response)

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Specific Information Requests (non-confidential responses)

1: Indicate which UC(s) from the list below your overall comment(s) relate to (please write the UC number(s) separated by semicolons):

UC1: Formulation of mixtures
UC2: Electroplating on plastic substrate
UC3: Electroplating on metal substrate
UC4: Use of primers and other slurry coatings
UC5: Other surface treatments (ETP and others)
UC6: Uses as functional additive/process aid

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Please select mandatory specific question confirmation or if you select specific question confirmation then please fill in the answer.Please select mandatory specific question confirmation or if you select specific question confirmation then please fill in the answer.

2: To which sector(s) does your organisation belong to? (please indicate which sector name(s) apply from the list below, separated by semicolons):

Automotive & Transport Equipment, Aerospace,
Aviation & Defence,
Mechanical Engineering & Industrial Machinery,
Hydraulics & Fluid Systems,
Metal & Steel Industry,
Construction & Civil Engineering,
Mining & Earthmoving,
Marine & Offshore, Energy & Power Generation,
Oil, Gas & Petrochemical,
Chemical Industry,
Plastics, Rubber & Materials Processing,
Paper, Printing & Converting,
Textile & Ceramic Industries,
Food & Beverage Industry,
Pharmaceutical, Medical & Healthcare,
Cosmetics, Perfumery & Personal Care,
Household Appliances & Consumer Goods,
Sanitary, Bathroom & Kitchen Equipment,
Furniture, Wood & Interior Products, Precision Engineering & Tooling,
Packaging Industry,
Electronics & Electrical Equipment,
Heating & Thermal Systems / Gas Appliances,
Agriculture & Forestry,
Architecture & Building Fittings,
Workshop, Maintenance & Industrial Services,
Cable Transport Systems
Other

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3: Transition period:

Please comment on the proposed transition period of 18 months in relation to the different options assessed by SEAC. For each of the options below, respond to the following: Is this transition period feasible for you with regard to limit value for workers (LV) and emission limit values (ELVs)? if not, please indicate which limit value is most problematic (i.e. LV and/or ELV) and specify a more realistic duration of the transition period. Please provide a clear justification and evidence to underpin your answers separately for:

… RO2 (see table 4 in section 3.4.2 of the SEAC draft opinion)

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4: … RO3 (see table 4 in section 3.4.2 of the SEAC draft opinion)

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5: … a LV for workers’ exposure of 1 µg/m³ that is the same for all UCs

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6: … a LV for workers’ exposure of 0.5 µg/m³ that is the same for all UCs

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7: … a LV for workers’ exposure of 0.1 µg/m³ that is the same for all UCs

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8: To comply with the restriction, some companies may need to improve their risk management measures (RMMs). The proportion of companies expected to do so may be different depending on the limit value. What transition periods would be required in each restriction option so that the suppliers of improved RMM equipment and services are able to handle the increase in demand? Please provide a clear justification and evidence to underpin your answers.

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9: Maximum release factors (MRFs) for emissions to air as an alternative way to demonstrate compliance, instead of ELVs:

In this option analysed by the Dossier Submitter (AO5), installations that cannot comply with the ELV for air emissions may alternatively demonstrate compliance with a MRF of 0.1 % (instead of 2.5 kg/Cr(VI)/year in RO1) or 0.01 % (instead of 0.25 kg/Cr(VI)/year in RO2).

If you expect to close or relocate because you will not be able to comply with the ELVs, would it be possible for you to instead comply with a maximum release factor (MRF) of

0.01% or
0.1%?

Would the possibility of complying with an MRF change your plans for closure or relocation?
Please describe the impact of AO5 in terms of compliance costs.

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10: RAC proposal:

RAC proposes emission limit values of 0.15 kg Cr(VI)/year for water emissions and 0.25 kg Cr(VI)/year for air emissions; and a limit value for workers’ exposure of 0.1 µg/m³ that shall not be exceeded on any day of the year, and that must be implemented following the hierarchy of control measures (workers can be protected by respiratory protective equipment as a temporary measure, only if other options (i.e. engineering and administrative RMMs) have been fully exhausted and are still not sufficient).

What would be the impact of this restriction option on your company/sector? Please provide information on the type of technical changes that would be required to comply with such an option for your company/sector and the associated costs.

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11: In the consultation on the Annex XV dossier, for certain uses of barium chromate (e.g. pyrotechnic delay compositions), it was claimed that safety concerns would limit the possibilities to implement effective ventilation to comply with the limit values for workers in all the restriction options. Please provide more information on whether there are alternative risk management measures that could be used to comply. What are the cost implications of these measures?

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12: Comments on each section of the SEAC draft opinion:

In case you wish to comment on Section 1.2. ‘SEAC opinion’, please provide the comments here.

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13: In case you wish to comment on Section 2.2.2. ‘SEAC opinion summary’, please provide the comments here.

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14: In case you wish to comment on Section 3.2. ‘Justification that action is required on a Union wide basis’, please provide the comments here.

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15: In case you wish to comment on Section 3.3.1. ‘Availability and technical and economic feasibility of alternatives’, please provide the comments here.

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16: In case you wish to comment on Section 3.4.1. ‘Regulatory risk management options other than restriction’, please provide the comments here.

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17: In case you wish to comment on Section 3.4.2.2. ‘Definition of the baseline’, please provide the comments here.

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18: In case you wish to comment on Section 3.4.2.2.1. ‘Costs’, please provide the comments here.

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19: In case you wish to comment on Section 3.4.2.2.2. ‘Benefits’, please provide the comments here.

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20: In case you wish to comment on Section 3.4.2.2.3. ‘Other relevant impacts’, please provide the comments here.

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21: In case you wish to comment on Section 3.4.2.2.4 ‘Proportionality’, please provide the comments here.

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22: In case you wish to comment on Section 3.4.2.3. ‘Practicality, including enforceability’, please provide the comments here.

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23: In case you wish to comment on Section 3.4.2.4. ‘Monitorability’, please provide the comments here.

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24: In case you wish to comment on Section 3.4.3. ‘Conclusion whether the suggested restriction is the most appropriate EU-wide measure’, please provide the comments here.

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25: In case you wish to comment on Section 3.5.2. ‘Uncertainties evaluated by SEAC’, please provide the comments here.

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26: In case you wish to comment on ANNEX I. ‘SEAC box on calculation of non-use costs’, please provide the comments here.

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27: In case you wish to comment on ANNEX II. ‘Summary of the information on technical and economic feasibility of alternatives to Cr(VI) provided in the BD’, please provide the comments here.

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SECTION VI. Confidential comments

Please only use the box below to provide confidential information (including confidential responses to the specific information requests). In addition to the confidential information itself, please also include a clear justification on why the information is considered confidential (see below for further details).

Confidential information will only be used by ECHA, including its Committees, by the Member State competent authorities and by the European Commission.

* I declare that confidential information is only provided in this box. I have also included in this box reasons, enumerated in Article 4(1) or 4(2) of Regulation (EC) No 1049/2001 regarding public access to documents, why the information below submitted as confidential cannot be disclosed to persons requesting access to documents (please explain below in the commenting field those reasons; a reason could be that the protection of your commercial interests, including intellectual property, would be undermined).

Please provide your confidential comments in the box below (maximum 63 999 characters): Do not use characters < >

This consultation procedure is subject to data privacy rules. In case you face problems related to the protection of your personal data, you can turn to the Data Protection Officer of ECHA under: data-protection-officer@echa.europa.eu).

General comments or one attachment should be provided as a minimum. At least general comments or one comment for specific information request or one attachment is required.