functional chrome plating - echa

CHEMICAL SAFETY REPORT

Functional chrome plating

-PART A-

PUBLIC VERSION

Substance Name: chromium trioxide

EC Number: 215-607-8

CAS Number: 1333-82-0

Applicants: CROMOMED S.A.

CRONOR S.A.

CROMO EUROPA S.A.

CHROMATLANTIQUE INDUSTRIEL S.A.

VILA ELECTROQUIMICA S.A.

Chromium trioxide

NOTE TO THE READER

In 2012, a group of more than 150 companies came together to form the Chromium Trioxide REACH

Authorization Consortium (CTAC). The sole purpose of this consortium is the joint development of

the documentation required to submit REACH authorisations for several Chromium Trioxide uses.

All the companies included in this application are SMEs (small enterprises) that were founding

members of the CTAC, actively participating and providing data for the development of the file

relating to the use of chromium trioxide in hard chrome plating - along with 90 other companies

specifically interested in this use-.

As a result of the work carried out under the CTAC, this Chemical Safety Report (CSR) was

completed in April 2015. It includes a Generic Exposure Scenario (GES) with a number of conditions

of use and risk management measures that lead to an exposure estimation directly associated with a

Socio-economic Analysis (SEA) which shows that the benefits of continuing to use the substance

greatly outweigh the non-use scenario.

In order to demonstrate that the conditions of use developed in applicants' facilities are carried out

within the limits and boundaries set by the Generic Exposure Scenario, and that the exposure remains

at the lowest threshold possible through the use of best industry practices, this CSR has been

completed and refined with specific information for each installation for which authorisation is

sought.

EC number:

215-607-8

Chromium trioxide – Functional Chrome Plating CAS number:

1333-82-0

2015-11-11 CHEMICAL SAFETY REPORT iii

Table of Contents

Part A ...................................................................................................................................................................... 1

1. SUMMARY OF RISK MANAGEMENT MEASURES ................................................................................ 1 2. DECLARATION THAT RISK MANAGEMENT MEASURES ARE IMPLEMENTED .......................... 11 3. DECLARATION THAT RISK MANAGEMENT MEASURES ARE COMMUNICATED ...................... 11

EC number:

215-607-8


1333-82-0

2015-11-11 CHEMICAL SAFETY REPORT 1

Part A

1. SUMMARY OF RISK MANAGEMENT MEASURES

Summary of Risk Management Measures and operational conditions for each applicant is presented in the

following tables. Please refer to 9.0.2.3 (Table 10) for more detailed information on RMM and hygiene practices.

Summary of Working Contributing Scenarios and (estimated) resulting exposure levels are presented in section

10.1.1 (table 19).

EC number:

215-607-8


1333-82-0


SUMMARY OF RISK MANAGEMENT MEASURES FOR APPLICANTS: CROMOMED S.A; CRONOR S.A. & CROMO EUROPA S.A.

ECS

and

WCS

Task (ERC/spERC

or PROC)

Annual

amount

per site

(t/year)

Technical RMMs

Organisational RMMs

[See 9.0.2.3. (Table 10)]

PPE

[See 9.0.2.3. (Table 10)]

Other conditions/Task

explanation

Effectivenes

s of waste

water and

waste air

treatment

(for ERC)

Release

factors:

water,

air and

soil (for

ERC)

Detaile

d info.

in CSR

(section

)

ECS Functional chrome

plating (ERC 6b)

< 10

tn/year

each

applicant

- Air emission

abatement (Wet

Scrubber + mist

suction system)

- Duration: 8 h

- Frequency: Daily

- All solid and any liquid waste is

collected and the collected waste

is directly forwarded to an

external waste management

company, (licenced contractor)

for disposal as hazardous waste

- -

Air: 99.9%

Water: No

discharge,

closed loop

operation.

Soil: No

release to

soil

ERC

default

(see

9.1.1.1)

9.1.1.

WCS

1

Delivery and storage

of raw material

(PROC 1)

-

- Containment:

Closed system

- LEV: No

- General ventilation:

Good natural

ventilation

- Duration of activity: < 1 hour

- Frequency: max. 2 times/year

- Place of use: Indoor

- Occupational Health and Safety

Management System: Advanced

- Highly trained workers

Respiratory Protection: No

Chemical resistant gloves

Work coveralls

Safety shoes

Safety goggles

Chromium trioxide is delivered

always as dry powder in

watertight drums and stored in

a chemical storage room

- - 9.1.2.

WCS

2

Decanting of liquids

(PROC 8b) Included in CTAC Generic Exposure Scenario but not relevant for applicants 9.1.3.

WCS

3

Decanting of solids


WCS

4

Mixing - liquids

(PROC 5) Included in CTAC Generic Exposure Scenario but not relevant for applicants 9.1.5.

WCS

5

Mixing - solids


EC number:

215-607-8


1333-82-0


WCS

6

Re-filling of baths-

liquids (PROC 8b) -

- Containment: No

- LEV: YES

- Duration of activity: < 10 min

- Frequency: 1 time/week

- Work area: Indoors


Management System:

Advanced




Work coveralls

Safety shoes

Safety goggles

The chromium trioxide solution

is transferred to and manually

filled into the bath for

adjustment of the concentration

in the bath.

Concentration of the substance

in the bath: 15-30%

- - 9.1.7.

WCS

7

Re-filling of baths -

solids (PROC 8b) -

- Containment: No

- LEV: YES


- Frequency: 1 time/month



Management System:

Advanced


Respiratory Protection: Yes

[Respirator with APF 30]

[Effectiveness Inhal:

96.67%]


Work coveralls

Safety shoes

Safety goggles

The solid chromium trioxide is

transferred to and manually

filled into bath for adjustment

of the concentration in the bath


in the bath: 15-30%

- 9.1.8.

WCS

8

Loading of jigs


WCS

9

Chemical pre-

treatment (PROC 13) Included in CTAC Generic Exposure Scenario but not relevant for applicants 9.1.10.

WCS

10

Dipping/immersion

(PROC 2, PROC 13) -

- Containment:

Partial enclosure

- LEV: YES

- Duration of activity: < 8 hours

- Frequency: Daily



Management System:

Advanced




Work coveralls

Safety shoes

Safety goggles

Cylinders are submerged into

CR (VI) containing bath in a

semi-automatic process in

which articles are moved by the

operator using an overhead

travelling crane. DC

coupling/decoupling.

LEV is always operating during

the whole task.


in the bath: 15-30%

- - 9.1.11.

EC number:

215-607-8


1333-82-0


WCS

11

Rinsing/drying

(PROC 13) -

- Containment: No

- LEV: No


Good natural

ventilation


- Frequency: Daily



Management System:

Advanced




Work coveralls

Safety shoes

Safety goggles

Cylinders are manually or

automatically washed with

deionized water while hoisted

from plating bath.

Wash water falls on the bath

itself: All the wash water is

collected and reused. LEV is

always operating during this

task.

Once the cylinder is washed, it

is moved away from the bath

and manually dried. Then is

ready for being stored.

- - 9.1.12.

WCS

12

Chemical post-

treatment (PROC 13) Included in CTAC Generic Exposure Scenario but not relevant for applicants 9.1.13.

WCS

13

Cleaning and

unloading of jigs

(PROC 4)

Included in CTAC Generic Exposure Scenario but not relevant for applicants 9.1.14.

WCS

14

Cleaning of

equipment (PROC 8b) -

- Containment: No

- LEV: No


Good natural

ventilation


- Frequency: Daily



Management System:

Advanced




Work Coveralls

Safety shoes

Safety goggles

Cleaning of equipment is not a

separate task but conducted by

those employees working in the

bath area as part of their normal

working procedure.

- - 9.1.15.

WCS

15

Maintenance of

equipment (PROC 8a) -

- Containment: No

- LEV: No


Good natural

ventilation





Management System:

Advanced




Work Coveralls

Safety shoes

Safety goggles

Regular maintenance of the

baths and related equipment

(e.g. LEV, rectifier, pumps,

panels etc.).

- - 9.1.16.

EC number:

215-607-8


1333-82-0


WCS

16

Laboratory analysis

(sampling, laboratory

analysis) (PROC 15)

- - Containment: No

- LEV: YES





Management System:

Advanced



Work Coveralls

Safety shoes

Safety goggles

One or more samples are drawn

at the bath(s) and then

transferred in a closed flask to

the laboratory, then the

sample(s) will be diluted and

then analysed (this task could

be outsourced).

- - 9.1.17.

WCS

17

Storage of articles

(PROC 1) -

- Containment: No

- LEV: No


Good natural

ventilation


- Frequency: Daily

- Place of use: Indoor/outdoors


Management System:

Advanced




Work Coveralls

Safety shoes

Safety goggles

The finished articles are stored

in a separate storage area. There

is no potential for exposure.

- - 9.1.18.

WCS

18

Waste management

(PROC 8b) -

- Containment:

Partial enclosure

- LEV: No


Good natural

ventilation

- Duration of activity: 30 min

- Frequency: Daily



Management System:

Advanced





96.67%]


Work coveralls

Safety shoes

Safety goggles

No on-site wastewater

treatment. No discharge of Cr

(VI) in wastewater from site is

expected.

Process waste (empty bags,

containers, filters, waste from

cleaning activities) are stored in

closed containers which further

are collected by licensed waste

management companies for

treatment in accordance with

relevant waste management

regulations. This task describes

the transfer of such type of

waste (e.g. empty bags) to the

storage area.

- - 9.1.19.

EC number:

215-607-8


1333-82-0


SUMMARY OF RISK MANAGEMENT MEASURES FOR APPLICANTS: CHROMATLANTIQUE INDUSTRIEL SA & VILA ELECTROQUIMICA SA

ECS

and

WCS

Task (ERC/spERC

or PROC)

Annual

amount

per site

(t/year)

Technical RMMs

Organisational RMMs

[See 9.0.2.3. (Table 10)]

PPE

[See 9.0.2.3. (Table 10)]

Other conditions/Task

explanation

Effectivene

ss of waste

water and

waste air

treatment

(for ERC)

Release

factors:

water,

air and

soil (for

ERC)

Detailed

info. in

CSR

(section)

ECS Functional chrome

plating (ERC 6b)

< 10

tn/year

each

applicant

- Air emission

abatement: Droplet

separator

(condenser)

- Duration: <8 h

- Frequency: Daily

- All solid and any liquid waste is

collected and the collected waste

is directly forwarded to an

external waste management

company, (licenced contractor)

for disposal as hazardous waste

- -

Air: 99%

Water: No

discharge,

closed loop

operation.

Soil: No

release to

soil

ERC

default

(see

9.1.1.1)

9.1.1.

WCS

1

Delivery and storage

of raw material

(PROC 1)

-

- Containment:

Closed system

- LEV: No


Good natural

ventilation









Work coveralls

Safety shoes

Safety goggles

Chromium trioxide is delivered

as dry powder in watertight

drums or as aqueous solution in

sealed containers and stored in

a chemical storage room

- - 9.1.2.

WCS

2

Decanting of liquids


WCS

3

Decanting of solids


WCS

4

Mixing - liquids


WCS

5

Mixing - solids


EC number:

215-607-8


1333-82-0


WCS

6

Re-filling of baths-

liquids (PROC 8b) -

- Containment: No

- LEV: YES









Work coveralls

Safety shoes

Safety goggles

The chromium trioxide solution

is transferred to and manually

filled into the bath for

adjustment of the level/

concentration in the bath.


in the bath: 15-30%

- - 9.1.7.

WCS

7

Re-filling of baths -

solids (PROC 8b) -

- Containment: No

- LEV: YES










96.67%]


Work coveralls

Safety shoes

Safety goggles

The solid chromium trioxide is

transferred to and manually

filled into bath for adjustment

of the concentration in the bath


in the bath: 15-30%

- - 9.1.8.

WCS

8

Loading of jigs

(PROC 4) -

- Containment: No

- LEV: No


Good natural

ventilation

Duration of activity: < 3 hour

Frequency: Daily. Work area: Indoors

Occupational Health and Safety


Highly trained workers



Work coveralls

Safety shoes

Parts to be plated are manually

loaded into jigs or hangers.

Exposure to Cr(VI) cannot

occur directly but through

secondary sources (e.g. baths in

the same room)

- - 9.1.9.

WCS

9

Chemical pre-

treatment (PROC 13) -

- Containment: No

- LEV: YES

- Duration of activity: <3 hours




Management System: Advanced - Highly trained workers



Work coveralls

Safety shoes

Safety goggles

Parts are dipped into pre-

treatment acid or basic baths in

a semi-automatic process in

which they are moved by the


hoist. LEV is always operating

during this pre-treatment.

9.1.10.

EC number:

215-607-8


1333-82-0


WCS

10

Dipping/immersion

(PROC 2, PROC 13) -

- Containment:

Partial enclosure

- LEV: YES


- Frequency: Daily







Work coveralls

Safety shoes

Safety goggles

Parts are submerged into

CR(VI) containing bath in a

semi-automatic process in

which articles are moved by the


hoist. DC coupling/decoupling.

LEV is always operating during

the whole task.


in the bath: 15-30%

- - 9.1.11.

WCS

11

Rinsing/drying

(PROC 13) -

- Containment: No

- LEV: No


Good natural

ventilation


- Frequency: Daily







Work coveralls

Safety shoes

Safety goggles

Parts are automatically or

manually washed with

deionized water while hoisted

from plating bath.

Wash water falls on the bath

itself: All the wash water is

collected and reused. LEV is

always operating during this

task.

Once the part is washed, it is

moved away from the bath and

manually dried. Then is ready

for being stored or further

processing.

- - 9.1.12.

WCS

12

Chemical post-

treatment (PROC 13) Included in CTAC Generic Exposure Scenario but not relevant for applicant 9.1.13.

WCS

13

Cleaning and

unloading of jigs

(PROC 4)

-

- Containment: No

- LEV: No


Good natural

ventilation

Duration of activity: < 3 hours

Frequency: Daily

Work area: Indoors



Highly trained workers



Work coveralls

Safety shoes

After functional chrome plating,

articles are cleaned and

unloaded from hangers.

9.1.14.

EC number:

215-607-8


1333-82-0


WCS

14

Cleaning of

equipment (PROC 8b) -

- Containment: No

- LEV: No


Good natural

ventilation


- Frequency: Daily







Work Coveralls

Safety shoes

Safety goggles

Cleaning of equipment is not a

separate task but conducted by

those employees working in the

bath area as part of their normal

working procedure.

- - 9.1.15.

WCS

15

Maintenance of

equipment (PROC 8a) -

- Containment: No

- LEV: No


Good natural

ventilation









Work Coveralls

Safety shoes

Safety goggles

Regular maintenance of the

baths and related equipment

(e.g. LEV, rectifier, pumps,

panels etc.).

- - 9.1.16.

WCS

16

Laboratory analysis

(sampling, laboratory

analysis) (PROC 15)

- - Containment: No

- LEV: YES








Work Coveralls

Safety shoes

Safety goggles

One or more samples are drawn

at the bath(s) and then

transferred in a closed flask to

the laboratory, then the

sample(s) will be diluted and

then analysed (this task could

be outsourced).

- - 9.1.17.

WCS

17

Storage of articles

(PROC 1) -

- Containment: No

- LEV: No


Good natural

ventilation


- Frequency: Daily

- Place of use: Indoor/outdoors






Work Coveralls

Safety shoes

Safety goggles

The finished articles are stored

in a separate storage area. There

is no potential for exposure.

- - 9.1.18.

EC number:

215-607-8


1333-82-0


WCS

18

Waste management

(PROC 8b) -

- Containment:

Partial enclosure

- LEV: No


Good natural

ventilation


- Frequency: Daily








96.67%]


Work coveralls

Safety shoes

Safety goggles

No on-site wastewater

treatment. No discharge of

Cr(VI) in wastewater from site

is expected.

Process waste (empty bags,

containers, filters, waste from

cleaning activities) are stored in

closed containers which further

are collected by licensed waste

management companies for

treatment in accordance with

relevant waste management

regulations. This task describes

the transfer of such type of

waste (e.g. empty bags) to the

storage area.

- - 9.1.19.

EC number:

234-190-3


10588-01-9


Copy right protected – Applicants: Cromomed SA & others.

2. DECLARATION THAT RISK MANAGEMENT

MEASURES ARE IMPLEMENTED

We declare that the risk management measures referred to in Section 9 are implemented.

3. DECLARATION THAT RISK MANAGEMENT

MEASURES ARE COMMUNICATED

We declare that the risk management measures referred to in Section 9 are communicated to our customers when

relevant.

functional chrome plating - echa

Documents