Space sector action on Chromates (CrVI) – imminent ban of CrVI use in Europe under REACH legislation by 2017

Wednesday, November 28, 2012 3:17:00 PM

The EU Regulation (EC) No 1907/2006 ("REACH") creates a new legal framework for the use of chemical substances in Europe (i.e. the 27 EU Member States plus Norway, Iceland and Liechtenstein). Multiple Cr(VI) compounds currently used in the European space industry – for example chromium trioxide as part of Alodine 1200 for surface treatment – are or will be included in the list of Substances of Very High Concern (SVHC) subject to Authorisation (Annex XIV) of REACH in the beginning of 2013 and 2014. This means that they must no longer be used after “sunset dates” specified in Annex XIV, unless an authorisation has been granted to the user or the upstream manufacturer/importer. Authorisation applies regardless of the quantity used, and in addition to the REACH registration requirement. 

Today Cr(VI) compounds are still critical components for space systems, as their complete substitution by suitable safer alternatives by the estimated “sunset dates” will not be possible. Lacking appropriate action, Cr(VI) usage in the European industry will be forbidden by 2017. This is why ESA  together with the space industry industry has formed a Space Chromates Task Force in October 2012 in order to ensure continued use of Cr(VI) - where necessary - throughout the whole European space supply chain under the REACH authorisation scheme, also after 2017. The first operational activity of the Task Force is an information collection on Cr(VI) usage in the European space sector, in order to identify the Cr(VI) substances used, the organisations using them, the nature of the uses, other supply chain actors and authorisation intentions.

If your organisation is using/handling Cr(VI) substances for the development, production, and/or testing of space systems, it is concerned by REACH and shall contact Eurospace at the earliest to ensure that your organisation will be part of the joint activities of the Space Chromates Task Force.

 

Pierre Lionnet

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