Efforts in substitution of hexavalent chromium
By Xavier Verni
ArcelorMittal - Corporate Health & Safety
26 June 2014
AM/NS Calvert
Outlines
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Presentation of ArcelorMittal
Regulatory Background
Exposure scenarii
Research on Alternatives
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The world’s leading steel and mining company
• ArcelorMittal is the world's leading steel and mining company, with around
232,000 employees in more than 60 countries. ArcelorMittal is the leader in all
major global steel markets, including automotive, construction, household
appliances and packaging, with leading R&D and technology, as well as
sizeable captive supplies of raw materials and outstanding distribution
networks.
• An industrial presence in 20 countries exposes the company to all major
markets, from emerging to mature.
• ArcelorMittal values geographical breadth, product diversity and raw materials
security. Around 38% of our steel is produced in the Americas, 46% in Europe
and 16% in other countries such as Kazakhstan, South Africa and Ukraine.
Underpinning all our operations is a philosophy to produce safe, sustainable steel
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Geographical reach
Market position by region
Leader in
North America
Leader in
Latin America*
No 1 in
Europe
Major producer
in the CIS
Leader in
Africa
ArcelorMittal
Others
Emerging markets continue to offer
the best organic growth potential for
ArcelorMittal
• Superior demand growth potential
• We have the platform and
experience:
– Already the steel market
leader in the Americas,
Europe and Africa and topfour producer in the CIS*
– Brazil is one of our
franchise businesses
– We also have JV* projects
in the Middle East and
China
Industrial and commercial network focus on our franchise businesses
* Latin America includes Mexico.
* CIS: Commonwealth of Independent States (CIS)
JV: Joint Venture
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ArcelorMittal main markets
• Automotive
– ArcelorMittal is the leading automotive steelmaker with a worldwide presence, delivering
a large scale of innovative products, solutions and services to automotive customers
– No. 1 supplier of flat carbon steels for the global automotive sector, including advanced
and ultra high strength, galvanised and coated steels for the global automotive sector
• Construction
– Globally, the largest single market for steel: a 715 million tonne steel consumption market
comprised of diversified products
– Emerging markets represent more than 50% of the square meters constructed each year
globally
– ArcelorMittal is a world leader with over 27 million tonnes of products delivered to the
building and construction sector in 2012
• Packaging
– New packaging concepts constantly designed to achieve differentiation by steel solution
– Complementary industrial network in Europe with production plants and service centres
near customers' can making facilities
The leader in automotive steels
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Regulatory Background
A long Journey …
Mandatory Risk Assessment (RA) on Cr(VI) compounds: the Risk Reduction Strategy
(RRS) lead by the UK authorities
Five hexavalent chromium compounds (chromium trioxide, sodium chromate, sodium
dichromate, ammonium dichromate and potassium dichromate) were placed on the third list
of substances for assessment within the European Union’s (EU) Existing Substances
Regulation (EC) 793/93 (ESR) due to concerns for human health, particularly genotoxicity
and carcinogenicity and the large annual quantities used.
2002:
The risk assessment report (RAR) concluded that there is a need for risk reduction with
regards to:
• Health: risks to workers, consumers and humans exposed via the environment.
• Environment: local risks to the aquatic and terrestrial compartments of the environment
2005:
• A risk reduction strategy (RRS) with respect to human health and environment was
launched.
• Health & Safety Executive UK for the Health part,
• Risk & Policy Analysts, which was commissioned by the Department for environmental
food and rural affairs (DEFRA UK) for the Environment part.
 ArcelorMittal sent data on workers exposure (Exposure Scenarios) and on environment 5
releases
Regulatory Background
A long Journey …
2010 and 2011:
• Updates of the REACH candidate List
The substances sodium chromate, potassium dichromate, potassium chromate, ammonium
dichromate, acids generated from chromium trioxide and their oligomers (names of the acids
and their oligomers: Chromic acid, Dichromic acid, Oligomers of chromic acid and dichromic
acid), chromium trioxide, dichromium tris(chromate) and potassium
hydroxyoctaoxodizincatedichromate were put on the REACH candidate list of substances to
be authorized under the REACH Regulation.
• Creation of a consortium
At European level, a chromium trioxide REACH authorisation task force (called the Chromium
Trioxide REACH Authorization Consortium, CTAC) was created to deal with the authorisation
of chromium trioxide (including chromic acid).
The objectives of the CTAC are:
- To coordinate at European level all the actions linked to the authorisation of chromium
trioxide (review of the Chemical Safety Report, definition of common uses, analysis of
alternatives if no confidentiality issues)
- To share the costs of the authorisation dossier.
 ArcelorMittal is part of the CTAC.
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Regulatory Background
A long Journey …
2013:
The substances quoted below were officially introduced in the annex XIV (authorisation list) of
REACH (Commission Regulation (EU) No 348/2013)
Authorisation under REACH:
As chromium trioxide is a carcinogen, the Socio Economic Analysis route is the only
way to demonstrate that there are no suitable alternatives and that the socioeconomic benefits of this CrVI compound use outweigh the risks to the human
health and the environment.
Other regulations on articles:
- Directive 2000/53/EC on end of life vehicles (ELV)
- Directive 2011/65/EU on electric and electronic equipments (RoHS)
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Chromium Trioxide REACH Authorization
Consortium ‘CTAC’
• Number of members: 154 members (and their affiliates)
• Representing Importers, Formulators and Downstream Users from all important
European markets and sectors.
• The Consortium will prepare authorization dossiers (for use by members) for the
following chromium trioxide uses:
1. Formulation of mixtures
2. Functional chrome plating
3. Decorative plating
4. Other surface treatment with Chromium VI present on the end product
(article)
5. Other surface treatment with no Chromium VI present at detection limit on the
end product (article)
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CTAC Timing
Source : http://www.indestructible.co.uk/reach/
• September 2012: Mailing of Use group specific baseline questionnaires to
Members for collection of information on volumes, socio-economic data,
alternatives, risk assessment measures and exposure.
• October 2012: Licence Agreement with Chromium Trioxide REACH
Registration consortium to use their Chemical Safety Report (CSR)
• Consultant contract with Arcadis terminated 15 May 2013 and new consultancy
agreement signed with Environ 17 June 2013
• New information requested on Socio Economic Analysis (SEA) and Analysis of
Alternatives (AoA)
• Work should end in August 2014. Core Documents should be drafted early
enough to allow for personalization (Latest date of application: 21 March 2016)
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Exposure Scenarii
• Chromium hexavalent compounds may be purchased in solid (flakes or crystals)
or liquid form.
• Chromium hexavalent compounds may be used for:
– Passivation of metallic coated steels
– Pre-treatment for the adherence of organic coated steels
– Deposition of a chromium coating
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Exposure Scenarii
Metallic coated steel - User manual – ArcelorMittal Europe –
Flat Products
Reference Document on Best Available
Techniques for the Surface Treatment of
Metals and Plastics - August 2006
European Commission
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Human Health and the Environment
• Human Health:
– A risk analysis was performed to identify the high exposure areas.
– Air monitoring campaigns (personal sampling) are performed on a yearly
basis. Results are below the national Occupational Exposure Limits.
– Biomonitoring (chromium in urine) data are also available.
Issue: EU impact of the implementation of the new French Occupational
Exposure Limit of 1 µg/m3 per 8 hours (implementation from 1 July 2014)
• Environment:
– All solutions containing hexavalent chromium are treated in water treatment
station before discharge to the environment.
– Emission data (total chromium and chromium hexavalent) are in compliance
with the local requirements
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Analysis of Alternatives (AoA)
• Hexavalent chromium was THE substance that fulfilled all the technical
requirements for all type of applications
• Now, the choice of an alternative depends on:
– Final application (customer and market - driven) and conditions of use by
the final customer/consumer
– Nature of the metallic coating (Zn ,Al, Tin, Cu)
– Hazard of the alternative
• Due to RoHS* and ELV* requirements, substitution has already been
completed for the automotive, electric and electronic markets.
• Issues:
– Small industrial sectors may have difficulties to launch R&D projects and to
find some external partners (suppliers, universities)
– Spare parts: Spare parts should remain available for a certain period of
time.
* ROHS: Restriction of Hazardous Substances in electrical and electronic equipment
ELV: End of Life Vehicle
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Possible alternatives identified
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Chromium trivalent
Zirconium/Titanium
Aluminium based coatings
Phosphonic acid
Silanes /Siloxanes
Sodium silicates
Acrylic Polymer
Polyurethane
Etc…
BUT is it economically and technically feasible?
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THANK YOU FOR YOUR ATTENTION
Email: xavier.verni@arcelormittal.com
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