Akzo Nobel N.V. Corporate Velperweg 76 6824 BM Arnhem P.O. Box 9300 6800 SB Arnhem www.akzonobel.com Comments from AkzoNobel on applications made for an authorization under REACH for the use of lead sulfochromate yellow (C.I Pigment yellow) and lead chromate molybdate sulphate red ( C.I. Pigment red 104) in industrial and professional coatings 1. Introduction AkzoNobel is a leading global paints and coatings company, supplying to customers in our market sectors throughout the world. The end-user segments for our coatings products include : 1 (i) Buildings and infrastructure1 – manufacture and supply of coatings for protection, decoration and maintenance of bridges, offshore and onshore infrastructure, the interior and exterior of commercial buildings and residential dwellings and coil coatings applied to roofing. Products are supplied for both new build projects and for maintenance, renovation and repair. (ii) Transportation¹ – includes manufacture and supply of coatings for all interior and exterior surfaces of ships and boats and the aftermarket refurbishment and modification of cars, trucks and other vehicles. We also supply paints for components of cars, trucks and commercial vehicles. (iii) Industrial¹ – includes coatings for assets of the oil and gas, metals, mining, water, power and agriculture industries. (iv) Consumer goods – includes coatings for wood furniture and domestic appliances. Includes uses in coatings discussed in REACH authorisation consultation number 0012-01, 001202, 0012-03, 0012-04, 0012-05, 0012-06. AkzoNobel are committed to providing sustainable solutions to our customers. We consider product stewardship to be a key element of sustainability and that it is critical to ensure our products and processes do not pose a danger to people or the environment. We are constantly striving to introduce safer products into the market and in 2011 we became the first global paint company to completely phase-out the use of all lead compounds2 from all of our products and processes throughout the world. This prohibition is enforced under our company Product Stewardship program through a mandatory standard which includes a ban on the use of all lead compounds as pigments in all of our paints in all of our end-user segments. AkzoNobel took this stance having proven that safer and effective alternatives to lead chromate pigments are available which can be formulated to work in all our products from both a technical and economic perspective. 2. AkzoNobel experience with lead chromate-free pigments and coating products A range of suitable and safer alternatives to lead chromate pigments have been commercially available in the European Union and throughout the world for many years. Examples include : Bismuth vanadates Mixed metal oxides/iron oxides3 Organic pigments (eg Diketopyrrolo-pyrrole (DPP), azos, Isoindoline, benzimidazolones) These pigments can be used alone, as hybrids or in formulated mixtures with other pigments to obtain the desired coating 2 3 Including lead chromates Examples include “Solaplex” and “Sicopal” products from the Rockwood and BASF companies product characteristics and performance4 at an acceptable cost. Different formulation solutions are often required for different product types, depending on the end-use involved. Since the complete withdrawal from the use of lead compounds from all products across AkzoNobel at the end of 2011, it is clear that the performance achieved with lead chromate-free products has met the requirements of the customers in our markets. In transition we experienced no resistance to the introduction of lead chromate-free coatings from customers, neither have we lost business on account of being free of products containing lead chromate. 3. Economic feasibility In consideration of the economic feasibility of lead-free versus lead chromate containing coatings products it is important to take a life cycle approach from a human health and environmental perspective. For example, in addition to consideration of the cost of pigments as raw materials used in paints, costs associated with protecting and the monitoring of workers during handling of lead pigments, during paint manufacture and paint application should be included , along with those associated with removal of paint from lead contaminated surfaces and disposal of waste at end of life. 4. Conclusion on the suitability and availability of alternatives to lead chromate On the basis of experience in the markets in which we operate, AkzoNobel maintain that technically effective, economically feasible and safe products are available that do not contain lead chromate pigments. These products meet our customer requirements, are available globally and include the following uses relevant to the application for authorization: 4 Key issues include opacity, colour and gloss retention, coating durability (i) Production of yellow and red colour paste/dispersions for use in manufacture of solvent-based coloured paints5 (ii) Industrial application of coatings to metal surfaces of non-consumer articles including high grade steel-based products6 (eg. Piping used in the petrochemical industry, crane arms, agricultural machinery, steel bridges, construction arches and coil coating for roofing, ships and boats). (iii) Professional application of coatings to metal surfaces of non-consumer articles including high grade steel-based products7 (eg. Piping used in the petrochemical industry, crane arms, agricultural machinery, steel bridges, construction arches, ships and boats). 5. Other comments As regards coatings used for road marking on public roads, in car-parks and airports8 we do not believe use of lead chromates is technically necessary and believe that continued use is undesirable from a human exposure and environmental perspective (flaking). However we do recognise that there may be specifications based on colour for roads (i.e. bright yellow, bright red) which are historically based on previously approved products/formulations containing lead chromate. The widespread acceptance of lead chromate-free products in this sector will require approval prior to widespread adoption in the marketplace. 5 REACH authorization consultation numbers 0012-01, 0012-02 REACH authorization consultation numbers 0012-03, 0012-04 7 REACH authorization consultation numbers 0012-05, 0012-06 8 REACH authorization consultation numbers 0012-11, 0012-12. This use is not a significant market for AkzoNobel 6 6. References 6.1 Paint square – Paint and coatings industry news (2012). International Paint drops lead chromate. Link : http://www.paintsquare.com/news/?fuseaction=view&id=8186 6.2 Removing lead from coil coatings – AkzoNobel website. Link : https://www.akzonobel.com/ccna/coil_coatings/leadfree/