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February IMFormation 2006
Important communications on REACH and COMAH (copied
exactly as received, warts and all!) for the attention of members
The REACH (Registration, Evaluation and Authorisation of Chemicals) Directive
proposes that synthetic chemicals marketed in everyday objects should be tested for
toxicity and abandoned in favour of safer alternatives where possible.
The proposals will completely overhaul chemicals safety legislation, and was originally
intended to cut the use of deadly chemicals in everyday items such as cleaning
products, cosmetics, computers and carpets.
Around 100,000 different substances are registered in the EU, of which around
30,000 are manufactured or imported in quantities above 1 tonne, but environmental
and health effects is only available for a small proportion of these chemicals. The
existing regulatory system has prioritised 140 chemicals of high concern but progress
has been slow, such that the European Commission proposed the REACH system:
Editor’s comment Sounds good but what is the downside – significant increased costs
to manufacturers and where substances are made in small quantities then
manufacturers could decide that costs would overtake selling prices and decide to
cease manufacture, a serious situation where no alternative product is available, and
further, could seriously damage the European economy because of associated costs.
However, has common sense prevailed at last – let’s hope so, only time will tell.
- All chemicals produced or imported into the EU in quantities above 1 tonne per year would be registered in a central database.
- Chemicals deemed of most concern would need authorisation such that industry to gain specific permission for particular uses and demonstrated to be safe.
- The system would cover both ‘new’ and ‘existing’ substances.
- A European Chemicals Agency would be set up and act as a central point for REACH: it would run a database to operate the system, co-ordinate the evaluation of suspicious chemicals and run a public database in which
consumers and professionals can find hazard information.
Members of the European Parliament at their first reading position on the REACH
package for regulating chemicals across the European Union. After years of wrangling
and one of the most intensive lobbying campaigns in the EU’s history, the European
Parliament voted on the proposals to reach an agreed position. The outcome of the
The British EU presidency is hoping that the 25 member states will reach a political
agreement on REACH by the end of 2005. The EU could then finalise the details of its
position early in 2006. The European Commission says the law is unlikely to come into
force until 2007.
- 90% of commercial chemicals would be exempt from full tests
- Expensive toxicity tests were abandoned
- Substances still under research were given a 15 year exemption from REACH to encourage innovation. Undoubtedly the chemical industry, especially smaller companies, will be pleased with the outcome.
Hexavalent Chromium Electroplating Installations and You
A recent letter which members may be interested in ???
From: EUROPEAN COMMISSION Brussels, 7 December 2005
Editor’s comment. Of course, all owners of companies will immediately understand the ramifications (!!!)
of the above letter, especially those responsible persons who have already taken actions to obey what
was understood to be what COMAH (the Seveso II Directive) meant. Some companies are known to
have told their customers that they have ceased (or are ceasing) to supply chromium plating from CrVI
type solutions, whilst some are known to have expended money by having reduced the size of their
tank(s) in order to only be classed as lower tier.
DIRECTOR-GENERAL ENVIRONMENT ENV.A.5/PBTB/isk (D2005) 24825
NOTE FOR THE ATTENTION OF: COMPETENT AUTHORITIES OF THE SEVESO II DIRECTIVE
Subject: Classification of electroplating baths containing chromium trioxide/chromic acid:
Application of the Seveso II Directive for Airbus Industries and the electroplating industry
The electroplating industry uses Chromium trioxide which has been classified recently as very toxic by the 29th
ATP of the Dangerous Substances Directive. Chromium trioxide is dissolved in Chromic Acid in electroplating
baths, but the classification of the chromium component has not yet been identified properly.
If the chromium component is eventually classified as very toxic, many electroplating baths exceeding the
thresholds of 5 or 20 tons would be covered by the Seveso II Directive.
After a first discussion with the Member States at the Seveso Committee (Attachment 1: Discussion Paper
from the UK), Unit A.5 has consulted the Member States and has received substantial comments from Poland,
Belgium, Sweden, Germany, Italy and France (Attachment 2: Table compiling the comments attached). On the
basis of these comments, no consenus can be reached as the comments raises several technical questions
concerning the proper identification of the chromium compound of the electroplating baths and the correct
application of Directives 67/548/EC and 1999/45/EC in determining the classification of the composition
contained in the baths.
Following a preliminary opinion of the Major Accidents Hazard Bureau (MAHB) within the JRC on the risk
classification of chromium solutions (Attachment 15 November 2005), the dilution of chromium trioxide into
water leads to the creation of a new substance (mixture of chromic and dichromic acid) which has not yet been
classified according to the Directive 67/548/EEC and must therefore be self-classified as a separate
substance in accordance with Annex VI of Directive 67/548/EC, as foreseen in Annex I of the Seveso II
Directive (see Notes of Annex I, point 1, 2nd paragraph). A generic evaluation of Chromium (VI) compounds
classifies them as Cat 2 carcinogens and substances dangerous to the aquatic environment (N; R50/53, but
does not address toxicity by inhalation hazards.
On the basis of these preliminary evaluations, it appears that the companies need to carry out selfclassification
tests for their baths. Therefore, the testing conditions and procedures should be such that both
Committees established under the Dangerous Substance Directive and under Seveso II could agree with.
The Commission recommends that the affected Member States discuss their options and agree the next
steps. If further tests are agreed, MAHB has accepted to facilitate the discussions for agreement of all parties
on the conditions and parameters of these tests, prior to their performance. Furthermore, the MAHB offered
to attend the meeting with the electroplating industry on 8 December in the UK and to follow up the
discussions closely. Finally, for the long term, the classification of chromium acid/electroplating baths could,
on request of a Member State, generally agreed by including these substances in the 31 ATP
If at some time in the future, their action appears incorrect and they have therefore wasted good
money, who will compensate them for the actions that they have taken – the Government !, European
Comments from members on both the REACH and the SEVESCO articles are welcome, and should be
sent to the Institute at Exeter House, marked for the attention of The Editor IMFormation.
Health, Safety and Environment
Scottish Environment Protection Agency
SEPA has issued a consultative document seeking
comment on the proposed increases of the
Pollution Prevention and Control (PPC) subsistence
charges for 2006/07 and 2007/8 by more than the
Retail Price Index (RPI). The document can be
viewed on the SEPA website: www.sepa.org.uk,
which gives details of the various increases, and
how to comment.
Slow progress for IPPC regime
The European Commission has published a report
on the implementation of the IPPC regime, under
which all major industrial installations must have
their Permits by October 2007.
The report highlighted a disappointing progress on
the issue of permits among the countries covered,
and it anticipates a last minute rush for approvals
before the deadline.
Additionally, several Member States are well behind
schedule in transposing the legislation itself and
with differing approaches to the methods used to
do so. Legal action is ongoing against eight of the
EU countries (the UK is not one of them)) for
incorrect or delaying transpositions.
The report sets out an action plan to pressure
Member States to speed up the ‘permitting
process’ which involves use of the European
Pollutant Emission Register (EPER) to identify the
main producers of certain pollutants and check on
their permitted status.
For more information visit:
A campaign of roadside stop-and-search is targeting
flytippers in England as part of a programme to
encourage businesses to manage waste responsibly.
The checks by police, council staff and Environment
Agency officers are part of the Government’s
Business Resource Efficiency and Waste Programme
(BREW), which was set up to help businesses use
resources, water and energy more efficiently and to
cut the waste they send to landfill. Vehicles carrying
waste are being targeted to check that the drivers
have the correct registration to carry waste since
unregistered waste-carriers are often to blame for
incidents of fly-tipping.
UK lags behind in Safety of Abrasives
The UK is lagging behind other European countries
when it comes to the safety of abrasive products
such as grinding wheels, cut-off discs and coated
abrasives. So claims the Organisation for the Safety
of Abrasives (OSA), a not-for-profit association of
manufacturers who account for 70% of the world’s
production of hand held abrasives.
In some countries it is mandatory to use OSAcertified
products whilst in others they should
conform to the relevant EN standards. In the UK,
whilst HSE recognises EN standards, there are few
restrictions on the sale of unsafe products. OSA’s
methodical and exhaustive tests are performed by
recognised test institutes, which confirms that
products are safe and issues appropriate
certificates. Anyone thinking that OSA is just
another club which might lack ‘teeth’ may be
reassured that 50% of new members fail to meet
the stringent rules on their first attempt.
First Aid at Work
Are your First Aiders up to date with the latest
requirements to enable them to take up their duties
To find out more about courses in various centres
and company in-house courses, contact: Lifeskills
Medical Limited–Advanced Life Support Tel: 0870
225 0101 or E-mail: email@example.com
- Have they a valid certificate of competence?
- Do they need to take a refresher course?
- Have you sufficient First Aiders per number of employees? There are numerous training organisations but do they offer additional training specific to the surface finishing industry?
Environmental Management Standard
ISO 14001:1996 will be withdrawn in May 2006 and
the revised ISO 14001:2004 will be applicable. All of
the old certificates will cease to be valid. Companies
wishing to maintain a valid EMS registration must
make to transition to ISO 14001:2004.
A Comparison Guide explaining the changes and
transition arrangements is available on request from
BSI Management Systems –
A free e-learning package is available on the BSI
website, which contains details of all the changes
and a test of understanding. To access the package
‘In Court today’
Two companies have been fined a total of £46,000 and
ordered to pay combined costs of £156,244 after
wastes including syringes, bottles of pills, batteries,
metal knives and an inhaler, was spread on farmland.
The companies pleaded guilty to three offences under
the Environment Protection Act.
Municipal waste from a recycling centre owned by one
of the companies was mixed with green waste and
cattle manure and spread on farmland owned by the
other company, with a risk of pollution to the
environment and harm to human health. The
companies claimed it was part of a trial to
investigate the potential for recycling biodegradable
A university has been fined a total of £16,000 for
breaches of the radioactive substances regulations
after it pleaded guilty to five charges. The university
after an EA inspection was given three months to
put matters right, but did not do so, hence the
prosecution. In court it was stated that the daily
discharge limit for one substance, Oxygen-15, had
been exceeded by a factor of 840.
Company News and Products
About 100 visitors attended when the company
threw open its doors at its Surface Technology
Centre in Birmingham. Visitors had a twelve hour
day of seminars and training sessions as well a live
demonstrations which included the opportunity for
visitors to bring along their own samples and see
how they could be cleaned, deburred, peened and
polished, using air, wheel, and wet blast technology,
plus washing and vibratory finishing.
More information - Colin Ward - tel: 01924 276303
3M Abrasive Systems
3M Abrasive Systems offers a free information pack
to help employers meet new ‘hand-arm’ vibration
rules. The pack is to help companies comply with
the new EU regulations (2002/44/EC) on ‘hand-arm’
vibration at work, which can reduce levels of
vibration by as much as 37%. The pack is available
free by calling 0870 60 800 90, or email:
A fully automated inline barrel plating line formerly
used in the UK for zinc plating has been recently
exported to South Africa and installed at Saayman
Danks in Seaview near Durban.
Said director John Danks ‘We were introduced to
Riley Industries through there recent membership of
the South Africa Metal Finishing Association, as a
result of which we have been able to acquire a large,
modern and sophisticated plant at a fraction of the
cost it would have been when new. We are pleased
with the equipment and service we have received
from Michael Riley and his team’.
Sandvik Materials Technology UK
Sandvik have launched a new and innovative
coated strip material, for decorative applications in
the consumer electronics, domestic appliance,
automotive and similar industries. Called Sandvik
DecorexTM, the new material combines an extensive
and exclusive colour range in various surface
finishes – dull, satin, ground and bright, with
excellent processing properties and technical
benefits of stainless steel. The new material is seen
as an alternative to traditionally used anodised
aluminium. In comparison Decorex is more elastic,
harder and more ductile and can be used in much
thinner sections due to the strength benefits of
stainless steel. More details obtainable by
telephoning 0121 504 5111. Website:
AMETEK Spectro Analytical Instruments
Ametek have a range of X-ray fluorescence analysis
and optical emission spectrometry equipment
which will be essential instruments for proving the
conformity of products under the WEEE and RoHS
directives which come into force from July 2006.
These analytical techniques, amongst others, are
recommended in the ICE 111/24/CD from the
International Electrotechnical Commission. For
more details telephone: +44 121 550 8997
Members and guests who attended the event of
Christmas Lectures, Luncheon and Annual General
meeting at the Birmingham Medical Institute were
very complimentary in their praise of the
organisation of the event. The invited lectures by Dr
David Hemsley and that by Dr Stuart Lyon were very
well received and members who did not attend will
be able to read them in a future edition of the
Transactions. The full Christmas lunch was excellent
washed down with wines and the luncheon
concluded with the toast to the Institute proposed
by the President of the Institute of Corrosion (Dr
Stuart Lyon), in recognition of the Institute’s 80
years in existence.
After lunch came the legal requirement of the
Annual General Meeting which concluded with the
presentation of the Institute’s awards.
A provisional date for this event in 2006 has been
booked for 6 December – put it in your diary now so
you don’t forget!
IMF at Surface World Exhibition
For the Institute the exhibition was a great recruiting
opportunity and we ran out of application forms
quite early on! A rapid "mercy dash" from Exeter
House and use of the Exhibition’s copier soon fixed
that. Let us see how many turn into actual new
members, both professional and sustaining.
This was the first IMF exhibition for Ken and it was
a chance for him to get to know the industry, visit
other stands and be there for members who looked
us up as an oasis. Members and visitors from
around the world made a point of checking in with
IMF volunteers where there in abundance (thank
you for that) and we always seemed to manage two
on the stand and one roving for each of the three
Sharing a stand (with an invisible demarcation line)
with the SEA worked well, giving solidarity between
the professional and trade associations.
Honorary Secretary General of the IMF, Barry Gay, is
quoted, "I hope the Show was as good for the other
stands as it was for the Institute. It was good to see
Head Office staff and volunteers pulling together to
put on a professional face to the industry."
Guides to Practice in Corrosion Control, produced
some years ago by NPL and IMF are now available
in downloadable pdf format from:
and a link is on the IMF website under books.
New members and transfers
Cantwell P, Loughborough
Thangaraj V, India
Allen M, Tadley
Allin D.J, Torrington
Benstead I.P, Barnstable
Boden P, Basingstoke
Hill-Meldrum S, Bideford
Husband S, Bideford
Killner S, Bideford
Lee A.J, Bideford
Little J.C, Bideford
Mitchell D.J, Bideford
Sleigh C.P, Bideford
Smetham MC, Uckfield
Warren J.P, Bideford
Bunn E, Worcester
New Sustaining Member Companies
Gloucester GL2 9QH
Tel: 01452 712424, Fax: 01452 711549
Messier-Dowty Ltd are an aerospace company
who manufacture landing gear for the aircraft
industry. Their core plating process expertise
includes cadmium, chromium and nickel.
KPD Midlands Ltd, Unit 1, Angel Works
St Andrews Street, Birmingham B9 4JT
Tel: 0121 766 8226, Fax: 0121 771 2064
KPD are a surface treatment engineering
company who supply electroplating jigs,
anodising jigs, tanks & vats, vat heaters, cooling
coils, baskets, pvc coating and also provide a
Trinity Aerospace Engineering Ltd
Unit 15 – 18 Bilton Road
Kingsland Industrial Estate
Basingstoke RG24 8LJ
Tel: 01256 840276, Fax: 01256 840278
A member of the APPH Group, specialising in
repair and overhaul of aerospace components.
Facilities include - electrodeposition of chromium,
cadmium and sulphamate nickel, Alocom, shot
peening, machining, plasma spraying and painting.
Tutored Foundation Course
The Midland Branch are contemplating running the
tutored Foundation Course in the Spring on Basic
Electroplating & Surface Finishing, although
dependant on student requirements it may be
possible to introduce some of the recently studied
organic finishing units. Attendance would be on a
two hour evening session, one evening per week
over twelve weeks at IMF headquarters – Exeter
House. The end of course multiple-choice
examination would enable those passing to be
awarded the Foundation Certificate and apply for
the first stage professional qualification of
AssocIMF. Persons or companies interested in this
course should contact the Branch Secretary on
0121 308 0777 for receipt of the course syllabus.
Examination success at BMW, Oxford
Dr Keith Davies, Chairman of the IMF’s Examination
& Qualification Board, together with Ron Read,
Chairman of the Education & Training Committee
presented students from BMW who were
successful in the recent Automotive Surface
Finishing examination with their certificates. This is
the fourth course that has been completed at BMW
and from comments said by Mr Chris Reeve,(Training
Specialist) "will not be the last". The occasion
commenced with an address by the Automotive
Academy that was followed by an impromptu
address by Ron Read, which received wide
applause. Keith Dennis then presented the
successful students with their Technician-
Automotive Surface Finishing certificates.
BMW’s Director, Peter Crook gave a congratulatory
speech and said "the course had been a corner
stone to the success of the Paint Shop".
Following the presentations, the IMF were
themselves presented with a certificate from the
Automotive Academy showing approval of syllabi
and module notes for further courses, namely:
Foundation Certificate Course & Module
MF1 Module – General Principles
MF2 Module – Plating Practice
MF2 Module – Paint, Lacquer & Varnish
MF2 Module – Powder Coating
Modified tutored Foundation Course
The first tutored course for the Foundation Certificate
comprising a mixture inorganic and organic units has
been completed. The course consisted of units on
electroplating and anodising together with units on
conversion coatings, paints and their application,
powder coating together with mandatory units on
health & safety, environmental, and control of
processes and product quality. The course was
tutored by Gordon Davies on-site at IMI Norgren,
Examination results are as follows:
Armstrong S *
Blewitt M *
Carwithen M *
Hill D **
Palmer R **
Plover R *
Troy T *
* pass with merit, ** pass with distinction
Out & About
Organic Coating Environment and Health Issues in the Automotive
Industry. One-day symposium & tabletop exhibition on the 14
Birmingham Medical Institute. Details from IMF tel: 0121 622 7387
or see the IMF’s website at: www.uk-finishing.org.uk
Impact of the Nickel Risk Assessment. One-day symposium &
tabletop exhibition. 16 March 2006.
Birmingham Medical Institute. Jointly organised by IMF tel: 0121
622 7387, NI tel: 01527 584777 and
SEA tel: 0121 237 1123 from whom further details can be
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