In December 2020, just before Christmas, ECHA finally got around to authorizing chromium (VI). The process took four years, and in the end, something came out that might well cause common sense to be in doubt. The doubt is not so much about the fact that it is now permitted to use electrolytes containing chromium (VI) for another four years under certain circumstances, but rather about the accompanying circumstances, conditions and above all the deadlines set in this context.
After all, ECHA took more than three years beyond the sunset date to decide on authorization. Due to this massive missed deadline, larger parts of the electroplating industry are now under enormous pressure, because the deadlines that have to be met for further authorization-compliant use are, as some industry participants politely and very controlledly put it, more than sporty.
In particular, it could be considered utopian that extensive workplace exposure measurements must be carried out by June 18, 2021 - according to the current reading of experts - by accredited testing institutes. Leaving aside the not inconsiderable costs and the fact that this will have to take place annually from now on - if suddenly more than 1,000 affected companies want to book testing institutes for several days, it can almost be ruled out that this can be completed in the area by June.
Regardless of any deadlines, however, not just anyone who has joined the CTACsub application can continue to use chromium trioxide as before. Each user must justify the proposed use against the conditions of approval and communicate the reasoning to Echa.
But that's not all; those seeking another authorization period with CTACSub2 authorization must hurry - the decision must be made by March 31. The deadlines are somewhat less tight for EUPOC/VECCO or for a very expensive and time-consuming individual authorization.
Particularly in view of the current economic circumstances surrounding the Corona crisis, the European Commission's setting of deadlines is unsurpassable in its inconsideration of the electroplating industry and its lack of practical relevance. In this way, ECHA is causing sheer actionism at a time when companies could be using their resources more sensibly to survive the crisis.
If one considers the result of the authorization of chromium trioxide by ECHA in connection with the effort, not much more comes out of it than a European prescribed measure for occupational health and safety. And rules for occupational health and safety, and above all strict limit values, existed in our country even before that. In view of the sheer number of companies affected, it is doubtful that the ECHA, or rather the national authorities that have been responsible for this in the past and will continue to be responsible for it in the future, will be able to control the prescribed limit values even approximately completely. It is therefore not exactly easy to answer the question of the reward for all the effort.
Read more about this topic in the Knowledge section: