[Alt-photo] Dichromates, REACH and the EU

Bert Kuijer gemeentehuis at gmail.com
Sun Sep 18 14:47:59 UTC 2016


I'm a printer mastering very old (alt-photo) techniques, that require
scientific research & development.
Techniques that will support my creativity as an artist.  :)

2016-09-17 20:31 GMT+02:00 Laura V via Alt-photo-process-list <
alt-photo-process-list at lists.altphotolist.org>:

> Thanks John...so we are scientists now and not artists?
>
> Laura
>
>
> On 9/17/16 4:05 PM, John Brewer via Alt-photo-process-list wrote:
>
>> Hello dichromate users
>>
>> I wrote to the UK Health and Safety Executive a while ago and received
>> the reply below. As a tutor, practitioner and supplier of some alt process
>> chemistry I can buy dichromates without filling out the crazy form as it
>> can be used for 'research and development'. Note that doesn't mean I can
>> supply. I forwarded this email to my supplier who deals directly with Sigma
>> and they have no problem selling it to me provided it's in small
>> quantities. I'm not sure if this will apply to individuals but it's worth
>> quoting the information below to your supplier.
>>
>> I hope the email below helps some of you European dichromate users.
>>
>> Best wishes
>>
>> John
>>
>> Dear John,
>>   As you note, potassium chromate is listed in Annex XIV of REACH and is
>> therefore subject to authorisation. The sunset date for potassium
>> dichromate is 21 September 2017. After this date, it will not be permitted
>> for a company (including self-employed individuals) to use the substance in
>> the EU, or place the substance on the market for a use, unless they have
>> authorisation from the European Commission. It is technically challenging
>> and expensive to apply for authorisation.
>>   The ideal option beyond the sunset date would be to use a viable, safer
>> alternative to potassium dichromate. Perhaps this has already been
>> addressed in your industry? It may be worth talking to other painters
>> and/or a relevant trade association to find out if others have already
>> considered this issue and the approach they are taking.
>>   Alternatively, especially as you use such a low volume, you might
>> consider whether any of the exemptions from authorisation might apply here.
>> They can be found in our bitesize leaflet on authorisation (leaflet number
>> 19 at:  http://www.hse.gov.uk/reach/bitesize.htm). For example, Article
>> 56(3) is clear that authorisation does not apply to the use of substances
>> for scientific research and development (SRD).
>>   You mention that you are a tutor. It is possible that your use of the
>> substance (as a tutor) could be considered as SRD. SRD is a defined term in
>> REACH [Article 3(23)] as “scientific research and development: means any
>> scientific experimentation, analysis or chemical research carried out under
>> controlled conditions in a volume less than 1 tonne per year”.
>> ·         As well as covering chemical research, it also applies to
>> scientific experimentation or analysis;
>>
>> ·         The definition includes an ‘or’ and an ‘any’ so logically, the
>> ‘any’ applies to all three terms in the list; i.e., any scientific
>> experimentation, any analysis, and any chemical research;
>>
>>   However, it would be for you (and others who use chromium compounds in
>> a similar way) to decide whether your use meets any of the exemptions.
>> Should you decide to continue to use the substance after the sunset date,
>> we would recommend that you document any decisions made in case you are
>> ever challenged by a Regulatory Authority.
>>   Authorisation can be applied for by the user of the chemical or by the
>> EU-based supplier on behalf of the people they supply to. Therefore, if you
>> decide that the criteria for exemption are not met (i.e. that authorisation
>> is required), the next step you take will be determined by where your
>> supplier is based. If your supplier is based in the EU, we would recommend
>> that you contact your supplier to find out whether the supplier has applied
>> for authorisation, and whether you can benefit from this.
>>   If you source the substance directly from outside the EU, the duty to
>> apply for authorisation would fall to you. However, we appreciate that this
>> may be an unrealistic task. Please don’t hesitate to get back in touch with
>> the helpdesk should you wish to discuss this further.
>>   I hope this helps.
>>   Kind regards,
>>   Laura
>> ------------------------
>> Laura McCabe
>> REACH & CLP Helpdesk
>> Chemicals Regulation Division
>>   HSE, Redgrave Court, Bootle, Merseyside L20 7HS
>>
>>
>>
>> Sent from my iPad
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>>
>>
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