Chairman of Vecco e. V., Arnsberg, which offers its members extensive support in the REACh process. Interview: Heinz Käsinger
Galvanotechnik: The first approvals for the upstream authorization of chromium trioxide have been granted. Are you satisfied?
Matthias Enseling: Not really. The EU Commission has stuck to the expected timeframe with the review period of 7 years. However, as the whole thing starts with the sunset date in September 2017, the approval period is significantly shorter. This means that the affected companies must start working on follow-up applications today. And at full speed.
What exactly are you complaining about?
Basically, we are happy about the approval. It is also not our place to evaluate the results of another consortium. But the fact that it took three and a half years to reach a decision is not ideal for anyone involved. Then there is the short review period already mentioned and, finally, only five of the six approvals applied for have been granted to date. For the sixth application, the functional use of chromium with a decorative character, a substitution plan was subsequently submitted and is still being reviewed.
At least affected companies can now work with legal certainty until September 2024.
That is true, but many of those involved do not yet realize how much work and costs they will have to face. Anyone who wants to continue working with chromium trioxide must first submit a notification to the ECHA. There are short deadlines that must not be missed. This also applies to the submission of the annual measured values for exposure and emissions. It is questionable whether the few accredited measuring institutes can even manage this. Then there are the costs of reauthorization: another consortium, for example, has now announced its intention to submit a follow-up application. This would have to be received by the ECHA as early as March 2023 and the costs are enormous. The decision for this follow-up application would have to be made by the companies by the end of March and a five-figure sum would have to be paid in advance by then. Our conditions are much more SME-friendly.
Vecco has found a good solution for transmitting the exposure values?
Yes, the partner company, Hapoc GmbH & Co KG, has representative values for all the work scenarios mentioned. Around 400 values have already been entered into a database for this purpose in the recent past. The values are made available to members, completely anonymized of course. Benchmarking, historical development and a compliance check round off the offer. By the way: if a measured value does not fit, we also advise companies.
Vecco, Hapoc - and then there's Eupoc. Can you please explain the different organizations?
Vecco e. V. and Eupoc GmbH worked on the applications for approval. Eupoc is, if you like, the operational unit of Vecco e. V. and is supported by Vecco members from the very beginning. It develops individual and upstream authorizations and supports companies with registration and authorization. It is, so to speak, a consulting company by coaters for coaters. And Hapoc is the authorization holder. You need to know that an association cannot authorize. A further component is to be added shortly: Vecco:net is an innovation platform where the topic of substitution and the testing of alternative technologies can be carried out professionally.
