Vote tomorrow: ETUC support the proposal for objection of certain uses of chromium trioxide

Brussels, July 9th 2020


Dear Member of the European Parliament,

Tomorrow morning, the European Parliament will vote on the objection pursuant to Rule 112(2) and (3) of certain uses of chromium trioxide (Chromium VI). ETUC supports the objection and for users to find alternatives to the use of this dangerous substance, which are safer and would put workers at less risk.

Chromium VI is a carcinogen that affects about 1 million workers in Europe. It is used for chromium plating of metal parts but is also present in welding fumes. As far as workers' health is concerned, Chromium VI is covered by two pieces of EU legislation.

The first is the REACH regulation in which this carcinogen has been identified as "Substances of Very High Concern" and included in its annex XIV (the list of substances that require authorisation). For each use of this substance, users must therefore obtain an authorization to continue using it. The European Chemicals Agency ECHA (which prepares an opinion) and the European Commission (which takes the final decision) have already processed almost 200 dossiers. Authorisations have so far always been granted (except in one case). The whole debate is about alternatives. According to the legal text of REACH, if there is an alternative (technically and economically suitable), authorisation cannot be granted. The industry applying for the authorisations has always claimed that the existing alternatives are not suitable, but another part of the industry manufacturing the alternatives, and environmental NGOs, say the opposite and think that some authorisations for chromium plating with Chromium VI should be rejected.

ETUC support this position because the REACH authorisation system is not working properly and as intended. The aim of the authorisation system in REACH is to replace extremely dangerous substances on the market with safer alternatives. But if authorisations are granted almost automatically, as is currently the case, this will never happen. A well-functioning authorisation system would be one in which some applications are rejected and others granted. The applications for authorisation of Chromium VI that we are talking about here concern "decorative" applications for which there are of course alternatives that are safer and less risky for workers.

The second piece of legislation that covers Chromium VI is the CMD in which we now have a mandatory OEL for this carcinogen (included in the first batch of the revision). This limit value is especially useful for workers who do welding. This use is not covered by REACH because Chromium VI is here a "process generated substance". Manufacturers must comply with both REACH and the CMD. These two legislations therefore work in synergy. Exposure levels to Chromium VI for workers in plating applications are lower than in welding applications.

All the best,

Per Hilmersson
Deputy General Secretary