Having joined Stowlin Limited in October of last year, and following 20 years in the surface finishing industry I can honestly say that life has been extremely rewarding meeting many interesting people and customers along the way within the industry.
With previous experience of chromate and the controls associated to it, I have been appointed as the first line contact for any question or enquiries relating to Chromium Trioxide and the relevant UK REACH legislation for Stowlin’s current customers, and can of course assist with enquiries from new customers.
As you are more than probably aware by now there was a press release by the Chromium Trioxide Authorisation Consortium (CTACsub), on December 22nd, 2020. This outlined the recent decision of the European Commission to authorise five out of the six applied for essential uses of chromium trioxide (EC 215-607-8; CAS 1333-82-0).
Following the UK’s withdrawal from the EU and the end of the transition period the EU REACH legislation has been brought into UK law. The key principles of the EU legislation has been retained, and it is now known as UK REACH.
To be able to continue using Chromium trioxide as a downstream user certain obligations have to be met.
- Confirm to the HSE that you are an existing authorised downstream user. Further details are available of the H&S website. This has to be completed within 60 days from the end of the transition period, and has been termed “Grandfathering”.
- Information regarding any existing applications that have not yet been finalised by ECHA must have the dossier re-submitted to the HSE.
- Any new applications, from January 1st, 2021 must be submitted to the HSE.
- Check, assess and implement exposure scenarios.
- Implement a workplace exposure monitoring programme, according to good practice guidelines by June 18th
Please note that any dossiers of information submitted to the HSE have to be completed using IUCLID. A download of the software is available on the IUCLID 6 or ECHA websites. The use of this software is one of the requirements, and there are “How to subscribe as a downstream user” videos available on internet video platforms such as you tube.
Stowlin have provided data sheets to their customers to assist in their obligations that have been placed upon them as downstream user. Please contact your local salesperson if you need copies of the data sheets, or if you need to ensure that you have the latest version.
If all of this sounds a little daunting and to assist in your understanding, the chromium trioxide consortium held a webinar on January 15th. If you were unable to take part in the webinar slides and a video will be available after the event has taken place, and they can be found at. You will also find a whole array of further information, including good practice sheets which are listed under the “substances” tab.
So if there are any downstream users that have any questions relating to the above, please contact either your local sales person or direct your correspondence to. All the best with your applications.
