COMMENTS AND RESPONSE TO COMMENTS ON AUTHORISATION
Substance name: Lead chromate molybdate sulphate red (C.I. Pigment Red 104)
EC number: 235-759-9
CAS number: 12656-85-8
Broad information on use applied for (title): Distribution and mixing pigment powder in an industrial environment into solvent-based paints for non-consumer use
Consultation number: 0012-02
Applicant name: DCC Maastricht B.V. OR
Consultation period: 12/02/2014 - 09/04/2014
Reference number and date: / Submitter: / Alternative: / Attachments:Type / Generic name / EC Number / CAS Number / Description of technical alternative / Classification and Labelling
Ref.No: 516
Date: 2014/04/09 / Affiliation:
BehalfOfACompany
Type/Role in the supply chain:
Downstream User
Name of org/company:
Pronto Industrial Paints Ltd
Country:
United Kingdom / SubsInMixture / Scarlet Chrome Blended Colour / CLP
Not Hazardous / Comment_516_Attachment.doc
Applicants’ response:
Applicants reply to comments 516, 517, 518
Contributing third party: Pronto Industrial Paints LtdECHA consultation numbers 0012-02, 0012-04, 0012-06
DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PY.34 or PR.104.DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PR.104 to allow for the continued use of PR.104. The proprietary pigments from three multinational manufacturers, evaluated by Pronto Industrial Paints Ltd, lacked the chroma, cleanliness, shade functionality, opacity and dispersibility to be considered viable PR.104 alternatives. In addition to compensate for its lack of shade functionality, these pigments must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.
We agree to another important aspect of the comment submitted by Pronto Industrial Paints Ltd being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PR.104) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.
In addition to the increase of costs, the submitted comment by Pronto Industrial Paints Ltd also supports the applicant’s view on the lack of availability for the alternatives. In other words the proposed alternatives are not able to cover the total volume of PR.104 related to the uses applied for.
DCC notes that the Pronto Industrial Paints Ltd submission supports its application for authorisation for the continued use of PR.104.
Reference number and date: / Submitter: / Alternative: / Attachments:
Type / Generic name / EC Number / CAS Number / Description of technical alternative / Classification and Labelling
Ref.No: 507
Date: 2014/04/08 / Affiliation:
BehalfOfACompany
Type/Role in the supply chain:
Downstream User
Name of org/company:
Pronto Industrial Paints Ltd
Country:
United Kingdom / SubsOnItsOwn / Diketopyrrolopyrrole (DPP) Red – C.I. Pigment Red 254 / CLP
Not Hazardous / Comment_507_Attachment.doc
Applicants’ response:
Applicants reply to comments 507, 508, 509
Contributing third party: Pronto Industrial Paints LtdECHA consultation numbers 0012-02, 0012-04, 0012-06
DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PR.104, namely PR.254.DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PR.104 to allow for the continued use of PR.104. In support of Pronto Industrial Paints Ltd’s submission, PR.254 simply lacks the durability, shade functionality, opacity, solvent resistance and dispersibility to be considered a viable PR.104 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.
We agree to another important aspect of the comment submitted by Pronto Industrial Paints Ltd being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PR.104) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.
In addition to the increase of costs, the submitted comment by Pronto Industrial Paints Ltd also supports the applicant’s view on the lack of availability for the alternative. In other words the proposed alternative PR.254 is not able to cover the total volume of PR.104 related to the uses applied for.
DCC notes that the Pronto Industrial Paints Ltd submission supports its application for authorisation for the continued use of PR.104.
Reference number and date: / Submitter: / Alternative: / Attachments:
Type / Generic name / EC Number / CAS Number / Description of technical alternative / Classification and Labelling
Ref.No: 504
Date: 2014/04/08 / Affiliation:
BehalfOfACompany
Type/Role in the supply chain:
Downstream User
Name of org/company:
Pronto Industrial Paints Ltd
Country:
United Kingdom / SubsOnItsOwn / Napthol Red – C.I. Pigment Red 170 / 2786-76-7 / CLP
Not Hazardous / Comment_504_Attachment.doc
Applicants’ response:
Applicants reply to comments 504, 505, 506
Contributing third party: Pronto Industrial Paints LtdECHA consultation numbers 0012-02, 0012-04, 0012-06
DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PR.104, namely PR. 170.DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PR.104 to allow for the continued use of PR.104. In support of Pronto Industrial Paints Ltd’s submission, PR.170 simply lacks the durability, shade functionality, opacity and dispersibility to be considered a viable PR.104 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.
We agree to another important aspect of the comment submitted by Pronto Industrial Paints Ltd being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PR.104) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.
In addition to the increase of costs, the submitted comment by Pronto Industrial Paints Ltd also supports the applicant’s view on the lack of availability for the alternative. In other words the proposed alternative PR.170 is not able to cover the total volume of PR.104 related to the uses applied for. Also issues with raw material availability or lack of process capacity could impact the availability of the proposed alternative PR.170.
DCC notes that the Pronto Industrial Paints Ltd submission supports its application for authorisation for the continued use of PR.104.
Reference number and date: / Submitter: / Alternative: / Attachments:
Type / Generic name / EC Number / CAS Number / Description of technical alternative / Classification and Labelling
Ref.No: 501
Date: 2014/04/08 / Affiliation:
BehalfOfACompany
Type/Role in the supply chain:
Downstream User
Name of org/company:
Pronto Industrial Paints Ltd
Country:
United Kingdom / SubsOnItsOwn / Naphthol Red – C.I. Pigment Red 112 / 6536-46-2 / CLP
Not Hazardous / Comment_501_Attachment.doc
Applicants’ response:
Applicants reply to comments 501, 502, 503
Contributing third party: Pronto Industrial Paints LtdECHA consultation numbers 0012-02, 0012-04, 0012-06
DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PR.104, namely PR. 112.DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PR.104 to allow for the continued use of PR.104. In support of Pronto Industrial Paints Ltd’s submission, PR.112 simply lacks the durability, shade functionality, opacity, solvent resistance and dispersibility to be considered a viable PR.104 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.
We agree to another important aspect of the comment submitted by Pronto Industrial Paints Ltd being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PR.104) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.
DCC notes that the Pronto Industrial Paints Ltd submission supports its application for authorisation for the continued use of PR.104.
Reference number and date: / Submitter: / Alternative: / Attachments:
Type / Generic name / EC Number / CAS Number / Description of technical alternative / Classification and Labelling
Ref.No: 498
Date: 2014/04/08 / Affiliation:
BehalfOfACompany
Type/Role in the supply chain:
Downstream User
Name of org/company:
Pronto Industrial Paints Ltd
Country:
United Kingdom / SubsOnItsOwn / Diketopyrrolopyrrole (DPP) Orange – C.I. Pigment Orange 73 / 13515-40-7 / CLP
Not Hazardous / Comment_498_Attachment.doc
Applicants’ response:
Applicants reply to comments 498, 499, 500
Contributing third party: Pronto Industrial Paints LtdECHA consultation numbers 0012-02, 0012-04, 0012-06
DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PR.104, namely PO.73.DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PR.104 to allow for the continued use of PR.104. In support of Pronto Industrial Paints Ltd’s submission, PO.73 simply lacks the chroma, durability, shade functionality, opacity and dispersibility to be considered a viable PR.104 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.
We agree to another important aspect of the comment submitted by Pronto Industrial Paints Ltd being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PR.104) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.
In addition to the increase of costs, the submitted comment by Pronto Industrial Paints Ltd also supports the applicant’s view on the lack of availability for the alternative (i.e. only two major suppliers, BASF & CINIC). In other words the proposed alternative PO.73 is not able to cover the total volume of PR.104 related to the uses applied for.
DCC notes that the Pronto Industrial Paints Ltd submission supports its application for authorisation for the continued use of PR.104.
Reference number and date: / Submitter: / Alternative: / Attachments:
Type / Generic name / EC Number / CAS Number / Description of technical alternative / Classification and Labelling
Ref.No: 495
Date: 2014/04/08 / Affiliation:
BehalfOfACompany
Type/Role in the supply chain:
Downstream User
Name of org/company:
Pronto Industrial Paints Ltd
Country:
United Kingdom / SubsOnItsOwn / Benzimidazalone Orange – C.I. Pigment Orange 36 / 12236-62-3 / CLP
Not Hazardous / Comment_495_Attachment.doc
Applicants’ response:
Applicants reply to comments 495, 496, 497
Contributing third party: Pronto Industrial Paints LtdECHA consultation numbers 0012-02, 0012-04, 0012-06
DCC has one of the widest ranges of PY.34 and PR.104 alternatives, including organic, inorganic and hybrid blend pigments. DCC has been offering these for many years and as such is well versed in the difficulties and complexities in attempting to replace both PY.34 and PR.104 due to the compromises in performance that has to be made. The possible alternatives were presented in our Analysis of Alternatives (AoA). This document demonstrated that every alternative had shortcomings that dismissed them as candidates for 1:1 substitution of PR.104, namely PO.36.DCC notes that the comments submitted by Pronto Industrial Paints Ltd are in favour of approving the authorisation of PR.104 to allow for the continued use of PR.104. In support of Pronto Industrial Paints Ltd’s submission, PO.36 simply lacks the chroma, shade functionality, opacity and dispersibility to be considered a viable PR.104 alternative. In addition to compensate for its lack of shade functionality this pigment must be mixed with other pigments to attempt to match required shade targets resulting in unacceptable metamerism.
We agree to another important aspect of the comment submitted by Pronto Industrial Paints Ltd being the final cost impact in case an Authorisation is not granted. It is stated that the use of alternative substances (with prices about 2-10 times higher compared to PR.104) will impact the profitability of the company and endanger the competitiveness to companies active outside of the EU.
In addition to the increase of costs, the submitted comment by Pronto Industrial Paints Ltd also supports the applicant’s view on the lack of availability for the alternative (i.e. limited to <10 significant suppliers). In other words the proposed alternative PO.36 is not able to cover the total volume of PR.104 related to the uses applied for. Also issues with raw material availability or lack of process capacity could impact the availability of the proposed alternative PO.36.
DCC notes that the Pronto Industrial Paints Ltd submission supports its application for authorisation for the continued use of PR.104.
Reference number and date: / Submitter: / Alternative: / Attachments:
Type / Generic name / EC Number / CAS Number / Description of technical alternative / Classification and Labelling
Ref.No: 492
Date: 2014/04/08 / Affiliation:
BehalfOfACompany
Type/Role in the supply chain:
Downstream User
Name of org/company:
Pronto Industrial Paints Ltd
Country:
United Kingdom / SubsOnItsOwn / Disazo Orange – C.I. Pigment Orange 34 / 15793-73-4 / CLP
Not Hazardous / Comment_492_Attachment.doc
Applicants’ response:
Applicants reply to comments 492, 493, 494