Submission of Information on ALTERNATIVES (NON-CONFIDENTIAL)
Submission of information on
Template
for third party submission of information on alternatives for
Applications for Authorisation
non-confidential
Legal name of submitter(s): AkzoNobel N. V. , the Netherlands
Table of CONTENTS
1. alternative ID and properties 3
2. Technical feasibility 3
3. Economic feasibility 3
4. Hazards and risks of the alternative 3
5. Availability 4
6. Conclusion on suitability and availability of the Alternative 4
7. other comments 4
References 4
APPENDIXES 5
1. alternative ID and properties
A range of alternatives to lead chromate pigments have been commercially available for many years.
Examples include :
· Bismuth vanadates (CAS 14059-33-7)
· Mixed metal oxides (CAS 80078-18-9, CAS 68186-90-3) / iron oxides[1] (CAS 51274-00-1, CAS 1309-37-1)
· Organic pigments (eg Diketopyrrolo-pyrrole (DPP), azos, Isoindoline, benzimidazolones)
A formulated mixture of the above is often required to achieve the required performance of the end product, depending on the product type and end-use involved.
2. Technical feasibility
The pigments above can be used alone, as hybrids and in formulated mixtures with other pigments to obtain the desired coating product characteristics and performance[2] at a cost acceptable in the markets in which we operate.
3. Economic feasibility
See 2.
4. Hazards and risks of the alternative
GHS classification for the alternatives to lead chromate below show them to be less hazardous than lead chromate for both human health and the environment, ie.
CAS number of alternative / GHS classification14059-33-7 / H373
8007-18-9 / Unclassified
68186-90-3 / Unclassified
51274-00-1 / Unclassified
1309-37-1 / H411
Lead Chromate / GHS classification
7758-97-6 / H350, H360, H373, H400, H410
5. Availability
The alternatives to lead chromate pigments that are used in AkzoNobel products are commercially available in the European Union and throughout the world.
6. Conclusion on suitability and availability of the Alternative
AkzoNobel withdrew from the use of all lead compounds (including lead chromates) in all products throughout the world from the end of 2011.
Since taking this action it is clear that the performance achieved with lead chromate-free products has met the requirements of the customers in our markets. In transition we experienced no resistance to the introduction of lead chromate-free coatings from customers, neither have we lost business on account of supplying products free of lead chromates.
7. other comments
On the basis of experience in the markets in which we operate, AkzoNobel maintain that technically effective, economically feasible and safe products are available that do not contain lead chromate pigments.
These products meet our customer requirements, are available globally and include the following uses relevant to the application for this authorization:
(i) Production of yellow and red colour paste/dispersions for use in manufacture of solvent based coloured paints
(ii) Industrial application of coatings to metal surfaces of non-consumer articles including high grade steel-based products (eg. Piping used in the petrochemical industry, crane arms, agricultural machinery, steel bridges, construction arches and coil coating for roofing, ships and boats).
(iii) Professional application of coatings to metal surfaces of non-consumer articles including high grade steel-based products (eg. Piping used in the petrochemical industry, crane arms, agricultural machinery, steel bridges, construction arches, ships and boats).
8. References
Paint square – Paint and coatings industry news (2012). International Paint drops lead chromate. Link :
http://www.paintsquare.com/news/?fuseaction=view&id=8186
Removing lead from coil coatings – AkzoNobel website. Link :
https://www.akzonobel.com/ccna/coil_coatings/leadfree/
9.APPENDIXES
9.1 Information about AkzoNobel :
AkzoNobel is a leading global paints and coatings company, supplying to customers in our market sectors throughout the world. The end-user segments for our coatings products include :
(i) Buildings and infrastructure[3]– manufacture and supply of coatings for protection, decoration and maintenance of bridges, offshore and onshore infrastructure, the interior and exterior of commercial buildings and residential dwellings and coil coatings applied to roofing. Products are supplied for both new build projects and for maintenance, renovation and repair.
(ii) Transportation³ – includes manufacture and supply of coatings for all interior and exterior surfaces of ships and boats and the aftermarket refurbishment and modification of cars, trucks and other vehicles. We also supply paints for components of cars, trucks and commercial vehicles.
(iii) Industrial³ – includes coatings for assets of the oil and gas, metals, mining, water, power and agriculture industries.
(iv) Consumer goods – includes coatings for wood furniture and domestic appliances.
AkzoNobel are committed to providing sustainable solutions to our customers. We consider product stewardship to be a key element of sustainability and that it is critical to ensure our products and processes do not pose a danger to people or the environment. We are constantly striving to introduce safer products into the market and in 2011 we became the first global paint company to completely phase-out the use of all lead compounds from all of our products and processes throughout the world. This prohibition is enforced under our company Product Stewardship program through a mandatory standard which includes a ban on the use of all lead compounds as pigments in all of our paints in all of our end-user segments.
AkzoNobel took this stance having proven that safer and effective alternatives to lead chromate pigments are available which can be formulated to work effectively in all our products from both a technical and economic perspective.
9.2 Comment on coatings used for road markings
As regards coatings used for road marking on public roads, in car-parks and airports, we do not believe use of lead chromates is technically necessary and believe that continued use is undesirable from a human exposure and environmental perspective (flaking). However we do recognise that there may be specifications based on colour for roads (i.e. bright yellow, bright red) which are historically based on previously approved products/formulations containing lead chromate. The widespread acceptance of lead chromate-free products in this sector will require approval prior to widespread adoption in the marketplace.
Consultation numbers : 0012-01, 0012-02, 0012-03, 0012-04, 0012-05, 0012-6, 0012-11, 0012-12
7th April 2014
3
[1] Examples include “Solaplex” and “Sicopal” products from the Rockwood and BASF companies
[2] Key performance attributes include shade, opacity, colour and gloss retention, coating durability.
[3] Includes uses in coatings discussed in REACH authorisation consultation number 0012-01, 0012-02, 0012-03, 0012-04, 0012-05, 0012-06.