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ADCR Consortium
Update: Guidance documents on monitoring worker exposure to chromates will soon be available on this website
Authorisation requirements and past Authorisation work for the use of chromates in the EU
Critical uses of chromates (see footnote) throughout the entire A&D industry are at risk – this impacts both users of the chromates or chromates-based formulations and manufacture of chromate-containing parts and components.
In the EU, such uses require Authorisation under the REACH Regulation – Authorisation is for specific uses and is granted by the EU Commission for a specific period of time (the “review period”). It is not possible to continue to use these chromates without Authorisation. A vital element of Authorisation is that users must be engaged in looking for less hazardous, more suitable, alternatives.
Authorisation for the uses of these chromates in the A&D supply chain has been applied for, but it will be necessary to re-apply to extend the review period. This is because the review period for many uses will be shorter than needed for finding and moving to suitable alternatives, which means the Authorisation will expire while the continued use remains essential. This will particularly be the case for legacy spare parts.
Moreover, the EU Commission places conditions on Authorisations that are granted, as standard practice. For some companies in the A&D sector, these conditions may be too restrictive and mean that a company’s uses are not covered by the original authorisation. This in turn means a new application for Authorisation for these uses is required.
© Rolls-Royce 2019 – all rights reserved
Chromates of relevance include;
Chromium trioxide, sodium chromate, sodium dichromate, dichromium tris(chromate), potassium dichromate, strontium chromate, pentazinc chromate octahydroxide
and potassium hydroxyoctaoxodizincatedichromate.
The way forward – A new round of REACH Authorisations for the A&D Sector by the ADCR
A new consortium, the Aerospace and Defence Chromate Reauthorisation Consortium has been formed to address the above challenges. The ADCR is now open to new members. Importantly, ADCR membership is open to all companies in all A&D supply chains.
The key principles underlying this consortium are detailed in the Consortium Agreement:
- These will be sector authorisation applications and will be submitted by upstream applicants;
- End users will pay for dossier preparation and application fee costs; dossier preparation costs will be use- specific, and take into account the number of ADCR members applying for that use;
- Upstream applicants will be non-paying members;
- This is an Aerospace and Defence focused consortium, with any exceptions only by agreement, and with costs borne accordingly;
- Uses will be defined more narrowly so as to avoid any uncertainty, will be linked and therefore traceable to the original uses applied for in the first round of applications;
- Lessons learned from the first round of applications will guide the overall strategy to making these applications and to the level of detail within the applications;
- New applications / applicants are welcome;
- UK REACH Authorisations are within scope if required in addition to EU REACH.
Crucially, uses under the ADCR authorisations will be more targeted in order to address issues raised by the authorities concerning the original applications.
The biggest business risk facing A&D companies and their supply chains is assuming that someone else will take care of their REACH authorisation needs. If A&D companies are not covered by an authorisation, they need to apply for authorisation urgently. If A&D companies are covered by an authorisation, reauthorisations will be for more specific (narrower) uses than previously, so they must become active to ensure their uses continue to be covered. A&D companies therefore need to act and they need to act now.
To find out more about how to manage your A&D chromates authorisation business risks and find out more about the ADCR please contact: