5.1  Project description
As far back as 2014, a wide gap between practical working methods on baths in surface finishing businesses and applicators’ and experts’ knowledge about the risks was found to have developed. This lack of knowledge was found not just among industry experts, but also among the inspectors and those drafting legislative texts.

Vereniging ION was founded in 2014. Its campaign slogan: ‘Replace what you can, authorise what you have to – but do it safely!’ – a motto that fits with the business world’s obligation towards minimisation. One government website reads: ‘If a business emits a very alarming substance into the air, that business is obligated to try to prevent this emission. If this is not possible, the business is obligated to limit the emission toa minimum’. This so-called minimisation-obligation is found in article 2.4 section 2 of the Activities Decree, and also applies in terms of a business’ requirement to apply the best available technology and/or reduce emission concentration of a particular substance to below the maximum allowable risk level. The minimisation-obligation is a continued strive for the reduction of emission.

In addition to emission minimisation, the government explicitly wants to realist a zero-level health risk for employees working with very alarming substances through its ‘Road to zero’-project, started in 2015. Incidentally, this project is subject to the context of feasibility: if zero emission proves unachievable, a business must demonstrate that it has done everything in its power to ensure emission value is a close to zero-level health risk as possible, and must also demonstrate that it has at least managed to keep emission below the exposure limit (SER list - https://www.ser.nl/grenswaarden).

Emission and exposure minimisation can be achieved in several ways: substitution, new cleaning and/or production technology, or business operation adjustments. Another goal of the minimisation obligation is to promote innovation.

It should be noted that, for a number substances in partial applications, an alternative is available, in which case a business must find way to interpret the minimisation-obligation. However, in a number of cases, no (proven) alternative is available. Here, the focus should be on applications, not on substances. For such applications, safe working methods should be reviewed.

Over the past years, the industry has invested a great deal of time and energy into replacing, for example, chromium trioxide. In the Netherlands alone, the estimated sum involved has been calculated at € 50 million. In addition to safer working methods, separation through (1) division, (2) capping, (3) extraction, and (4) personal protective equipment have been reviewed. Often, a combination of several strategies is used.
Ad 1:  A process implementation that involves employees spending as little time as possible around process baths has been reviewed.
Ad 2:  Various methods of capping baths have been reviewed, including automated lids, hoods, balls, or liquids.
Ad 3:  Edge extraction, push/pull extraction, and in-building airflows have been reviewed.
Ad 4:  The personal protective equipment required in case other measures fail to offer adequate protection have been reviewed.

Chromium trioxide is the first ‘major processing substance’ to be authorised under REACH, which is why it has been given such a high degree of attention. The fact that, nearly two years after the sunset date, not authorisation regime has yet been implemented shows the exceptional complexity of what is at stake. The fact that this issue involves a processing substance is emphasised as, during the production process, it is converted into a harmless substance. In situations where the end product does contain substances of very high concern, a different regime will apply.
Chromium trioxide is reviewed in relation to two different processes. The first is a process in which hydrogen (H2) is created through as a consequence of the process (aerosols). The second process only uses submersion (no aerosols). Many other processing substances are expected to follow chromium trioxide in this process.

It should be noted that chromium Chromium-6 is a potential ingredient of certain paints, and that sanding or cutting may be an issue. We will process this information as part of the project.

This study has also been linked to the EU chromium trioxide project (biomonitoring) being performed by Radboud University Medical Centre.

Never before has there been a study into the cohesion of measures at such a scale. Until now, optimisation was mainly attempted at the individual level, while remaining within benchmark values. In practice, this led to a great deal of debate, high costs, and suboptimal solutions, with only individual businesses working on improvements.

The working method aligns with the structure of Inspectorate SZW (industry agency taking the lead in safe working methods) and offers a framework for (future) policy. It is therefore of crucial importance that Inspectorate SW support the approach, and will later implement it in its performance of inspections. The intended safe working methods are also a supplement to 5xbetter.
There is a need for performing measurements, since models result in an incorrect value too often. This is mainly due to the large spread of substances throughout mixtures, and to incomplete safety data sheets.

In broad strokes, the goal of this project is:

  • Establishing a safe working method.
  • Compiling a list of possible measures.
  • Validating the effects of these measures on both employees and environments.
  • Preventing debate regarding the effects of the measures on the working floor.
  • Simplifying audits and inspections.

The project’s result is to be a ‘catalogue of measures’ that will help businesses to make the best possible decisions. Its impact is to be detailed in an e-book with clickable links to relevant regulations and legislation, and where safe working methods are linked to exposure risk levels. Here, input from Inspectorate SZW is vital, as this is the body that will eventually be tasked with assessing the quality of the decisions. The basis for the measurements is NEN-EN 689-2018.

To establish safe working methods, over six companies will be visited for each substance. So far, a limited number of substances has been selected, all of them often found in the industry. Their common characteristic is that health risk due to the exposure to these substances is a recurring issue. Several of these substances can be designated so-called markers. For chromium trioxide, two variant processes are reviewed. Since, however, certain substances occur in a mixture (see tin or nickel), a large number of measurements must be taken.

Since a search for alternatives to the substances concerned is also ongoing, particulate matter released during thermal spraying will also be included in the assessment – since thermal spraying is considered an alternative to chromium trioxide. In practice, this procedure results in particulate matter that probably contains a percentage of Chromium-6.

De-coating/removal of Chromium-6-based paints will also be reviewed. In the industry, the process of applying a new coating begins with paint removal as standard – either in a building, or on-site. Both aspects will be reviewed.

5.2  Selected CMR substances in baths
The following is a list of substances which, as deemed by Vereniging ION, should be measured both in the distinct stages and in relation to the possibilities for preventing exposure. Supplements, suggestions, and ideas are very welcome.

It should be evident that none of the businesses are affected by all of these situations. However, by combining the insights and measurements obtained from a large number of businesses will lead to a representative impression that can be used as a basis for determining a safe working method.

The objective is to implement validation using the ISO689 standard as a basis for determining:

  1. Benchmark values per substance.
  2. Exposure time per employee (category) per substance.
  3. Substance emissions into the environment.

Ad 1:  Pursuant of the SER list.
Ad 2:  Time can be registered by using a stopwatch or analysing camera images. Substance exposure can be established by equipping employees with measuring devices.
Ad 3:  Environmental emissions can be established through ventilation system exhaust measurements.

The current list of substances intended for review is:

  1. Nickel sulphate (case no. 7786-81-4).
  2. Nitric acids (case no. 7697-37-2).
  3. Hydrogen fluoride (case no. 7664-39-3).
  4. Sulphuric acid (case no. 231-639-5).
  5. Chromium trioxide (case no. 1333-82-0) in 2 conditions (with and without aerosol production (H2)).
  6. Tin sulphate (case no. 7488-55-3).
  7. Hydrochloric acid (case no. 7647-01-0).
  8. Particulates emitted during thermal spraying (particularly the Chroom-6 fraction).
  9. Paint substances emitted during sanding/cutting (particularly the Chroom-6 fraction).
  10. A cobalt-based compound where possible.
  11. PFASs in electroplating.
  12. Isocyanates.

The current list of stadia (where distinguishable) is:

  1. Exposure during the standard process (product suspended in the bath).
  2. Exposure during filling/draining the baths.
  3. Exposure during preparing or cleaning the baths.

The following provisions for prevention of exposure are to be determined and reviewed:

  1. Capping baths with lids.
  2. Capping baths with balls.
  3. Capping baths with foam.
  4. Using cabinets on a pully-system (with and without extraction).
  5. Edge extraction.
  6. Edge extraction using push/pull.
  7. In-building airflow (away from the employee, relative to the bath).
  8. Cathode and anode bags
  9. Other ideas and solutions.

Project planning

Phase/activity Result Date Participants
Step 0: Initialisation Budget available
Plan of approach approved by Inspectorate SZW
Q1 2019 Veiligheid Voorop, RVO, NGO en Inspectorate SZW
Step 1: Inventory Shortlist Q1 2019 Vereniging ION en businesses
Step 2: Validation Validated dataset per substance Q1 en Q2 2019 Businesses and research institutions
Step 3: Determining safe working methods Process descriptions Q2 en Q3 2019 Inspectorate SZW, Vereniging ION and 5xbeter
Step 4: Communicating results; compiling e-book Coherent description of results Q4 2019 Vereniging ION and businesses

5.3  Supplemental notes
The project is implemented in collaboration with a large number of companies in the industry. Other parties that are (or have been) active, are:
•    Radboud University Medical Centre for biomonitoring
•    Royal Haskoning/DHV for environmental measurements
•    RPS and DH-Pro for business measurements
•    5xbetter and Inspectorate SZW for synchronising the results with existing structures and inspectorates
•    RVO (Netherlands Enterprise Agency)
•    Veiligheid Voorop (Safety First)
Where needed, results can also be used at the European level.