Note re. Need for Chromium Alloys CSR

This Note responds to questions the Chromium Alloys Consortium has received from some SIEF members asking why it is necessary to have access to a separate Chemical Safety Report (CSR) for Ferrochromium (FeCr) and Ferrosilicochromium (FeSiCr). Representatives of the Consortium met with the ECHA in September 2009, and were told in no uncertain terms that FeCr and FeSiCr will need to be registered as special preparations under REACH. As such, there is the need to:
1) Register Fe, Cr, and Si, respectively
2) Submit a CSR that address the properties and uses of the alloys.

As part of the Registration, Companies that produce/ import > 10 tonnes of the component metals as part of the alloys will need a Chemical Safety Report (CSR) for the alloy. Indeed, if your registration deadline is 30 November 2010 for Iron (Fe), Chromium (Cr), or Silicon (Si), either because you produce/import a sufficient amount of the alloy or a sufficient amount of the individual component metals to trigger a 2010 registration date, you will already need a CSR for that portion of the tonnage that is due to FeCr/ FeSiCr to cover the hazard and uses of the alloys. Although the Iron Platform, Chromium Metal Consortium and Silicon Consortium will be preparing CSRs for the individual metals, these CSRs will not cover the hazards and use of the individual metals in the FeCr/FeSiCr alloys.

The CSRs for FeCr and FeSiCr will each refer to the hazard data on Fe, Cr, and Si, but will also assess the way the individual metals are bonded into the chemical matrix, and include reference to impurities and other features specific to the alloy in question.

The CSRs for FeCr and FeSiCr contain data from tests carried out by the Swedish Royal Institute of Technology (KTH) into the release of component metal ions into various artificial biological fluids, as well as extensive analysis by researchers at the Finnish Institute of Occupational Health (FIOH). The CSRs address all of the necessary endpoints for both of the alloys (REACH Annexes VII-X inclusive). The CSRs also include OECD transformation/dissolution protocol (T/DP) tests that are very important for assessing the potential ecotoxicity of the alloys.

We recognise that Registrants of the FeCr/FeSiCr alloys would prefer to simply register the component metals and not have to obtain separate access to the alloy CSRs, but REACH requires that the alloys be assessed in the CSR and, as noted above, it has required considerable data and investigation to be able to assess the FeCr/ FeSiCr alloys.

We specifically want to direct your attention to the following additional information on the Chromium Alloys Consortium portion of the website: