Solid metal and metal alloy risks must be tested in actual conditions
The seminar ‘Refining the Classification of Metals and Alloys to Enable Non-toxic Society and Circular Economy’ organised by the Technology Industries of Finland and the Association of Finnish Steel and Metal Producers gathered European top experts together to solve a concrete problem with the classification of alloys. The seminar was a continuation of the ‘Non-toxic Environment’ seminar organised last autumn in Sweden by the Jernkontoret.
The seminars also discussed the legislation on metals being prepared in the EU more widely. This is a topical issue, because at worst, the EU legislation (CLP Regulation 1272/2008 on the classification, labelling and packaging of chemicals) may lead to alloys being considered as hazardous to humans even when they have been in use for decades and proven to be safe, such as stainless steel cutlery or building services products made out of brass. Such a classification is not only scientifically unsound, but also extremely problematic concerning the implementation of circular economy in the EU.
In the keynote address of the seminar, Urban Boije af Gennäs from the European Commission stated that a corrective review is in progress concerning the EU regulations on non-toxic environment, such as the CLP classification. Insufficient information on substances that are a cause for concern is seen as a challenge, as well as defining and tracing such substances in the circular economy.
Professor Inger Odnevall Wallinder from KTH emphasised that the inherent characteristics of stainless steel are completely different from the characteristics of its alloying components or impurities as separate substances. This means that the risk of alloys cannot be assessed based on their alloying components. For this reason, the concentration of nickel or chromium in stainless steel, for example, does not predict the risk of the usage of the alloy metal like stainless steel. A more accurate way to analyse the solubility of substances would be to expose the products to actual conditions.
Violaine Verougstraete, EUROMETAUX, and Adriana Oller, NIPERA, proposed an alternative method for the CLP classification of alloys. The method is based on determining the dissolution of alloying compounds from the alloys, i.e. the bioelution. This requires confirmed and standardised instructions for determining solubility.
Camilla Kaplin, Outokumpu, noted that while the legislation does recognise alloys as a separate group, special mixtures, it does not provide instructions on how to regulate these special mixtures. The problem must be corrected, because the situation causes uncertainty in the industry, and applying for exemptions takes a very long time.
Kaplin also noted that the CLP classification affects the legislation on the value chain of a very large number of products. For example, the Act on Public Procurement and Concession Contracts includes a section stating that an environmental label may be required in connection with a tender, and the EU Ecolabel Regulation applies criteria based on the CLP Regulation.
For further information:
Association of Finnish Steel and Metal Producers
Advisor, Chemical Policy
Technology Industries of Finland