- Actively addressed the critical issue of lead’s candidate listing for REACH authorisation
- Advanced a refined test method for determining corrosivity of solid bulk cargoes, replacing a test that gave erratic results for copper concentrates
- Harmonised hazard classifications of granulated copper, setting a positive precedent for assessments of other copper forms
In June, lead metal became a candidate for authorisation under Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), as a result of its classification as a Category 1A reproductive toxicant. The listing triggered obligations, under certain conditions, for suppliers to notify the use of lead in articles to the European Chemicals Agency (ECHA), to communicate safe use information and to respond to customer requests.
The legislative process aiming to make the uses of lead metal authorisable under REACH will have major impacts on the use of lead in copper alloys and in copper recycling streams. ECI is working closely with the International Lead Association (ILA) to inform members and the value chain, as well as to design and execute an extensive advocacy strategy. We question the proportionality and regulatory effectiveness of authorisation as a risk management measure. Hence we support the position that any residual risk related to the current use of lead metal is better managed through targeted REACH restrictions combined with a revision of workplace exposure limits.
Under an ECI initiative, the copper industry undertook an extensive research program to address the challenges posed by various regulatory bodies in Europe that wish to impose stricter limits for copper in ambient workplace air. We gave an invited presentation of industry views on copper occupational exposure limits (OEL) to the European Commission’s Working Party on Chemicals in June, and they opted to delay implementation of the Steering Committee on OEL proposal (10 µg/m3 respirable copper in an eight-hour Time Weighted Average exposure) and remove copper from the 5th Adaptation to Technical Progress (ATP) list of the Chemical Agents at Work Directive 98/24/EC.
Pivotal factors for the EU and German regulatory bodies to delay their decisions included the industry’s positive attitude and willingness to investigate the actions of copper particulates in lungs, and perform a comprehensive analysis on findings from long-term observations of workers. On the latter, an independent ethics committee recently granted authorisation to ECI and the International Copper Association to perform an epidemiological study of worker health at one of the largest copper smelting plants in Europe. We hope the Working Party will delay their final decision until the assessment of medical data from workers is available.
In September, the International Maritime Organization agreed in principle to a refined method for testing the corrosivity of solid bulk cargoes. This marks a major milestone in the mining and metals industry’s mission to overcome issues with the initial regulatory test method, which exhibited erratic results and classified all copper concentrates as “corrosive to metals”. We developed and validated the refined test method for copper concentrates, and provided technical and strategic direction to a global industry alliance specifically formed to address this issue. The outcome of this work ensures the copper industry can avoid an estimated 150 million USD of additional transportation and safety costs.
The REACH Copper Consortium joined the newly-established Metals and Inorganics Sectorial Approach (MISA), a framework of cooperation with the European Chemicals Agency to improve registration dossiers and advance technical and scientific issues. In preparation for the first workshop on human health endpoints, we reviewed the adopted read-across and data adaptation approaches jointly with the Copper Compounds Consortium. Aside from administrative issues, the copper dossier is found to meet expected standards.
Hazard classifications have far-reaching consequences for the industry due to additional legislative requirements, increased transportation costs, stigmatisation and restricted market access. The Committee for Risk Assessment of the European Chemicals Agency ECHA issued an opinion on the harmonised hazard classification of granulated copper. We contributed to the process by providing the ecotoxicity database on copper, by conducting additional tests to address data gaps and regulatory concerns, and by feeding into the public consultation. The outcome of the debate was mostly in line with our views, although some outstanding scientific issues were identified. The assessment of granulated copper provides a reassuring precedent for future assessments of other copper forms and substances.