REACH Chromium Salts Update
Products containing Chromium Salts
REACH regulations regard chemicals as possible hazards to health or the environment. There is also the possibility of it leading to classing chemicals as “Substances of Very High Concern (SVHC’S)”. They can also be included in annexe XIV of the regulations. This happens when you place a sunset date on the use of the chemical. The chemicals will not be available to sell or use within the EU. This is unless you get authorisation from the European Chemicals Agency, ratified by the European Commission.
Chromium salts are also in annexe XIV. Interested parties do support authorisation for some of them. Indestructible Paint have applied for authorisation for zinc tetroxy chromate. This is for continued use in Rockhard 700-155-003 baking chromate primer to MSRR 9226. As a result, it has been granted an almost unprecedented 12-year recommendation for Authorisation by ECHA. This is due to its current irreplaceable use in certain aeroengine and flying uses. However, there are several that are not. Therefore, these will be unavailable now we have passed the sunset date of January 2019.
Included in these are chromium salts used by Indestructible in the manufacture of IP9165-R1; Skydrol Resistant Primer, and IP9064-4853; Pre-Treatment Etch Primer Base and 588-0066/3.
PLEASE BE ADVISED THAT AS THE SUNSET DATE HAS PASSED THESE PRODUCTS ARE NO LONGER AVAILABLE.
Within the Indestructible range, there are alternative products. These are typically chrome salt-free, and can be considered as replacements. Samples of these can be provided for trials.
It should be remembered that the Rolls-Royce specification MSRR9032, to which IP9165-R1 was approved, was withdrawn several years ago. This was with a recommendation from R-R for the use of MSRR9226 (Indestructible product code 700-155-003).
REACH Registration and Authorisation, Chrome VI & Chrome Salts
Issue 3 – 19 May 2016
Please note that this page will be updated regularly, so please ensure that you are using the latest issue.
We are manufacturers of high-performance aerospace coatings to the aerospace, defence and allied industries. Therefore, Indestructible have a long history of supplying erosion resistant coatings. These traditionally contained hexavalent chromium.
In the late 1990’s we commenced investigation into chrome free alternative anti-corrosive primers. This was for both baking and room temperature cure systems. We worked closely with Pratt & Whitney in Canada, followed by Pratt & Whitney America; the Safran group in France, and the Meggitt group in the UK. Together we developed high performance chrome free primers to meet the exacting standards of these groups. As a result, the approved products have been in successful use for over 10 years. Typical uses are aerospace engineering components including aluminium and magnesium engine parts, helicopter gearboxes and componentry for wheels and braking systems.
We supply these chrome free products alongside our traditional chrome containing products. This includes wash primers, room temperature cure primers and baking primers.
We aim to update the position, and availability of chrome containing products, in the light of REACH restriction and authorisation, environmental issues and client specific requirements.
We have been using a colour key, to try and identify products where we believe hexavalent chrome will be authorised for continued use. Additionally, we’ve also attempted to identify where the chrome will not be authorised for use beyond a sunset date.
Yellow Block: Current products containing hexavalent chrome
Red Block: Indicates products that use chemicals that will not be authorised beyond the sunset date
Blue Block: Indicates products that use chemicals where authorisation is being sought and will we believe have continued availability beyond the sunset date
Green Block: Recently formulated chrome free alternative or replacement product
The REACH regulations came into law throughout Europe about 10 years ago. The purpose is to register and control the use of chemicals within Europe. The law looks at chemicals deemed to be ‘dangerous’ to either people or the environment. It requires to list these chemicals as ‘substances of very high concern’ (SVHC’s).
When you list a chemical as an SVHC, it can be moved into Annex XIV of the regulations. This defines a sunset date. You cannot use the chemical after this date has passed. If you wish to do so, you need to authorisation issued by the Commission. This will be after an investigation by the European Chemicals Agency (ECHA).
Chromium Trioixde and various chrome salts are listed in Annex XIV, and therefore have sunset dates. The chemicals concerned, that affect Indestructible Paint Ltd, are as follows:
Chromium Trioixde (Chromic Acid): CAS No: 1333-82-0 Sunset Date: 21 September 2017
Strontium Chromate: CAS No: 7789-06-2 Sunset Date: 22 January 2019
Zinc Tetraoxy Chromate: CAS No: 49663-84-5 Sunset Date: 22 January 2019
Working towards authorisation
Indestructible are members of two Europe wide consortiums. These have formed to work towards the authorisation of SVHC chemicals to allow continued use for specific applications after the relevant sunset date.
CTAC covers the use of chromium trioxide in specific uses in pre-treatments and sacrificial coatings. A dossier to cover authorisation for continued use has been submitted to ECHA. Although there is no guarantee, it is hoped that an authorisation for continued use will be granted.
CCST covers the use of hexavalent chromium used in anti-corrosive systems. The two main chemicals of interest within this grouping salts are Strontium Chromate and Zinc Tetraoxy Chromate. Strontium Chromate and Zinc Tetraoxy Chromate are being supported in CCST and a dossier submission to ECHA is being prepared.
1. Surface Pre-Treatments
Traditionally we have worked with commercially available hexavalent chrome products, and the aerospace industry have almost universally worked with chrome based systems, to include Alocrom 1200 and similar conversion coatings or Chromic Acid Anodising.
At first it was thoughts that Alocrom 1200 would not be supported, but we understand that Henkel have agreed to support the use of chromium trioxide in chrome based conversion coatings (Alocrom 1200).
DOW 19; chemical conversion coating for magnesium.
As part of our continuous development of new systems, Indestructible have been working on chrome free alternative pre-treatments. Our developments are hexavalent and trivalent chrome free.
IPTREAT 1: silane based adhesion promoter formulated for use with high heat capable coatings, needed force curing, and gave no corrosion protection in its own right. This product is now withdrawn.
IPTREAT 12: chrome free conversion coating, with limited corrosion protection, but excellent adhesive characteristics. Restricts filiform corrosion under chrome free primers. Typically used with aluminium alloys, but has given good results on magnesium. Please contact our Sales Department on +44 (0) 121 702 2485 or on firstname.lastname@example.org to discuss this further.
MagSol: Anti-corrosive Sol-Gel. Initially for magnesium. Currently under test within commercial processes.
2. Sacrificial Coatings
Ipcote Range of inorganic basecoats and seal coats manufactured using hexavalent chrome.
The use of chromium trioxide within these coatings is supported in CTAC and covered in the authorisation request dossier. Products involved:
IP9183-R1 Ipcote sacrificial aluminium basecoat
IP9356 Ipthin thin film aluminium basecoat
IP9442 Smoothcote basecoat
IP9184 Seal coats; typically either Khaki or Green, but other colours to include black and blue
IP9444 Smoothseal seal coat
IP1041 Ipal diffusion coating: for turbine components high temperature and sour gas resistant capability
LR3210 Chrome free touch up basecoats, replacement for PL177 and IP9138-R1 (when burnished)
Organic chrome free alternatives for both basecoats and seal-coats are currently available
LR1715 Organic sacrificial basecoat for high temperature alloys only. Requires processing at 490°C and peening
IP9029-R3 High temperature aluminium coating. It acts as a barrier coat and can be used in place of other basecoats which have not been peened.
J900 Clear organic sealcoat
IP1949 Blue organic sealcoat
Additionally, chrome free alternative basecoats based on inorganic, silicate chemistry are available. These have the draw-back of reduced corrosion resistance, even when used as a sacrificial coating.
We are involved in two Innovate UK funded projects to formulate acidic based, chrome free systems.
AMSCA covers the formulation of a chrome free sacrificial basecoat. The project runs until 2017. Results to date are very encouraging with in excess of 1000 hours neutral salt spray. Linked to the project is additional development of chrome free inorganic sealcoats.
CASCOAT covers the formulation of a chrome free diffusion coating to replace IP1041.
3. Two Component Wash/Etch Primers
Thin film primers used as direct to metal or where no other pre-treatment system is possible. Covered by defence standard Def-Stan 80-15 or aerospace British Standard BSX32. These products are typically formulated on Zinc Tetraoxy Chromate, which is being supported for authorisation in CCST. Please see the CCST Press Release, for further information.
Two Indestructible Products are concerned:
IP80-15 2 pack etch primers to Def-Stan 80-15
IP9064-4853/4854 2 pack wash primer to BSX32
A chrome free alternative, IP3-4853/4854 is available but whilst this gives excellent adhesion, has lower corrosion performance than chrome containing coatings.
Two development products are being evaluated against both the Defence Standard 80-15 and British Standard BSX32:
LR3113 Wash primer formulated on alternative chromate (product available subject to authorisation).
LR3018 Wash primer formulated on latest generation chrome free anti-corrosive pigments.
4. Single Part Air Dry Primers
There are a limited number of ‘basic’ air drying primers still used in high performance applications.
US specification TTP1757 calls for a zinc chromate based primer. This originally also included a lead chromate colour pigment.
IP1757-R1 is now available, still containing chromate, but lead chromate free colour pigments. Development of a non chromate version is ongoing. Please contact our Sales Department on +44 (0) 121 702 2485 or on email@example.com to discuss this further.
IP2066 Chrome free alternative to FE6; single pack AD primer, with excellent steel protection properties.
IP2878 Alternative to Suncorite ‘conversion’ primer. Chrome free holding coat.
5. Two Component Room Temperature Cure Epoxy Primers
These are often used in aerospace applications. They have traditionally been made on strontium chromate. They are covered by multiple international and company-specific specifications. Including BSX33; BS2X33; DTD 5567 (DTD 5555; DTD 5580); MIL-PRF-23377; MSRR 9064.
It is likely that these primers will continue to be available in the short to medium term.
We can offer two variants:
IP9064-6362 Standard VOC 2 component epoxy primer
IP3-6362 Low VOC 2 component epoxy primer
Chrome free alternatives
These product types have seen much development of chrome free alternatives, in the main driven by the requirement of the aerospace primes to utilise chrome free anti-corrosive technology.
Indestructible have been working for over ten years on this technology, and can offer a range of products to varying client and international standards:
IP714: Low VOC Chrome Free Epoxy Primer Grey: CPW 714; PWA36568; SPOP148/155. Meets the performance requirements of BS2X33; MIL-PRF-23377 type N
IP3-6500: Low VOC Chrome Free Epoxy Primer: LB568. Meets the performance requirements of BS2X33; MIL-PRF-23377 type N
IP3-6600: Low VOC Fluid Resistant Chrome Free Epoxy Primer Yellow-Green: Meggitt PRO599 (ML-TR-100031).Meets the performance requirements of BS2X33;MIL-PRF-23377 type N
IP9064-6500: Standard VOC Chrome Free Epoxy Primer. Meets the performance requirements of BSX33; MIL-PRF-23377 type N
Introducing new chrome free anti-corrosive pigments has resulted in new developments of standard and low VOC primers with increased corrosion performance
LR2962 (IP5-2000) Standard VOC: alternative to IP9064-6500 on small components, small volume usage where VOC emissions are not a concern
LRxxxx (IP5-3000) Low VOC, Fluid Resistant: alternative to IP3-6500 and IP3-6700.
Please contact our Sales Department on +44 (0) 121 702 2485 or on firstname.lastname@example.org for the latest product updates.
Building on the need for low VOC primers, but which can be applied as thin films a new range of water based epoxy systems are in development. These utilise latest generation chrome free anti-corrosive pigments. An advantage of the water based resin is a much increased fluid resistance.
6. Baking Systems
We currently offer a range of baking anti-corrosive primers. These are typically for original equipment use including:
- aerospace component
- fan case assemblies
- helicopter components
- wheels and braking systems
The main range is based on our ‘Rockhard 985’ epoxy chemistry, which gives high heat performance up to 220°C, allied to excellent chemical resistance.
Three primers are available that contain hexavalent chrome anti-corrosive systems:
700-155-003 subject to current authorisation activity.
Chrome free alternatives are being formulated. LR2992 contains Chromate (not ‘yet’ listed in Annex XIV). Further formulations are being examined, to replace the chromate anti-corrosive pigments with strontium chromate or chrome free technologies. Please contact our Sales Department on +44 (0) 121 702 2485 or on email@example.com for further details.
588-0060/2 Expected to be covered by authorisation of the chromate in CCST.
588-0060/3 Expected to be covered by authorisation of the pigment in CCST.
Alongside the work from the early 2000’s on the primers, a chrome free baking primer was also developed. This utilises the same anti-corrosive pigment. The product, IP985-6500, has several aerospace approvals. These include ECS2178; LB569; Safran Landing Systems (M-B-D).
A revised primer, LR2965, uses the latest generation of chrome free anti-corrosive pigments. Please contact our Sales Department on +44 (0) 121 702 2485 or on firstname.lastname@example.org for further details.
We also have a higher temperature capable primer available. This can operate up to 300°C. IP9310 is made on strontium chromate. Development of a chrome free alternative, IPCF9310 is ongoing.
7. Polyurethane Primers
There are not often used in the aerospace industry. However, we offer a low VOC polyurethane primer that is chrome free. Product Coding: IP6-6500.
8. Land Based Systems
Indestructible Paint focuses on aerospace coating systems. However, loss of chromate issues arise on land based systems. One of the main primers specified for Defence land vehicles, Def-Stan 80-207, specifies zinc chromate anti-corrosive pigment. REACH have not registered this chemical. Therefore, in theory, it cannot be used within Europe. If Zinc Tetraoxy Chromate has been substituted, this will become available only if authorised. This is not covered under CCST which specifies aerospace use only.
Indestructible Paint is not aware of an authorisation request to cover land based systems. We have chrome-free products suitable for Defence, End of Vehicle Life and RoHS compliant applications. For more information, contact our Sales Department on +44 (0) 121 702 2485 or on email@example.com