2 × 3 = 4

Do you remember that?

That’s how, a long time ago, a little girl with red hair used to imagine the world as a colourful and beautiful place.

Over the past few months, I have been following the debate on restricting Cr(VI) at various levels.

I don’t really want to say much about the RAC (Committee for Risk Assessment). The RAC is simply the RAC. The members of this committee come from the world of monitoring and regulation – a world that many electroplating companies, as high-risk industrial facilities, know only too well. There, the focus is on risk. And from this perspective, fewer SVHC substances mean less risk in Europe.

Since representatives of this committee seriously believe that almost all electroplating companies can already today comply with an occupational exposure limit of 0.1 µg/m³ Cr(VI), all hope was pinned on the socio-economic committee, SEAC (Committee for Socio-economic Analysis).

It was all too obvious that the models and limit values discussed by the RAC would entail significantly more socio-economic disadvantages than benefits for the already struggling European economy. The figures were well known. Surely the committee members must have seen it that way too. At some point, economic rationality and common human sense were going to win out.

But things turned out differently.

To start with, the SEAC has significantly underestimated all the costs associated with the so-called ‘non-use’ scenario – the ‘closure of an electroplating plant’. And not in a minor way, but by around 50 per cent.

Please do understand me correctly: the figures have to be right.

Nevertheless, I have come to the conclusion that certain models are being favoured. Perhaps it is because I was probably the only person in the virtual meeting who has ever personally shut down and an electroplating plant.

Why does no one else realize that the turnover and profits of the downstream supply chains must be taken into account? Why are disposal costs not considered, costs which can easily run into the millions even for smaller companies?

Ultimately, the gap in the cost-benefit analysis is still so striking that, in reality, only the restriction models R01 and A01 appear socio-economically feasible. Yet even the choice of wording and the hours-long discussions about terms such as ‘likely’ or ‘in the short term’ suggested that mental bridges are already being built for other scenarios.

Bridges for those who will ultimately make the political decision.

Because that is ultimately what this is all about: it is a political decision as to what kind of economy we want to have in Europe in the future. This applies to Cr(VI) just as much as it does to PFAS. Key technologies and their supply chains do not, it seems, enjoy the highest priority in this regard. Or is there a plan for tomorrow’s economy that I am not aware of?

An example:

Even in the defence sector, the RAC shows no mercy. Whilst the SEAC, in its comments on the restriction of Cr(VI) for the defense sector, recognizes a ‘serious impact on the EU and the Member States’, the RAC merely states that, even in this specific case, it will not support the occupational exposure limits set out in R01 and R02.

For systemically important sectors such as aerospace engineering, where hard chrome plating cannot be substituted for the foreseeable future, this represents a significant disadvantage for the autonomy and security of our economy and way of life.

So, can’t the people on these committees do maths?

Of course they can.

Only experts who prove themselves at national level are appointed to such committees. I would like to emphasize at this point that the task is extraordinarily complex and that I have great respect for the work these people do. I was surprised, for example, at the depth of technical expertise on hard chrome and PFAS available within German ministries.

The real question is therefore a different one.

It is a political decision. And given the scale of the supply chains for PFAS and hard chrome, it is a decision with significant economic implications. It is no coincidence that initiatives such as the Industrial Green Deal or the Chemical Industry Action Plan now exist in the European Union.

But what use are the finest plans if the economic reality is quite different?

Every day, industrial companies are closing their doors. Every day, people working in key technologies are losing their jobs.

One might say: that is the normal course of the market economy. For every door that closes, a new one opens.

But so far, I do not see these new sectors of the economy emerging in Europe.

Perhaps I lack creativity on this issue. Perhaps I lack knowledge of other market segments.

What I do see, however, is an economy under immense pressure. I see bureaucracy and regulation reaching proportions that are becoming increasingly difficult to manage. I see Member States that cannot agree on a common strategy. And I see no one who, at the end of the day, rings up the members of the REACH Committee and makes a sound decision.

Let us therefore look at the matter once more through Mrs Langstrumpf’s eyes and imagine the world of REACH and Cr(VI) as we would like it to be:

• The authorization of Cr(VI) will be replaced by a restriction in 2028.
• Only socio-economically viable models such as R01 or A01 will be pursued.
• Respiratory protection masks may be used as a risk-minimization measure.
• Future technologies will be specifically promoted in substitution hubs.
• Regulations from OSH, BREF and REACH are harmonized across Europe.
• An end to so-called ‘free riders’ who do not abide by any rules.
• Less bureaucracy and more scope for European ideas and businesses.

Having been engaged with this issue for more than 10 years now, I am very keen to see how this story will unfold in the final stretch.

Matthias Enseling

Vecco