The Space Chromate Task Force (STF) has concluded “Phase 2” of its activities: A joint Analysis of Alternatives and Socio-Economic Analysis Report for the use of chromium trioxide in chromic (or chemical) conversion coating (CCC) and the repair or maintenance of such coating on aluminium alloy parts used in launchers and space vehicles (“STF dossier”).
Key elements of this collective work have been used to support the aerospace-related uses of the CTACSub Upstream Application for REACH Authorisation in the ECHA public consultation in October 2015. The authorisation decision by the European Commission is expected in the course of 2017.
A separate application for authorisation based on the STF dossier (“Phase 3”) is therefore currently not envisaged by STF. It would also require addition of a Chemical Safety Report.
Third parties interested in acquiring access to the STF dossier are advised to contact the STF Secretariat: Pierre LIONNET, ASD-Eurospace, firstname.lastname@example.org, +33 (1) 44420070.
STF is an initiative of several companies from the European space industry to collaborate on the issue of mission-critical uses of Cr(VI) substances for the purpose of compliance with the EU chemicals legislation REACH (Regulation (EC) No 1907/2006). Key space industry participants include:
· AIRBUS DEFENCE AND SPACE
· AEROSPACE PROPULSION PRODUCTS
· OHB SYSTEM AG
· RUAG SPACE
· THALES ALENIA SPACE
The STF is assisted by the European Space Agency (ESA) and Centre National d’Etudes Spatiales (CNES). It is coordinated with the ASD REACH Implementation Working Group through STF participants and monitored by the Materials and Processes Technology Board (MPTB). Eurospace is acting as Secretariat, REACHLaw Ltd. as consultant.
The sunset date for chromium trioxide and some other chromates included in the REACH authorisation list (Annex XIV) is 21 September 2017. From this date, the placing on the market and use of those substances on their own or as part of formulations will in principle be banned in the European Union, unless an authorisation covering the use has been granted by the European Commission. Downstream users relying on an authorisation granted to an upstream supplier (e.g. the manufacturers and importers within CTACSub) have to notify ECHA according to REACH Article 66 after the granting of the authorisation.