COMMENTS AND RESPONSE TO COMMENTS ON AUTHORISATION Substance name: Lead sulfochromate yellow (C.I. Pigment Yellow 34) EC number: 215-693-7 CAS number: 1344-37-2 Broad information on use applied for (title): Industrial application of paints on metal surfaces (such as machines vehicles, structures, signs, road furniture, coil coating etc.) Consultation number: 0012-03 Applicant name: DCC Maastricht B.V. OR Consultation period: 12/02/2014 - 09/04/2014 Reference number and date: Submitter: Alternative: Type Generic name EC CAS Description of technical alternative and Labelling Ref.No: 538 Date: 2014/04/09 Affiliation: BehalfOfAnOrganisation Type/Role in the supply chain: Non-governmental organisation (NGO) Name of org/company: European Environmental Bureau (EEB) Country: Belgium Reflective material, such as reflective marking tape, reflective film, etc. Applicants’ response:
• Regulated traffic signs • Applications to corrugated surfaces • Application to stainless steel • Non-vertical applications • Graphics made for automotive Original Equipment Manufacturers (OEM); contact 3M Automotive Division at 1-800-328-1684, Ext. 444, for alternatives” The above confirms that such tapes do not have the durability to withstand the elements. In particular it should be noted they do not warrant for horizontal or road marking applications. Applications 3M is only willing to warrant are very limited as follows: “These applications are warranted by the 3M_ MCS_Warranty. • Graphics produced with the GERBER EDGE™ thermal transfer printing system • Vehicle graphics, commercial signs, and striping • Vertical applications only” Reference number and date: Submitter: Alternative: Type Generic name EC CAS Description of technical alternative and Labelling Ref.No: 525 Date: 2014/04/09 Affiliation: BehalfOfAnOrganisation Type/Role in the supply chain: Non-governmental organisation (NGO) Name of org/company: European Environmental Bureau (EEB) Country: Belgium Rutile, Iron and Perovskite based pigments CLP Several substances, several Applicants’ response: classification
Industrial and professional applications of the uses applied for have simply bought specialized coatings from competitors to Akzo. As mentioned above the volume of paint involved for a company like Akzo is so minimal that they are unlikely to notice the difference. Furthermore Akzo’s greatest strengths in these markets lie in paints that have different characteristics than the coatings produced with PY. 34 and PR. 104. Other remarks The Applicant concurs with Akzo that coatings used in Airports and plastic hot melts used in road markings are subject to specifications that cannot and should not be lightly changed. As Akzo admits they are not a player on these markets. Companies that are active in these markets have voiced very different views in the public consultation regarding this issue and the Applicant believes their opinion should prevail. Reference number and date: Submitter: Alternative: Type Generic name EC CAS Description of technical alternative and Labelling Ref.No: 262 Date: 2014/04/07 Affiliation: BehalfOfACompany Type/Role in the supply chain: Other Name of org/company: AkzoNobel Country: Netherlands see non CLP see attachment Applicants’ response: