Rank: New forum user 
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Good morning all.
I'm trying to find out if I'm required to register a particular substance under the REACH requirements.
My company produce high spec titanium and steel tubes.
As part of the pickling process we produce Potassium Chromate and Sodium Chromate which is then neutralised at the end of the process.
As we don't produce it and pass it into the supply chain I thought we didn't have to register this as a hazardous chemical.
We use all the necessary controls during the process and at the end of the process neither chemical exists.
Would anybody be able to help with this.
Any help or advice would be appreciated.
Best regards
Dave
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Rank: Super forum user
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Richardson22118 wrote: .... as part of the pickling process we produce Potassium Chromate and Sodium Chromate which is then neutralised at the end of the process.
Dave, that is a curious statement. Chromate substances cannot be 'neutralised'. If they are in an acidic or basic solution then yes the acid or the base can be neutralised (the pH that is) but the chromate is still chromate. So you have a waste product containing chromate.
Richardson22118 wrote:As we don't produce it and pass it into the supply chain I thought we didn't have to register this as a hazardous chemical.
We use all the necessary controls during the process and at the end of the process neither chemical exists.
REACH law on chemicals does not include 'waste', but REACH may apply to waste which is recovered.
Waste which is essentially unchanged, e.g. recovered solvents, will be covered by the original solvent registration, and will not need to be registered again as a new substance has not been formed.
Waste by-products which are new substances, changed from what you used originally, and become the raw material for another process or use, or go through a recovery process, will require registration under REACH, where the annual production exceeds 1 tonne per year.
Presumably your chromate waste is sold to someone who uses it is one of their processes?
John
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Rank: New forum user
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Thanks John
I'll put this information to our company chemist and confirm his original statement that we neutralise for Ph only.
All waste chemicals go into an acid pit which is neutralised for Ph and then the complete acid pit is sucked out into a waste tanker and taken away. I think I need to confirm where it goes to when it leaves our site.
Dave
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Rank: Super forum user 
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On your first point start from your role in the supply chain - you will end up identifying yourself as a Down Stream User ergo your responsibilities will NOT include registration but WILL include ensuring that your supplier knows what it is that you are doing with the purchased materials for communication back up the supply chain (as part of their preparation of extended Safety Data Sheets for example).
http://echa.europa.eu/we...s/reach/downstream-users
On the subsequent discussion (as an ex-electro plating chemist) I am horrified by the suggestion of mere pH neutralisation as any available hexavalent Chromium must first be reduced to the trivalent form then pH adjusted - sure your chemist can give a clearer explanation of all the steps occurring at your site rather than the quick layman's explanation presented to the forum.
Your process then disposes of "hazardous" waste - end of. Here a Duty of Care under EPA starts in understanding how your provider deals with the material after it leaves your premises but does not impose REACH registration obligations upon your company for further activities enacted by others.
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Rank: Super forum user
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On your first point start from your role in the supply chain - you will end up identifying yourself as a Down Stream User ergo your responsibilities will NOT include registration but WILL include ensuring that your supplier knows what it is that you are doing with the purchased materials for communication back up the supply chain (as part of their preparation of extended Safety Data Sheets for example).
http://echa.europa.eu/we...s/reach/downstream-users
On the subsequent discussion (as an ex-electro plating chemist) I am horrified by the suggestion of mere pH neutralisation as any available hexavalent Chromium must first be reduced to the trivalent form then pH adjusted - sure your chemist can give a clearer explanation of all the steps occurring at your site rather than the quick layman's explanation presented to the forum.
Your process then disposes of "hazardous" waste - end of. Here a Duty of Care under EPA starts in understanding how your provider deals with the material after it leaves your premises but does not impose REACH registration obligations upon your company for further activities enacted by others.
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