Dave Elliot, CEO of the Surface Engineering Association (SEA) recently visited the European Chemicals Agency to find out more about the reclassification of Silver.
The European Chemicals Agency (ECHA) published the intention of the Swedish Chemicals Agency, KEMI, to classify silver metal as:
Skin Sens. 1, H317
Muta. 2, H341
Repr. 1B, H360FD
Aquatic Acute 1, M-factor=10 (powder <1mm) and M-factor=1000 (powder <0.0001mm)
Aquatic Chronic 1, M-factor=10 (powder <1mm) and M-factor=100 (powder <0.0001mm)
This classification has been proposed in the context of the Biocidal Products Regulation but will apply to other regulations (e.g.: REACH) and other applications (e.g.: jewellery, electronics, solar energy etc.) as well. Skin sensitization cat 1 could trigger a restriction for skin contact materials like jewels. A classification as reprotoxicant category 1B can trigger a fast track restriction process banning all the consumer uses of silver and silver compounds (e.g.: no jewellery, no silverware anymore).
This classification will also qualify these substances for the authorisation process under REACH which could require an authorisation for each industrial and professional use. The final aim of these regulatory measures is the substitution of the classified substances by safer alternatives.
I attended a meeting of the European Precious Metals Federation (EPMF) last week and they are not supporting this classification proposal because it is based on weak weight of evidence rather than robust scientific data. The EPMF has identified data gaps in the scientific database for silver, and has been proactive in filling this data gap. Under REACH, the EPMF submitted a Testing Proposal to perform an Extended One Generation Reproductive Toxicity study in 2015 for silver, which has been approved in June 2019. The testing program has just started.
EPMF believes that great care is needed in making any proposals for the Classification and Labelling of silver and silver compounds.
The EPMF profoundly regrets that the Swedish Chemical Agency has chosen to submit a classification proposal for silver nitrate in December 2018 and for silver in July 2019, and that they will soon submit another separate proposal for silver chloride without properly recognizing the scientific data gaps and without taking into account the Testing Proposal under REACH. It is frustrating for the precious metals industry to see two parallel but separate processes which have an impact on each other working in isolation and, potentially, leading to different outcomes.
France Capon firstname.lastname@example.org is the Secretary General of the EPMF and I’m sure she will provided you with any further information.
Here is a link to the presentations from the meeting that we can use to inform our members https://www.epmf.be/epmf-silver-workshop-2/