Possible implications of the proposed new harmonised classification (CLH) for cobalt metal, which includes a proposal for lowering the specific concentration limit (SCL) for cobalt to 0.01% (from the generic limit of 0.1%) will not be confined to the cobalt industry, or indeed to the use sectors for cobalt; they could extend to the many other metals and materials containing cobalt, and should not be underestimated. Not only would the proposed changes to CLH, put forward by the Netherlands, go against the scientific weight of evidence, they could cause far-reaching harm to several key manufacturing sectors in Europe.
Cobalt compounds are used in a wide variety of applications, including but not limited to alloys, automotive, batteries, catalysts, chemicals, driers, electronics, hard metals, magnets, medical devices, pharmaceuticals, pigments, steels and surface treatments. As a contributor to both established and emerging technologies, cobalt is of significant value to the European economy.
Obtained as a co-product of the nickel and copper mining processes, cobalt can unintentionally be present as an impurity above the proposed, far lower specific concentration limit of 0.01% in a range of primary (raw) materials, intermediate complexes and secondary (recycled) materials. For example, cobalt is naturally present in the raw materials (nickel matte, ferroalloy) used to manufacture stainless steel, and is considered to be a benign and beneficial impurity, conferring hardness and durability. Should this strict classification change be introduced therefore, it would not only result in a technically difficult and energy intensive process to remove the cobalt impurity, but would be an unnecessary step in terms of its (perceived) impact to health.
The current industry self-classification of cobalt metal (all forms) as a Category 1B carcinogen by inhalation is based on risk considerations and findings of a USA NTP inhalation study; with the classification requirements currently being reviewed in light of new (bioelution) testing. Only inhalable forms of cobalt metal are impacted, therefore many (massive) forms of cobalt metal and alloys do not need to be labelled. The industry has proactively implemented this self-classification and borne the related costs.
According to the Cobalt REACH Consortium (CoRC) and Cobalt Institute (formerly the CDI), and supported by a range of other impacted industry bodies, the proposed classification of Carc 1B all routes (and Repro 1B and Muta 2) goes beyond the scientific evidence and would burden European businesses – many SMEs with limited resources – with further substantial direct costs.
The cobalt industry has already incurred costs of circa 30 million Euros related to the implementation of REACH, which represent a direct cost impact to industry. Should these proposed CLH changes be introduced, the cobalt producing industry estimates an annual cost of around EUR 500,000 for changes to labelling/packaging and eSDS updates. The required workplace changes to production processes to account for a new classification covering oral and dermal exposure would require redesign, and increased capital expenditure and construction costs. These costs would pale into insignificance when compared to the likely cost of loss of market, in the event that the proposed CLH change is introduced. Some of these workplace changes would result in increased manufacturing costs in the EU and ultimately higher prices for cobalt and cobalt-containing products in the EU, placing European businesses at a competitive disadvantage compared to non-EU producers not required to meet such demanding standards. All of this at a time when the EU has identified cobalt as a critical raw material (CRM) – confirming cobalt is economically important to the EU economy.
Currently, recovery and recycling rates for cobalt in the EU are very good, with the End of Life recycling rate estimated to be around 68%, (United Nations Environmental Programme) higher than for most other metals. Several of the use sectors for cobalt report recycling rates of up to 90% – hard metal (ITIA 2017) and rechargeable batteries (Product Environmental Footprint 2016), with the recovery/recycling rate for stainless steel, where cobalt is contained as an impurity, at around 80% (Eurofer 2016). The implementation of such a stringent level for cobalt metal would negatively impact recycling initiatives in key industry sectors, with a similar impact on the EU’s Circular Economy targets.
There would be several direct and indirect consequences for the cobalt industry, and also for the many important industrial sectors where cobalt is present as an impurity, including steel, and in particular stainless steels, high-alloy steels, superalloys and their secondary feed materials, as well as the critical applications in which they are used. In powder metallurgy, too, there will be an increase in costs for manufacturing powder products given the current wide range of steel and stainless steel powders being manufactured where cobalt is an impurity in concentrations above the new proposed lower limit of 0.01%. Similarly, most nickel metal and all ferronickel will be caught by the new level, and it is not deemed technically possible to remove all cobalt from nickel during the refining process. As well as steel and nickel alloys, naturally-occurring cobalt is also found in copper and ferroalloys; and present in final slags from pyro-metallurgical
processes, which end up in concrete applications, and other filling materials used extensively in the construction industry, which means the CLH proposal could also impact on the recycling of these materials.
It should not be forgotten that cobalt is deliberately added to many alloys to impart critical properties of hardness, high temperature strength and corrosion resistance, including jet engines, land based turbines, medical implants, tool steels, cutting and drilling tools, the chemical and oil & gas industries. Therefore unnecessarily classifying these applications as carcinogenic, especially where decades of use have not provided evidence of harm being caused, would send a very damaging message, as well as being hugely disruptive and costly for important European industrial sectors. The CoRC and CI are coordinating an industry platform to address these issues, and would welcome your interest and involvement.
Source: CoRC/Cobalt Institute
