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CHEMICAL SAFETY REPORT

1

Chemical Safety Report

Legal name of applicants: Amphenol Limited, Amphenol Socapex, Souriau-Esterline,

ITT Cannon, Connecteurs Electriques Deutsch and

Tyco Electronics UK Ltd

Submitted by: Souriau-Esterline

Substance: Chromium trioxide, EC 215-607-8 and CAS 1333-82-0

Potassium dichromate, EC 231-906-6 and CAS 7778-50-9

Sodium dichromate, EC 234-190-3 and CAS 10588-01-9 / 7789-

12-0

Acids generated from chromium trioxide and their oligomers, EC

231-801-5 or 236-881-5 and CAS 7738-94-5 or 13530-68-2

Use title: Use-1: Industrial use of a mixture containing hexavalent chromium

compounds for the conversion of cadmium coated circular and

rectangular connectors in order to achieve a higher level of

performances than the requirements of international standards as

well as to withstand harsh environments and high safety

applications (such as in the military, aeronautic, aerospace,

mining, offshore and nuclear industries or for the application in

safety devices for road vehicles, rolling stock and vessels).

Use-2: Industrial use of a mixture containing hexavalent chromium

compounds in conversion coating and passivation of circular and

rectangular connectors in order to meet the requirements of

international standards and special requirements of industries

subject to harsh environments.

Use-3: Industrial use of a mixture containing chromium trioxide

for the etching of composite connectors used by industries subject

to harsh environments, to mainly ensure adhesive deposit to meet

the requirements of international standards.

Use number: Use-1 ; 2 & 3


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9. EXPOSURE ASSESSMENT

9.1. Introduction

The hexavalent chromium compounds are used in conversion coating

(subdivided in two uses) and for the etching of circular and rectangular connectors.

CMG’s application for authorisation therefore concerns three industrial uses of

hexavalent chromium as detailed in Table 16. These uses are located in six sites as

described in the following table:

Company Site (Town) Country

TE Connectivity Evreux (Connecteurs Electriques Deutsch) France (FR)

Hastings (Tyco Electronics UK Ltd) United Kingdom (UK)

Amphenol Thyez (Amphenol Socapex) France (FR)

Whitstable (Amphenol Limited) United Kingdom (UK)

Souriau - Esterline Champagné France (FR)

ITT Cannon Weinstadt Germany (DE)

Table 16: Location of activities covered in the Application for Authorisation

The three uses of the CMG’s authorisation dossier are described in Table 17

below and cover the activities of connectors for circular, rectangular and associated

accessory lines on aluminium, composite and steel substrates.

9.1.1. Overview of uses and Exposure Scenarios

CMG’s authorisation is composed of three uses that are described below.

Titles of identified uses Title of Exposure Scenario

Use 1

Industrial use of a mixture containing hexavalent chromium compounds for the conversion of cadmium coated circular and rectangular connectors in order to achieve a higher level of performances than the requirements of international standards as well as to withstand harsh environments and high safety applications (such as in the military, aeronautic, aerospace, mining, offshore and nuclear industries or for the application in safety devices for road vehicles, rolling stock and vessels).

ES1: Industrial use of hexavalent chromium in bath for the surface treatment of connectors.

Use 2

Industrial use of a mixture containing hexavalent chromium compounds in conversion coating and passivation of circular and rectangular connectors in order to meet the requirements of international standards and special requirements of industries subject to harsh environments.


33

Titles of identified uses Title of Exposure Scenario

Use 3

Industrial use of a mixture containing chromium trioxide for the etching of composite connectors used by industries subject to harsh environments, to mainly ensure adhesive deposit to meet the requirements of international standards.

Table 17: Identified uses and Exposure Scenarios

The Exposure Scenario described covers the activities of the six sites (Evreux,

Hastings, Thyez, Whitstable, Weinstadt and Champagné).

9.1.1.1. Process explanation

This CSR discusses the use of hexavalent chromium in baths for the surface

treatment of connectors. As uses, parts treated, operating conditions and risk

management measures are similar, while differences are few and relate only to

concentration and other products present in the baths treatment, it was chosen to

assess exposure through one exposure scenario (as described in section 9). Ranges of

concentrations are however used to express the slight differences from one site to

another.

Presentation of baths treatment line

The surface treatment of connectors’ part is performed on bath treatment

lines. Connector parts are articles dipped in successive baths, including chromium

bath. This CSR focuses on the use of hexavalent chromium, consequently only baths

containing hexavalent chromium will be considered.

There are two types of treatment lines for two types of activities: manual or

automated dipping. The treatment lines for each site is presented on the following

figure:


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Figure 7: Treatment baths on the site of Amphenol Limited (for manual dipping)

Figure 8: Treatment line on the site of Amphenol Socapex (manual dipping)


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Figure 9: Manual treatment bath on the site of Souriau

Figure 10: Automated line on the site of Souriau


36

Figure 11: Automated line with loading area on the site of Souriau

Figure 12: Automatic treatment line on the site of ITT Cannon


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Figure 13: Chromium bath on the site of ITT Cannon

Figure 14: Automatic treatment line on the site of Connecteurs Electriques Deutsch


38

Figure 15: Chromium bath Tyco Electronics UK Ltd (manual treatment line)

All these treatment lines are composed of several baths, but a bath

containing hexavalent chromium is always followed by at least one rinsing bath.

On automated lines, the chromium bath is located on the treatment line and

far away from other activities which are not performed directly on the line. On these

treatment lines, there is a restricted area which permits workers to access the

treatment bath, in case of sampling, addition of mixture, drain or visual routine

control on the bath. When the automated line is operating, the connector parts are

fixed on the automated robot which immerses them in the successive baths. During

this operation, no workers are located next to the bath.

On manual lines, the workers handle a frame on which connector parts are

mounted or, depending on the part to be treated, placed into a small barrel. Workers

then use the frame or the barrel to manually dip the articles in the successive baths

treatment.

Some chromium baths feature internal exhaust ventilation. It could be defined as a

fixed capturing hood located in close proximity of and directed at the source of

emission. The global description is in accordance with the following figures.


39

Figure 16: Internal local exhaust ventilation of baths

The efficiency of these ventilations is verified according to the flow calculations

recommended by INRS10 or in an equivalent approach.

Sampling of bath and lab analysis

A tiny amount (maximum 100 ml) of the mixture is transferred into small

vessels, in order to perform a titration of hexavalent chromium or pH measurements

on the solution contained in the bath.

The titration of hexavalent chromium or other analyses are performed in the

laboratory of the site. The laboratory is a separate room, next to the plating shop.

The lab operator is subject to exposure to hexavalent chromium only during these

tasks.

The pH measurement is a specific consideration because it can be performed

at the bath directly during the sampling, by using a portable pH meter, which the

platers just immerse into the solution. Consequently the pH measurement is

considered in the same contributing scenario with sampling activity.

Sampling and lab analysis concern all CMG members except ITT Cannon for

which the efficiency of the chromium mixture in the solution tank is judge on the

basis of the colour on the final article.

This task is considered in the exposure to hexavalent chromium. It is treated in this CSR in the Contributing Scenarios 2 & 3 (CS-2&3).

10 Cuves de traitement de surface. Guide pratique de ventilation. ED651. INRS, 2014.


40

Drainage of baths

A waste treatment plant (or a specific container on the site of Amphenol

Limited) is located in a separate and dedicated room on the industrial site, for the

water treatment in an enclosed system. The treatment of liquid effluent is

considered in the environmental contributing scenario 1. When a chromium bath on

the plating line needs to be emptied, it is drained into the waste treatment plant by

using a pump and a valve located next to the bath. During this operation the

operator is located next to the bath for a maximum of 60 minutes. This is the total

duration of the transfer.

The waste system used during this task is completely closed. Therefore, there

is no possibility of exposure related to the transfer of hexavalent chromium. The

exposure considered during this task will be inhalation exposure due to the presence

of open chromium baths next to the worker.

This task is considered in the estimation of exposure to hexavalent chromium. It is treated in this CSR in the Contributing Scenario 4 (CS-4).

Visual control and maintenance operations

A visual routine control on the bath or maintenance operation can be

performed by one worker. In this case, the worker is on the restricted area.

Maintenance operations are operations involved directly on the installation. In both

cases of visual control or maintenance operation, there is no possibility of direct

exposure.

The exposure considered during these tasks will be inhalation exposure due

to the presence of open chromium baths next to the worker.


Repackaging of hexavalent chromium

When hexavalent chromium is supplied in large containers, the volume of

product to add to the treatment bath cannot be accurately controlled at the bath if

poured directly from the large container. Thus, the quantity to be added to the bath

is transferred to a smaller recipient in order to quantify the amount of product

needed and facilitate the addition into the bath. This transfer is manually performed

by one worker and it can involve liquid or solid products. It is performed in a

separate and dedicated room. The risk management measures and operating

conditions described for this repackaging can differ between CMG members and

they are detailed in 3 different contributing scenarios.

On the site of Amphenol Socapex, the repackaging of powder is performed

once a year when a new stock is received on site. All the stock is directly repacked

during the same day in order to use the laboratory fume-cupboard (which would not

be available for a daily repacking). Thus, the repackaging is done by one specific

operator, made aware of the hazards of hexavalent chromium and equipped with all


41

the necessary protective equipment. The powder is repackaged into small airtight

containers in order to avoid any contact with ambient air (it is a requirement for

storage).

On the site of Amphenol Limited, once a year, one of the 2 lab employees re-

package a big drum of solid chromium (VI) chemistry into smaller containers, which

are the correct weight for use in a bath. As for Amphenol Socapex, packaging it in

small ready-to-use pots keeps it in a better condition and stops the chemistry

deteriorating.

On the site of Souriau, workers use specific equipment dedicated to the

repacking of powder, just before the addition to the bath. This operation is

performed by a specific operator. Thus, as for Amphenol Socapex and Amphenol

Limited, the handling is done in a controlled way by a responsible member of the

staff. The powder is transferred form one large container to a small one behind local

ventilation which permits a form of encasing of the source of dust during the

transfer. Only the front side is open. This enclosing hood is designed as follows:

Figure 17: representation of the enclosing hood used for the repacking of powder on the site of Souriau

On the site of Amphenol limited, the transfer for weighing out and

repackaging of powder is performed in the specific chemical store. In this room,

there is a fan to provide an enhanced general ventilation and the operator wears

specific personal protective equipment (including specific mask) for this task because

it is identified as a task of high concern for the exposure to hexavalent chromium.

On the site of Amphenol Socapex the repackaging of liquid is performed once

a week before the addition into the bath. The repacking is made in small airtight

container in order to avoid any contact with ambient air.

This task is considered in the estimation of exposure to hexavalent chromium. It is treated in this CSR in the Contributing Scenarios 5, 6, 7 & 8 (CS-5,6,7&8).


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Manual addition of mixture to bath

The hexavalent chromium compound can have different forms: liquid or

solid, and in a mixture or as a pure material. It is added by one worker directly to the

chromium treatment bath by pouring it from the container as supplied or transferred

according to the condition described in the previous section.

The hexavalent chromium is diluted in the liquid contained in the bath. Thus,

the bath concentration of hexavalent chromium compound does not exceed 10%

(w/w). It will be considered as Minor (in the range of 5 to 10%) in this CSR.

This task is considered in the estimation of exposure to hexavalent chromium. It is treated in this CSR in the Contributing Scenario 9 (CS-9) for liquid products, and the

contributing scenario 10 (CS-10) for solid products.

Addition of liquid in bath via pumping system

Hexavalent chromium can be added in the bath using a closed system with a

flexible pipe and pumping system. This automated transfer into the bath involves

only liquid mixtures containing hexavalent chromium, it cannot involve solid forms

(mixtures or pure material).

The container of hexavalent chromium mixture is placed next to the

treatment bath. This container is opened, a pumping cane is placed into the

container opening and is submerged below the liquid surface. The pumping cane and

the container opening are close in diameter. The other end of the pumping system is

a flexible pipe which is submerged in the treatment bath. This transfer is considered

as a potential emission source if it is located in the breathing zone of an operator

located next to the container during the transfer, in order to control it.

This task is considered in the estimation of exposure to hexavalent chromium. It is treated in this CSR in the Contributing Scenario 11 (CS-11) for liquid products only.

Assembling and dismantling of connector parts

Before and after the dipping process performed on the treatment line,

connector parts must be placed on /in or attached and then removed from:

- a frame or a barrel, in the case of manual dipping,

- a structure which will be linked to the robot of the automated line.

Therefore, at the beginning and at the end of treating articles by immersion, workers

are handling the connector parts. This task is presented on the following figure:


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Amphenol

Limited

Amphenol

Socapex


44

Souriau-

Esterline

ITT Cannon


45

Connecteurs

Electriques

Deutsch

Tyco Electronics

UK Ltd

Figure 18: Handling of articles

This frame, barrel or structure is commonly called a jig. During the assembly

of connector parts on the jig, before the chromium treatment, the parts have not yet

been in contact with hexavalent chromium. Consequently, there is no possible

exposure to hexavalent chromium from handling these articles.

When removing connector parts from the structure after the treatment

process, the parts have been rinsed in water and further treated. Consequently, the

remaining hexavalent chromium on the article is included into a matrix composed of

the formation of oxidized surface of the article. Chromate is therefore contained in

this matrix, and cannot evaporate. Thus, for exposure by inhalation route, these

articles are not the main emission source of hexavalent chromium.

However, the inclusion of hexavalent chromium into a matrix does not

preclude the cutaneous route of exposure. Therefore, this exposure will be analysed

in a separate contributing scenario (CS-12).

There are two further considerations, depending on the plating shop

configuration:


46

- When this task is performed at the extremity of the treatment line (in

the plating shop), workers can be subject to indirect exposure due to

the automated activity with open surface of chromium bath on the

treatment line. This exposure will be considered and included in the

contributing scenario 15 (CS-15). The additional time needed for this

operation will thus be considered. It is the case of TE connectivity on

the site of Evreux (Connecteurs Electriques Deutsch), on the site of

Hastings (Tyco Electronics UK Ltd), Souriau-Esterline, ITT Cannon and

Amphenol Limited.

- When this task is performed in a separate room, there is no

possibility of exposure via inhalation. It is the case of Amphenol

Socapex.

Dermal exposure to hexavalent chromium during this task will be treated in this CSR in the Contributing Scenario 12 (CS-12).

There is no direct inhalation exposure to hexavalent chromium during this task when it is performed next to the treatment line. However, indirect exposure due to the immersion in bath on the treatment line will be considered during this activity

in the Contributing Scenario 15 (CS-15).

Dipping connectors in treatment baths

Depending on the automatic or manual configuration of the treatment line, the

exposure will be considered differently.

For the automated treatment line, the dipping of connector parts in successive baths

treatment is automatically performed, and no operators are present next to these

baths. The robot which performs the dipping in baths on this treatment line is

launched and controlled from a steering console. This steering console is a few

meters away from the treatment line, in the same plating shop. The operator, who is

using the steering console, is indirectly exposed to hexavalent chromium. This

exposure is due to the automated activity on the treatment line via the exposure to

the ambient air of the plating shop, and is considered in the contributing scenarios

15 (CS-15).

For a manual treatment line (or exceptional manual operations), the dipping of

connector parts in successive treatment baths is performed by one worker located

immediately behind the bath (less than 1 metre). Exposure due to the presence of a

chromium bath or rinsing bath in the near field will be considered in the contributing

scenario 13 & 14 (CS-13 & 14).

This task is considered in the estimation of exposure to hexavalent chromium. It is treated in this CSR in the Contributing Scenario 15 (CS-15) for automated treatment

lines, and in the contributing scenario 13&14 (CS-13 & 14) for manual operations.


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Drying of connectors

Connector parts can be dried automatically on the treatment line (in this case

there is no intervention of workers), or just by placing the jig with connector parts in

a proofer. These tasks do not involved additional exposure for workers since the

potential emission source is confined and it is far away from the workers.

Furthermore, the main source of exposure considered in the ambient air of the

plating shop is the open chromium baths.

In the case of manual drying, it is performed by using an air gun. A jig of parts

is hung inside an extraction booth, so the process is done under extraction. It can be

presented as follow:

Figure 19: manual drying of connector parts

The manual drying of connectors is considered in the next sections of this

CSR.


Wastewater treatment plant

The wastewater treatment plant (WTP) on the industrial site is an installation

designed specifically to treat effluents containing hexavalent chromium.


48

All the baths containing hexavalent chromium are treated with the same

process in the WTP dedicated to the used chromium mixtures. This includes the

liquid effluent from chromating baths, and liquid effluents from rinsing baths

(contaminated by hexavalent chromium), except for at Amphenol Limited, where

effluent from chromium tanks is stored in a waste tank, and then periodically

collected by a registered waste company to be treated and disposed of off-site.

Bath effluents are collected in a dedicated container in the WTP in which

dechromating (with sodium bisulfite) is performed. During this operation, hexavalent

chromium is reduced to trivalent chromium. Then, neutralisation is performed with

soda and flocculation followed by filtration on a filter press. Sludge produced is

disposed of to a specialized center.

This step on the process is considered in the estimation of environmental exposure to hexavalent chromium. It is treated in this CSR in the Contributing Scenario 1

(CS-1).


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9.1.1.1.1. Tasks to be considered in the CSR

Based on the foregoing description of the process, the exposure scenarios will be

described with the following tasks:

Exposure scenario 1 (ES1), Industrial use of a mixture of chromic acids for

chromium plating:

o Sampling of bath

o Lab analysis

o Other activities next to the bath

o Repackaging of solid by using fume cupboard

o Repackaging of solid by using other local ventilation

o Repackaging of solid without local ventilation

o Repackaging of liquid

o Addition of liquid to bath

o Addition of solid to bath

o Addition of liquid in bath via pumping system

o Handling of articles

o Dipping connector parts in treatment bath, in the worker’s near field

o Dipping connector parts in rinsing baths, in the worker’s near field

o Treatment baths in the workers’ far field

o Drying connector parts

9.1.1.2. Tonnage information / Number of worker exposed:

Tonnage information

Tonnage of substance used for each legal entity is presented in the following

section. It should be noted that Souriau is the only legal entity concerned by Use-3;

consequently, the tonnage information is not presented for the others.

Amphenol Limited:

The tables below present the past consumption until the year 2015 and the

estimated consumption of hexavalent chromium compounds (sodium dichromate

and chromium trioxide) on the site of Amphenol Limited.

Quantities (in tons) for the years 2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Use-1 0.148 0.160 0.064 0.106 0.101 0.097 0.093 0.089 0.085 0.081 0.078 0.074

Use-2 0.194 0.273 0.203 0.246 0.255 0.265 0.276 0.287 0.298 0.310 0.323 0.336

Total 0.342 0.433 0.267 0.352 0.357 0.362 0.369 0.376 0.383 0.392 0.401 0.411

Table 18 : Past and future estimated consumption on the site of Amphenol Limited


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Quantities (in tons) for the years 2025 2026 2027 2028 2029

Use-1 0.071 0.068 0.066 0.063 0.060

Table 19 : Estimated consumption in the site of Amphenol Limited

It should be noted that on the site of Amphenol Limited, both sodium

dichromate (CAS 10588-01-9) and sodium dichromate dihydrate (CAS 7789-12-0) are

used. These two substances are presented as the same substance since the EC

number is common for both substances (EC 234-190-3).

Quantities presented in the following table are based on the above

estimations for the maximum amount used for chromium plating to cover the

activities considered during the review period. Consequently, the total tonnage of

the substances considered in this CSR is presented as follows.

Use-1 Use-2

Sodium dichromate 0 0.26

Chromium trioxide 0.12 0.1

Total 0.12 0.36

Table 20: Tonnage information for Amphenol limited

Amphenol Socapex:



and chromium trioxide) on the site of Amphenol Socapex.

Quantities (in tons) for the years

2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Use-1 0.64 0.62 0.56 0.60 0.55 0.50 0.50 0.50 0.50 0.50 0.40 0.40

Use-2 0.21 0.15 0.20 0.20 0.20 0.20 0.15 0.15 0.15 0.10 0.10 0.10

Total 0.85 0.77 0.76 0.80 0.75 0.70 0.65 0.65 0.65 0.60 0.50 0.50

Table 21 : Past and future estimated consumption on the site of Amphenol Socapex


Use-1 0.40 0.30 0.30 0.30 0.20

Table 22 : Estimated consumption in the site of Amphenol Socapex






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Use-1 Use-2

Sodium dichromate 0.02 -


Total 0.55 0.20

Table 23: Tonnage information for Amphenol Socapex

ITT cannon:



and chromium trioxide) on the site of ITT Cannon.

Quantities (in tons) for the years

2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024

Use-1 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9 1.9

Use-2 1.7 1.7 1.7 1.7 1 1 1 0.75 0.75 0.75 0.75 0.75

Total 3.6 3.6 3.6 3.6 2.9 2.9 2.9 2.65 2.65 2.65 2.65 2.65

Table 24 : Past and future estimated consumption on the site of ITT Cannon


Use-1 1.9 1.9 1.9 1.9 1.9

Table 25 : Estimated consumption in the site of ITT Cannon





Use-1 Use-2


Table 26: Tonnage information for ITT Cannon

It could be noted that only one substance is used on the site of ITT Cannon.

Connecteurs Electriques Deutsch (TE connectivity Evreux - FR)



and chromium trioxide) on the site of TE Connectivity Evreux (Connecteurs

Electriques Deutsch).


52


Use-1 0.16 0.16 0.16 0.16 0.16 0.16 0.16 0.16 0.15 0.15 0.14 0.14

Use-2 0.03 0.05 0.08 0.08 0.08 0.09 0.09 0.09 0.10 0.10 0.10 0.10

Total 0.19 0.21 0.24 0.24 0.24 0.25 0.25 0.25 0.25 0.25 0.24 0.24

Table 27: Past and future estimated consumption on the site of Connecteurs Electriques Deutsch


Use-1 0.13 0.13 0.12 0.12 0.12

Table 28: Estimated consumption in the site of Connecteurs Electriques Deutsch





Use-1 Use-2

Potassium dichromate 0.016 0.10

Chromium trioxide 0.144 -

Total 0.160 0.10

Table 29: Tonnage information for Connecteurs Electriques Deutsch

Tyco Electronics UK Ltd (TE connectivity Hastings - UK)



and chromium trioxide) on the site of TE Connectivity Hastings (Tyco Electronics UK

Ltd).


Use-1 0.32 0.82 0.32 0.63 0.63 0.63 0.63 0.63 0.63 0.63 0.53 0.52

Use-2 0.21 1.01 0.65 0.90 1.10 1.05 1.00 0.95 0.93 0.90 0.80 0.70

Total 0.53 1.83 0.97 1.53 1.73 1.68 1.63 1.58 1.56 1.53 1.33 1.22

Table 30: Past and future estimated consumption on the site of Tyco Electronics UK Ltd


Use-1 0.51 0.41 0.41 0.41 0.41

Table 31: Estimated consumption in the site of Tyco Electronics UK Ltd






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Use-1 Use-2

Potassium dichromate 0.53 0

Sodium dichromate 0.08 0


Total 0.63 1.10

Table 32: Tonnage information for Tyco Electronics UK Ltd

Souriau:

On the table below are presented the past consumption until the year 2015

and the estimated consumption of hexavalent chromium compounds (sodium

dichromate and chromium trioxide) on the site of Souriau.


Use-1 0.999 1.031 0.917 0.944 0.973 1.002 1.032 1.063 1.095 1.127 1.161 1.196

Use-2 1.773 2.337 2.160 2.225 2.292 2.361 2.270 1.500 1.500 1.500 1.000 0

Use-3 2.856 3.907 3.418 3.521 3.626 2.000 2.000 1.000 0.500 0 0 0

Total 5.628 7.274 6.495 6.690 6.891 5.362 5.302 3.563 3.095 2.627 2.161 1.196

Table 33 : Past and future estimated consumption on the site of Souriau


Use-1 1.232 1.269 1.307 1.346 1.386

Table 34: Estimated consumption in the site of Souriau





Use-1 Use-2 Use-3

Sodium dichromate 0.7 1.7 0

Chromium trioxide 0.7 0.7 3.7

Total 1.4 2.4 3.7

Table 35: Tonnage information for Souriau


54

Number of people exposed

The total number of workers exposed is presented in the following table.

Number of people exposed

Amphenol Limited 12

Amphenol Socapex 14

ITT Cannon 6

Connecteurs Electriques Deutsch

26

Tyco Electronics UK Ltd 11

Souriau 31

Table 36: Number of people exposed


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9.1.1.3. Overview of exposure scenarios

The following table lists all the exposure scenarios (ES) assessed in this CSR.

Identifiers* Market

Sector

Titles of exposure scenarios and the related contributing

scenarios

Tonnage of

chromium

trioxide (tonnes

per year)

IW-1

d

SU 3

PC 14

ES1- Industrial use of a mixture of chromic acids for chromium

plating.

14.32

(

IW-1.2 - Sampling of bath (PROC 8a)

IW-1.3 - Lab analysis (PROC 15)

IW-1.4 - Other activities next to the bath (PROC 28)

IW-1.5 - Repackaging of solid by using fume cupboard (PROC 26)

IW-1.6 - Repackaging of solid by using other local ventilation (PROC 26)

IW-1.7 - Repackaging of solid without local ventilation (PROC 26)

IW-1.8 - Repackaging of liquid (PROC 8a)

IW-1.9 - Addition of liquid to bath (PROC 8a)

IW-1.10 - Addition of solid to bath (PROC 8a)

IW-1.11 - Addition of liquid in bath via pumping system (PROC 8b)

IW-1.12 - Handling of articles (PROC 21)

IW-1.13 - Dipping connector parts in treatment bath, in the worker’s near

field (PROC 13)

IW-1.14 - Dipping connector parts in rinsing baths, in the worker’s near

field (PROC 13)

IW-1.15 - Treatment baths in the workers’ far field (PROC 13)

IW-1.16 - Drying connector parts (PROC 7)

* IW = Industrial end use at site.

Table 37: Overview of exposure scenarios and contributing scenarios


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9.1.2. Introduction to the assessment

9.1.2.1. Environment

The environmental assessment is not the main consideration for this CSR

dedicated to the Application for Authorisation regarding the SVHC properties stated

in column 2 of entry 16, 18 & 19 in annex XIV of REACh (COMMISSION REGULATION

(EU) No 125/2012).

At the end of the process, all waste is managed by a specialised waste management

company that also collects all waste (paper, PPE…), except liquid waste which is

treated onsite. Amphenol limited is a specific case for which all the waste is sent off-

site to a specialised certified company (including liquid waste).

Nevertheless, in the environmental contributing scenarios, applicant will analyse and

discuss the possible release and risk for the general population.

9.1.2.2. Man via environment

Risk analysis for man via environment will be performed according to the

conclusions of the environmental release identified in the environmental

contributing scenario.

9.1.2.3. Workers

The excess risk calculation will be based on RAC/27/2013/06 Rev.1 which

establishes a reference dose response relationship for carcinogenicity of

hexavalent chromium.

Regarding the publication of the RAC, no data clearly indicate that dermal exposure

to Cr(VI) compounds presents a risk of cancer to humans. As a consequence, the risk

induced via dermal exposure will not be considered in what follows, especially taking

into account the dermal protections used when the substance is handled.

Moreover, we will estimate the cancer risk mainly due to volatility of the

substance, for lung cancer, and maximize excess of cancer risk by not taking into

account the small intestine cancer risk.

Monitoring measurement campaign are planned on site for exposure assessment of

the entire process. For the description of each contributing scenario, we will use the

ART 1.5 software to calculate an associated value of exposure. In the modelling

process, we will use the Long-term value at 90th percentile for the entire

contributing scenario. ART modelling reports are given in Annex III. It has to be

stressed that, in the ART model, the duration of activity does not impact the results

of the raw exposure estimated for one task. Thus, the duration can be adjusted for

each member for the estimation of the global exposure (made in section 10 and

duration presented in annex I). The results of the modelling approach will be

compared to monitoring measurements. Nevertheless, to calculate the excess risk of

cancer (section 10) we will use the estimation value from ART to assess a

quantitative analysis.


57

In France, as of July 2014, the regulatory constraining level is fixed at 1 µg/m3.

Companies are obliged to carry out air working measurement and take adequate risk

management measures in order to ensure that exposures are below the regulatory

level.

Considering reprotoxic effects, as mentioned in section 5, this Chemical Safety

Report focuses on the use of hexavalent chromium for the carcinogenic/mutagenic

effects. RMM are in place to reduce the risk as low as possible in the framework of

the non-threshold effects (cancer) of the substances. Consequently, as explained in

section 5, it is deemed that these measures also cover the risk due to threshold

effects for reproduction. Finally, when threshold effects are adequately controlled,

they must not be taken into account in the excess risk calculation.

Thus, exposures and excess risk calculation will be developed considering only

carcinogenic effects.

It has to be stressed that the estimated exposures presented for each contributing

scenario in the section 9 are based on the worst case according to the description of

each site, as presented in annex I.

9.1.2.4. Consumers

Not relevant since no consumer will use the final manufactured articles because they

are high technology equipment and they are not intended to be used by consumers.

Only professional workers use the treated connector parts.


58

9.2. Exposure Scenario 1 (ES1): Industrial use of hexavalent

chromium in bath for the surface treatment of connectors.

Sector of use:

Industrial use: Uses of substances as such or in preparations at industrial sites (SU 3)

Article category:

Metal articles (AC 7)

Environemental contributing scenario:

CS1 - Industrial use resulting in inclusion onto a matrix (ERC 5)

Worker contributing scenarios:

CS2 - Sampling of bath (PROC 8a)

CS3 - Lab analysis (PROC 15)

CS4 - Other activities next to the bath (PROC 28)

CS5 - Repackaging of solid by using fume cupboard (PROC 26)

CS6 - Repackaging of solid by using other local ventilation (PROC 26)

CS7 - Repackaging of solid without local ventilation (PROC 26)

CS8 - Repackaging of liquid (PROC 8a)

CS9 - Addition of liquid to bath (PROC 8a)

CS10 - Addition of solid to bath (PROC 8a)

CS11 - Addition of liquid in bath via pumping system (PROC 8b)

CS12 - Handling of articles (PROC 21)

CS13 - Dipping connector parts in treatment bath, in the worker’s near field (PROC 13)

CS14 - Dipping connector parts in rinsing baths, in the worker’s near field (PROC 13)

CS15 - Treatment baths in the workers’ far field (PROC 13)

CS16 - Drying connector parts (PROC 7)

The exposure scenario concerns the immersion of connector parts in bath

treatment for chromium treatment. Only the tasks which lead to exposure of

hexavalent chromium, as identified in the section 9.1.1 are analysed as contributing

scenarios. For all the contributing scenarios concerning the exposure at the

workplace, detailed conditions of use for each site are presented in annex I.

Efficiency of respiratory protective equipment

When it is described in the contributing scenario, wearing respiratory

protective equipment (RPE) is mandatory. Thus, to estimate exposure of workers at

the workplace, it is necessary to determine the effectiveness of the respiratory

protection. The result is the assigned protection factor (APF). The choice of this


59

factor may vary, depending on the country for which it is used. Table 38 presents the

various protective factors assigned to the breathing equipment used in this exposure

scenario (except for the contributing scenario 7). It is a half mask which has been

tested to European Standard EN 143, EN 140 or EN 405 and has met the relevant

requirements of the category P3.

Country /

Nominal protection factor

Assigned protection factors (APF)

EN 140/143 EN 405

France (advised by INRS11

) 10 -

Germany 30 30

Italy 30 -

United Kingdom 20 10

Nominal protection factor 48 33

APF used in this CSR 10 10

APF presented in annex C of the NF EN 529 standard and in INRS guidance

11

Table 38: assigned protection factor

The applicant made the choice to use an APF of 10. This tie in with a

precautionary approach and with the methodology of the modelling approaches of

MEASE12, recommended in the technical guidance of ECHA (ECHA 201213).

For the contributing scenario 7 (CS-7), the respiratory protective equipment (RPE)

used is a powered filtering device incorporating a hood/helmet which has been

tested to European Standard EN 12941 on the class TH3.

11 INRS (Institut National de Recherche et de Sécurité). Les appareils de protection

respiratoire, choix et utilisation. 2011. Ref : ED 6106 12

MEASE is a modelling tool for exposure estimation at the workplace. As described in the section 9.1.2.3, the modelling approach of this CSR , is based on the ART Tool for a Tier 2 exposure estimation. MEASE is not used because it is a Tier 1 exposure estimation. However, the present version of ART cannot estimate the exposure with respiratory protective equipment and consequently the applicant needs to determine an assigned protection factor.

13 Guidance on information requirements and chemical safety assessment, Chapter R.14 :

Occupational exposure estimation. Version : 2.1. 2012. Paragraphe R.14.4.8.3 page25.


60

Country /

Nominal protection factor

Assigned

protection

factor (APF)

France (advised by INRS11

) 40

Finland 200

Germany 100

Italy 200

Sweden 200

United Kingdom 40

Nominal protection factor 500

APF used in this CSR 40

APF presented in annex C of the NF EN 529 standard and in INRS guidance

Table 39: assigned protection factor for the RPE used for CS-7

The applicant made the choice to use an APF of 40. This tie in with a

precautionary approach and with the methodology of the modelling approaches of

MEASE12, recommended in the technical guidance of ECHA (ECHA 201213).


61

9.2.1. Environmental contributing scenario 1: Industrial use resulting in

inclusion onto a matrix

9.2.1.1. Conditions of use

Parameter Information

Product characteristics

• Product Hexavalent chromium in a mixture.

• Physical form Solid dissolved in a liquid

• Amount 0.3 to 7.3 t / year for each site

• Weight fraction of

the substance in the

liquid mixture

Concentration of substance in a bath is in the range of 0.12 to 10 % (w/w)

Operational conditions

• Emission Sources

No release is expected on the process, except for:

- Air extraction from the baths treatment

- Waste production during the treatment of liquid effluents

The integrity of the process circuit is regularly monitored.

The possibilities of release are detailed below.

• Atmospheric

emissions

Air from local extraction of the baths in the plating shop is collected through a specific system. The air is then evacuated through a chimney on the roof of the plating shop.

The possible atmospheric emissions will be considered in the following part of the CSR.

• Liquid effluents

All the liquid effluents containing hexavalent chromium on the industrial site are collected in specific wastewater pipe and treated with a specific treatment in the wastewater treatment plant (WTP) of the site. For the specific case of Amphenol Limited, wastewater is disposed of in specific containers in order to be sent off-site to a specialized certified company.

Water used in the rinsing baths is recycled by using a treatment with ion exchange resin and active carbon. This treatment produces demineralized water. Chromium is consequently eliminated from water.

Mixture drained from the used chromium tanks is collected and treated with a specific process. Hexavalent chromium is reduced with sodium metabisulphite, sodium bisulphite and/or soda (soda can be added specifically to increase the pH value). Then a flocculation is performed, followed by a filtration on filter. The water produced with this process is then recycled to produce demineralised water through the process with active carbon described above.

With this treatment, there is no liquid effluent from the process.

• Waste production All the waste (sludge and used materials) produced during these treatments is managed by a specialized certified waste company.

Table 40: condition of use for the contributing scenario 1


62

9.2.1.2. Releases

Considering the data presented in Table 40, only atmospheric release could

be considered. The air emissions are treated through a specific process, which

reduces hexavalent chromium.

Experts considered in different official reports on possible exposure to hexavalent

chromium14,15, that the most probable risk would be in the local air compartment.

Indeed, on water and soil, hexavalent chromium is transformed into trivalent

chromium via redox reaction 15,16.

Moreover, in the EU RAR about release of hexavalent chromium compounds from

use in metal treatment, no air release was considered (except during formulation of

products)14.

In order to provide more information on possible atmospheric release, the following

table presents the maximum tonnage of substances considered and the distance

between the emission source located on the plating shop and the first home.

Company Site (Town) Distance Total tonnage

TE Connectivity Evreux, FR (Connecteurs Electriques Deutsch) ≈ 200 m 0.26

Hastings, UK (Tyco Electronics UK Ltd) ≈ 135 m 1.73

Amphenol Thyez, FR (Amphenol Socapex) ≈ 115 m 0.79

Whitstable, UK (Amphenol Limited) ≈ 180 m 0.48

Souriau - Esterline Champagné, FR ≈ 250 m 7.5

ITT Cannon Weinstadt, DE ≈ 180 m 3.6

Table 41: Distance from point of release and tonnage of substance

The applicants estimated the release based on modelling exposure. Based on the

table 41, two worst cases are considered:

- Worst case 1: an atmospheric release of 7.5 tons per year with a distance of

200m.

- Worst case 2: an atmospheric release of 1.73 tons per year with a distance of

100m.

14 European Union Risk Assessment Report on hexavalent chromium substances (Volume

53 3rd

priority list) 15

INERIS - Fiche de données toxicologiques et environnementales du chrome et de ses dérivés

16 EPA Ground Water Issue, Natural Attenuation of Hexavalent Chromium in

Groundwater and Soils, EPA154015-941505, 1994


63

The technical guidance document part II17 proposes estimated release factors

depending on the activity type.

The associated release factor is determined by the following parameters:

o IC 16 (Industrial category: engineering industry),

o Solubility > 1g/L,

o Vapor pressure <10 Pa,

o MC=3 (Main category: Non-dispersive use)

Thus, the release factor is determined at 0.00001.

Based on this release estimation and the Doury abacus18 (which estimates the

dispersion speed), we calculated the exposure of the general population around the

site for the worst cases 1&2 and the associated risk.

Worst case 1 (7.3 tons/200m):

Release per working day is estimated (considering 365 working days per year):

= 205.48 mg per day

Worst case 1, release per day: 205.48 mg/day (average of 2.38 µg/s on 24h)

For the assessment, we took the nearest house at approximately 200m for the worst

case 1.

Atmospheric transfer coefficient (at 200m) from Doury Abacus: 5.85x10-4 s/m3

The release in air adjusted on 24h is:

Release

(2.38 µg/s) X

Atmospheric transfer coefficient (at 200m) from

Doury Abacus (5.85x10-4

s/m3)

= 1.39 x 10-3

µg/m3

Worst case 2 (1.7 tons/100m):

Release per working day is estimated (considering 365 working days per year):

= 47.4 mg per day

17 Technical Guidance Document on risk assessment, part II about environmental risk

assessment 18

Abaques d'evaluation directe des transferts atmospheriques d’effluents gazeux, Doury et al, February 1980


64

Worst case 2, release per day: 47.4 mg/day (average of 0.55 µg/s on 24h)

For the assessment, we took the nearest house at approximately 100m for the worst

case 2.

Atmospheric transfer coefficient (at 100m) from Doury Abacus: 1.87x10-3 s/m3

The release in air adjusted on 24h is:

Release

(0.55 µg/s) X

Atmospheric transfer coefficient (at 100m) from

Doury Abacus (1.87x10-3

s/m3)

= 1.03 x 10-3

µg/m3

9.2.1.3. Exposure and risks for the environment and man via the environment

As described above, release of hexavalent chromium in the environment via

soil and water are negligible. No exposure to the substance of man via environment

is therefore considered in this exposure scenario via these compartments.

Considering the release in the atmospheric compartment, after calculation,

the exposures for general population are:

o 1.39 x 10-3 µg/m3 per 24h and considering 365 working days for the worst case 1,

o 1.03 x 10-3 µg/m3 per 24h and considering 365 working days for the worst case 2.

The excess of risk of lung cancer for the general population will be adjusted to the

review period.

Weighted excess of lung cancer risk for general

population Value

Excess risk of lung cancer, per µg/m3 of Cr(VI)

based on 70 years, 365 days per year, 24h per

day (RAC 2013) 2.9x10-2


based on 1 year, 365 days per year, 24h per day 4.1x10-4


based on 7 years (review period for Use-2 & 3),

365 days per year, 24h per day 2.9x10-3


based on 12 years (review period for Use-1),

365 days per year, 24h per day 5.0x10-3

Table 42: RAC adjusted excess of risk calculation for general population


65

Excess risk Worst case Value

Final individual excess risk of lung cancer based on 7 years

(review period for Use-2&3), 365 days per year, 24h per day

Worst case 1 (7.3 tons & 200m)

4.03x10-6


2.97x10-6

Final individual excess risk of lung cancer based on 12 years

(review period for Use-1), 365 days per year, 24h per day


6.92x10-6


5.10x10-6

Table 43: Risk calculation for general population

All the calculated excess risks presented in the above table are in the order of

magnitude of 10-6. The approach used is a generic approach with several

uncertainties which lead to an over-estimation of the exposure:

- The results presented above are based on two worst case scenarios for the

CMG (in terms of tonnage of substance and distance from the source of

emission).

- The air extraction is evacuated from the plating shop through a chimney

located on the roof of the plating shop. This chimney is not located high

enough to consider a wide atmospheric dispersion.

- Specific treatment process for treating the air extracted from the process,

before evacuating it in the atmosphere (acido-basic scrubber, mist

eliminator…) are not considered in the generic estimation presented above.

- In order to respect a short and simple methodology, the quantities used for

the exposure calculations for each worst case scenarios are the global

quantities used on site (for the uses 1, 2 & 3). Consequently, the excess risks

presented separately for Use-1 and the Uses-2&3 take into account the

global quantities involved for the three uses. Thus, there is a double count in

the excess risk presented. A more detailed estimation of exposure is not

presented in order to keep the simplest calculation method.

- This estimation does not take into account the degradation/transformation

reaction of hexavalent chromium. In the environment, including in the air

compartment, hexavalent chromium is a strong oxidising agent which can

react with a wide range of reducing agents to form chromium (III)16. It has

also been shown that chromium (VI) can be photochemically reduced by UV-

light to chromium (III)16.

Conclusion:

Compared to the worker’s excess risk of lung cancer

Considering the risk management measures implemented by all CMG members

Considering the level of containment of the process

Considering the uncertainties which lead our calculation to an over-estimation


66

Considering that the decision point for “acceptable” lifetime cancer risk levels used

for general population are generally around 10-5 *

The risk for general population is considered as negligible.

* This decision point is presented in the technical guidance of ECHA19

19 ECHA Guidance on information requirements and chemical safety assessment,

chapiter R8, Appendix R. 8-14 page 140.


67

9.2.2. Worker contributing scenario 2: Sampling of bath

This contributing scenario deals with the exposure of workers during the

sampling of the mixture containing hexavalent chromium in the bath treatment, as

described in paragraph 9.1.1.1.


In this contributing scenario, exposure is estimated with the modelling approach of

ART (Advanced REACh Tool) version 1.5. The conditions of use described in the table

44 present the information required for this estimation.

Parameters Information for modelling

Product characteristic

• Product Mixture

• Physical form Powder dissolved in a liquid matrix

• Weight fraction Minor (5-10%)

• Viscosity low viscosity (like water)

Operating condition

• Activity class Transfer of liquid products.

Falling liquids.

• Loading type Submerged loading (where the amount of aerosol formation

is reduced).

• Flow of transfer <0.1l/minute

• Duration 2min

• Primary emission source proximity <1m

Risk management measures

• General ventilation 3 ACH

• General control Measures No localised control

• Level of containment Open process

• Demonstrable and effective housekeeping practices in place

No

• General housekeeping practices in place Yes

• Work area Indoors

• Size of the work area 3000m3

Version of the modelling tool : ART (Advanced REACh Tool) version 1.5

Table 44: Condition of use of the contributing scenario 2 - modelling

The ART modelling tool does not take into account all the necessary information for

the risk assessment as required in the CSR. Table 45 presents the necessary

information that does not affect the modelling results.


68

Parameters Information

Personal protective equipment

• Respiratory protective

equipement (RPE) No RPE

• Other personal protective

equipment Protective gloves (chemical gloves approved according to EN 374) and Protective clothes. Technical data sheet in annex.

Exposure value will be validated by working air measure campaign (monitoring). Level of exposure lower than

the estimated level will confirm the risk assessment performed in this CSR.

Table 45: Condition of use for the contributing scenario 2 - other conditions

9.2.2.2. Exposure and risks for workers

The estimated exposure for this contributing scenario is presented in the

table 46. The exposures are presented without respiratory protective equipment

(RPE).

Type of exposure Raw exposure concentration

estimation Duration of work

Short term, ART estimation -

Without RPE 1.7 µg.m

-3 2 min

Table 46: Exposure estimation - contributing scenario 2


69

9.2.3. Worker contributing scenario 3: Lab analysis


titration of the mixture containing hexavalent chromium, performed on a laboratory

bench, in a dedicated area separate from the plating shop, as described in paragraph

9.1.1.1.



ART (Advanced REACh Tool) version 1.5. The conditions of use described in the Table




• Product Mixture


• weight fraction Minor (5-10%)


Operating condition

• Activity class

Activities with open liquid surfaces or open reservoirs.

Activities with undisturbed surfaces (no aerosol formation).

• Duration All the activities concerned cannot exceed 120 min, depending on the

site.


• Open surface <0,1m²


• General ventilation No restriction on general ventilation characteristics

• General control Measures Enclosing hood, fume cupboard.


No

• General housekeeping practices in place

Yes









70




equipement No RPE







The estimated exposure for this contributing scenario is presented in the Table

49. The exposures are presented without respiratory protective equipments (RPE).





-3 120 min



71

9.2.4. Worker contributing scenario 4: Other activities next to the bath


activities performed next to the chromium bath, as described in paragraph 9.1.1.1.







• Product Powders dissolved in a liquid matrix

• Physical form Liquid matrix


• Viscosity Liquids with low viscosity (like water)

Operating condition

• Activity class Activities with open liquid surfaces or open reservoirs.


• Duration All the activities concerned cannot exceed 300min, depending on the site.

• Primary emission source proximity

<1m

• Open surface 0.3 – 1m²





No


Yes









72




equipment (RPE) No RPE







The estimated exposure for this contributing scenario is presented in the table






-3 300 min



73

9.2.5. Worker contributing scenario 5: Repackaging of solid by using fume

cupboard


transfer from one container to another, as described in paragraph 9.1.1.1.







• Product Solid

• Physical form Granules, flakes or pellets

• weight fraction Pure material (100%)

• Moisture content Dry product (<5 % moisture content)

Operating condition

• Activity class

Transfer of powder

Falling of powders

• Drop height Drop height < 0.5 m

• Flow of transfer 0.1 – 1 kg/minute

• Duration 420 min



• General ventilation No restriction on general ventilation

• General control Measures Careful transfer involves workers showing attention to potential

danger. Transfer performed by using a fume cupboard.

• Level of containment Handling that reduces contact between product and adjacent air


No


Yes






74







equipement P3 half mask which has been tested to European Standard EN 143, EN 140 or EN 405








55. The exposures are presented with and without respiratory protective equipments

(RPE). The description of the RPE used is given at the beginning of the section 9.2.





-3 420 min


With RPE 0.11 µg.m

-3 420 min



75

9.2.6. Worker contributing scenario 6: Repackaging of solid by using other

local ventilation









• Product Solid




Operating condition

• Activity class

Transfer of powder

Falling of powders



• Duration 15 min





danger. Local exhaust ventilation, enclosing hood (other enclosing hood).



No


Yes






76





















-3 15 min


With RPE 0.61 µg.m

-3 15 min



77

9.2.7. Worker contributing scenario 7: Repackaging of solid without local

ventilation









• Product Solid




Operating condition

• Activity class

Transfer of powder, granules or pelletised material

Falling of powders



• Duration 5 min



• General ventilation General ventilation: ACH = 3


danger.



No


Yes






78







equipement Powered filtering device incorporating a hood/helmet which has been tested to European Standard EN 12941 on the class TH3.













Without RPE 140. µg.m

-3 5 min


With RPE 3.5 µg.m

-3 5 min



79

9.2.8. Worker contributing scenario 8: Repackaging of liquid









• Product Liquid


• Weight fraction Substantial (10-50%)

Operating condition

• Activity class

Transfer of liquid

Falling liquid.

• Type of handling Splash loading

• Flow of transfer 1 - 10 l/minute

• Duration 5 min






No


Yes









80

















Without RPE 50 µg.m

-3 5 min


With RPE 5 µg.m

-3 5 min



81

9.2.9. Worker contributing scenario 9: Addition of liquid to bath


addition of mixture in the bath treatment, as described in paragraph 9.1.1.1.







• Product Mixture


• weight fraction Substantial (10 - 50%)

• Viscosity Low viscosity (like water)

Operating condition

• Activity class

Transfer of liquid products

Falling liquids, Splash loading

• Flow of transfer 1-10 l/minute








No


Yes









82


















-3 60 min


With RPE 1.8 µg.m

-3 60 min



83

9.2.10. Worker contributing scenario 10: Addition of solid to bath


addition of mixture in the bath treatment, as described in paragraph 9.1.1.1.




68 presents the information required for this estimation.



• Product Solid




Operating condition

• Activity class Transfer of powder

Falling of powders



• Duration All the activities concerned cannot exceed 60min, depending on the

site.




• General control Measures

Careful transfer involves workers showing attention to potential danger.

Wetting at the point of release

• containment of the process Open process


No


Yes









84


















-3 60 min


With RPE 1.3 µg.m

-3 60 min



85

9.2.11. Worker contributing scenario 11: Addition of liquid in bath via

pumping system


addition of mixture in the bath treatment via a pumping system, as described in

paragraph 9.1.1.1.







• Product Mixture


• weight fraction Substantial (10 - 50%)


Operating condition

• Activity class

Transfer of liquid products

Bottom loading.

• Flow of transfer 10-100 l/minute

• Duration 10 min




• General control Measures Handling that reduces contact between product and adjacent air.

Low level of containment


No


Yes









86













The description of the RPE used is given at the beginning of the section 9.2.





-3 10 min



87

9.2.12. Worker contributing scenario 12: Handling of articles

This contributing scenario deals with the dermal exposure of workers during the

disassembly of connector parts on the structure, at the end of treatment process, as

described in paragraph 9.1.1.1.


In this contributing scenario, dermal exposure is quantitatively analysed. The

conditions of use are described in the Table 74:

Parameters Condition of use on the CMG’s site


• Product Articles with hexavalent chromium included into a matrix

Operating condition

• Activity class Handling of articles


• General ventilation Good general ventilation

• Personal protective equipment Protective gloves (chemical gloves approved according

to EN 374) and Protective clothes. Technical data sheet in annex.


No

• General housekeeping practices in place. Yes


Other parameters

• Quantity <0.01% per article

• Frequency Every days

Table 74: Condition of use for the contributing scenario 12


Considering that:

- there is no liquid form of the mixture of hexavalent chromium remaining on

the article (they have been rinsed, further treated without hexavalent

chromium and then dried);

- the remaining hexavalent chromium on the article is included into a matrix

composed of the oxidized surface of the article;

- the remaining hexavalent chromium is lower than 0.01% for each article

(RoHS compliant);

- protective gloves are used to avoid any potential contact with chemicals,

including hexavalent chromium;


88

The cutaneous route of exposure is considered negligible.

Furthermore, as indicated by RAC, there is no data to indicate that dermal exposure

to Cr(VI) compounds presents a cancer risk to humans. NIOSH20 reports that some

data indicates that CrVI is reduced prior to systemic uptake (Corbett GE et al. 1997 ;

Liu KJ et al. 1997).

The cancer risk to workers via dermal route, in the case of CMG members is

therefore considered negligible.

20 National Institute for Occupational Safety and Health, Occupational Safety and Health

Administration Request for information Occupational Exposure to Hexavalent Chromium (CrVI); Novermber 20, 2002.


89

9.2.13. Worker contributing scenario 13: Dipping connector parts in

treatment bath, in the worker’s near field

This contributing scenario deals with the exposure of workers during the dipping

of article in the bath with local exhaust ventilation (LEV), as described in paragraph

9.1.1.1.











Operating condition





<1m




• General control Measures

Local exhaust ventilation (LEV), fixed capturing hood.


No


Yes


• Size of the work area

3000m3







90

















-3 50 min



91

9.2.14. Worker contributing scenario 14: Dipping connector parts in rinsing

baths, in the worker’s near field

This contributing scenario deals with the exposure of workers during the dipping

of article in the bath treatment line, as described in paragraph 9.1.1.1.









• Weight fraction Very small (0.5-1%)


Operating condition



• Duration All the activities concerned cannot exceed 30min, depending on the

site.


<1m






No


Yes









92

















-3 30 min



93

9.2.15. Worker contributing scenario 15: Treatment baths in the workers’

far field

This contributing scenario deals with the exposure of workers when they are

present in the plating shop, as described in paragraph 9.1.1.1.











Operating condition





>1m

• Treated surface 1 – 3m²



• General control Measures Fixed capturing hood


No


Yes









94

















-3 420 min



95

9.2.16. Worker contributing scenario 16: Drying connector parts

This contributing scenario deals with the exposure of workers when they are

present in the plating shop, as described in paragraph 9.1.1.1.









• Weight fraction Small (1-5%)


Operating condition

• Activity class

Spray application of liquids (this activity class is considered in a precautionary approach, in order to consider evaporation and impaction as emission generation mechanisms)

Surface spraying liquids. Horizontal or downward spraying Spraying with no or low compressed air use

• Duration 3 min


<1m

• Application rate Very low application rate (< 0.03 l/minute is considered as the rate of aerosol

formation due to the use of air gun)



• General control Measures Enclosing hoods (other enclosing hoods)


No


Yes









96




equipment (RPE) P3 half mask which has been tested to European Standard EN 143, EN 140 or EN 405.










It has to be stressed that the estimation of exposure for this contributing

scenario is an over-estimation since the activity class considered is a spray

application of liquids whereas the potential formation of aerosol by using the airgun

cannot be considered as important as a spraying activity. However, this activity class

was used in order to consider evaporation and impaction as emission generation

mechanisms in order to ensure the suitability of the precautionary approach used in

this CSR and to take into account all the potential emission mechanisms which could

lead to an exposure. Consequently, the exposure estimation presented in this

contributing scenario is particularly an over estimation, but this contribute to take

into account all the potential exposure of workers.





-3 3 min


With RPE 0.67 µg.m

-3 3 min



97

9.3. Exposure Scenario 2 (ES2): Professional use of articles

treated by immersion.

This exposure scenario deals with the use of final treated articles. They are

equipments used for high technology purposes and they are not intended to be used

by consumers. Only professional workers are therefore concerned by this ES.

Considering that there is no liquid form of the mixture of hexavalent chromium

remaining on the article, there is no possibility of exposure to hexavalent chromium

via inhalation route.

Considering that:

- the remaining hexavalent chromium on the article is included into a matrix

composed of the formation of oxidized surface of the article;

- the thick layer of this matrix is in the order of magnitude of micrometer;

- the remaining hexavalent chromium is lower than 0.01% for each article;

The cutaneous route of exposure is considered negligible.

Furthermore, as indicated by RAC, there is no data to indicate that dermal exposure

to Cr(VI) compounds presents a cancer risk to humans. NIOSH21 reports that some

data indicates that CrVI is reduced prior to systemic uptake (Corbett GE et al. 1997;

Liu KJ et al. 1997).

The cancer risk to workers via dermal route in the case of the use of connectors

produced by CMG is therefore considered negligible.

21 National Institute for Occupational Safety and Health, Occupational Safety and Health

Administration Request for information Occupational Exposure to Hexavalent Chromium (CrVI); Novermber 20, 2002.


98

10. RISK CHARACTERISATIO N RELATED TO

COMBINED EXPOSURE

10.1. Human health (related to combined exposure)

This CSR analyses only hexavalent chromium exposure at the workplace for an

industrial use. There is no possibility of exposure for professional use. The risk

characterization is performed for the sites of CMG members concerned by Use-1, 2 &

3.

It should be noted that the contributing scenario 12 (Handling of articles) is focused

on dermal route and a qualitative approach has been used. Thus, the risk

characterisation presented in this section focuses on the inhalation exposure.

10.1.1. Workers distribution of tasks

Two different common assumptions are made in order to estimate the frequencies

of exposure during one typical year. For all the sites, the plating shop is considered

open during 51 weeks per year. Each individual employee only works 44 weeks a

year.

10.1.1.1. Amphenol Limited

For the site of Amphenol limited, it is important to describe the baths solution

lifecycle, in order to understand the frequencies associated with drainage of baths

(CS-4), manual addition of liquid mixture (CS-9) or solid (CS-10) and the repackaging

associated with manual addition (CS-7). The control of this lifecycle is made through

lab analysis. Consequently, the frequencies of sampling and lab analysis are also

linked with these activities.

For Use-1:

At Amphenol Ltd, the solution lifecycle varies, depending on what the solution is:

olive Cd passivation, yellow Cd passivation or clear Cd passivation.

Sampling & lab

analysis Drainage of

baths Manual

addition, liquid Manual

addition, solid Repackaging

of solid

Olive Cd passivation

Twice a day

(2*5*51per year)

1 per week

(51 per year)

1 per week

(51 per year) - -

Yellow Cd passivation

(also used for Use-2)

1 per week

(51 per year, considered at 26 per

year for Use-1)

4 per year

(considered at 2 per year for

Use-1)

4 per year

(considered at 2 per year for Use-1)

- -

Clear Cd passivation

1 per week

(51 per year) Once a year - Once a year Once a year

Table 87: Activities associated with solutions lifecycle at Amphenol Ltd – Use-1


99

It should be noted, that:

- no lab analysis is performed for these baths, sampling and pH measurements

are performed at the bath and thus both considered with the contributing

scenario 2 (as described in the section 9.1.1.1);

- There are no routine maintenance additions made to these solutions, either

manually or via an autodosing unit. Substances are only added to the tank at

the time of making up a new solution (ie the old solution is drained out, and a

new one made up).

There are a total of 3 baths considered for Use-1. The treatment bath used for Yellow

Cd passivation is also used for ZnCo, in the context of Use-2.

Thus, the following table is presented with the estimated duration and frequencies

for each contributing scenario.

On the site of Amphenol Limited, the duration for draining a bath does not exceed 15

minutes (this is the time to open the valve and allow the old solution to empty out of

the tank into the waste holding tank).


100

Time/frequency CS-2: Sampling

of bath

CS-4: other, next to the bath

CS-7:

Repackaging,

solid

CS-9:

Manual

addition,

liquid

CS-10: Manual

addition, solid

CS-13: Dipping

in chromium

bath, near field

CS-14: Dipping

in rinsing bath,

near field

CS-15: Treatment

bath, far field For drain Others

For Use-1: Olive Cd, clear Cd and yellow Cd (but the yellow bath is used for Cd and ZnCo)

Duration of the task 1 min 15 min 120 min 5 min 60 min 60 min 10 min for a whole

day 5 min for a whole

day 420 min

Frequency per year

(for all workers) (2*5*51) + 51 +26 2+51+1

Maintenance estimated at twice a

year 1 2+51 1

1 per day, 5 days per week, 51 weeks per

year


year

1 per day, 5 days per week, 44 weeks per year

Annual frequency

(for 1 of the 2 lab analysts)

Not done by lab. Not done by lab Not done by lab 1/2 Not done by

lab Not done by lab Not done by lab Not done by lab Not done by lab

Annual frequency

(for 1 of the10 platers)

587 / 10 54/10 Not concerned Not concerned (2+51)/10 1/10 5*51/10 5*51/10 5*44

Annual frequency

(for 1 of the 2 workers of the maintenance team)

Not concerned Not concerned 2 Not concerned Not concerned Not concerned Not concerned Not concerned Not concerned

Table 88: Table with durations and frequencies at Amphenol Ltd – Use-1


101

For the Use 2:

As for Use-1, the baths solution lifecycle and the frequencies of tasks associated are

detailed in the following table. At Amphenol Ltd, the solution lifecycle varies,

depending on what the solution is: black Zn-Ni passivation, Zn-Ni post dip, Black Zn-

Co, Green Zn-Co and stainless steel. A total of five baths are involved, or six if we also

consider the Yellow Zn-Co (counted twice with Use-1).

Sampling & lab

analysis Drainage of

baths Manual addition,

liquid Manual

addition, solid Repackaging

of solid

Black Zn-Ni passivation

Twice a day (2*5*51

per year)

+

1 Lab analysis per week

(51 per year)

Once a month

(12 per year)

Once a week (routine) +

Once a month (to

make up a new solution)

- -

Post dip Zn-Ni - Once a month

(12 per year)

Once a month

(to make up a new solution)

- -

Yellow Zn-Co

(also used for Use-1)

1 per week

(51 per year, considered at 25 per year for Use-2)

4 per year

(considered at 2 per year for Use-1)

4 per year

(to make up a new solution, considered at 2

per year for Use-1)

- -

Black Zn-Co Twice a day (2*5*51

per year) Every 6 months

(2 per year)

2 per year


- -

Green Zn-Co Twice a day (2*5*51

per year) Every 3 months

(4 per year)

4 per year


- -

Stainless Steel - 1 per year - 1 per year


1 per year

Table 89: Activities associated with solutions lifecycle at Amphenol Ltd – Use-2

When the black Zn-Ni passivation bath is analysed weekly, the sampling is performed

by the lab technicians; all other sampling (to measure pH) is done by platers

(operators).


102

Time/frequency

CS-2:

Sampling of

bath

CS-3: Lab

analysis

CS-4: other, next to

the bath CS-7:

Repackaging,

solid

CS-9: Manual addition,

liquid

CS-10:

Manual

addition,

solid

CS-13:

Dipping in

chromium

bath, near

field

CS-14:

Dipping in

rinsing

bath, near

field

CS-15:

Treatment

bath, far

field

CS-16:

Drying For drain Others

For Use-2: ZnNi (black passivate + post dip); ZnCo: green, black, yellow (shared with Cd); Stainless steel.

Duration of the task

1 min 5 min 15 min 120 min 5 min

2 min

(routine addition)

60 min


60 min 50 min for a whole day

5 min for a whole day

420 min 3 min

Frequency

(for all workers)

3*2*5*51 + 51+ 25

51

(12+12+2+2+

4+1)

per year

1 per year (maintenance)

1/year 51 12+12+2+2+4 1 per year


year

1 per day, 5 days per week, 51

weeks per year


year

20 jigs per day, 5 days

per week, 51 weeks per

year

Annual frequency

(for 1 of the 2 plating lab analysts)

51/2

(black Zn-Ni) 51/2 Not done by

lab

Done by Maintenance

team – not lab.

1/2 Not done by

lab Not done by

lab Not done by

lab Not done by lab

Not done by lab

Not done by lab

Not done by lab

Annual frequency

(for 1 of the10 platers)

(3*2*5*51+25) / 10

Not concerned

33/10

Done by Maintenance

team – not platers.

Done by Lab 51/10 32/10 1/10 5*51/10 5*51/10 5*44 (20*5*51)/1

0

Annual frequency (for 1 of the 2 workers of the maintenance team)

Not concerned Not

concerned Not

concerned 1

Not concerned

Not concerned

Not concerned Not concerned Not concerned Not

concerned Not

concerned Not

concerned

Table 90: Table with durations and frequencies at Amphenol Ltd – Use-2


103

10.1.1.2. Amphenol Socapex

For Amphenol Socapex the description of the baths solution lifecycle is not

necessary for the understanding of the frequencies associated with the contributing

scenario considered:

o For Use-1:

- CS-4: Other activities next to the bath

- CS-5: Repackaging of solid by using fume cupboard

- CS-8: Repackaging of liquid

- CS-9: Addition of liquid to bath

- CS-10: Addition of solid to bath

- CS-13: Dipping connector parts in treatment bath, in the worker’s near field

- CS-14: Dipping connector parts in rinsing baths, in the worker’s near field

- CS-15: Treatment baths in the workers’ far field

o For Use-2:

- CS-2: Sampling of bath

- CS-3: Lab analysis

- CS-4: Other activities next to the bath CS-5: Repackaging of solid by using fume cupboard

- CS-8: Repackaging of liquid





It should be noted, that there are no sampling and titration under Use-1. New

solution bath is made up with a solid form in the context of Use-1 and with a liquid

form in the context of Use-2.

The duration taken into account for the CS-15 (Treatment bath, far field) is lower

than the other CMG members because as described in the section 9.1.1. the

assembly and dismantling of parts is made by operators in a separate room.

Consequently the time provided for this activity is not considered as an exposure into

the CS-15, and the global duration of the CS-15 for an operator of the plating shop is

thus considered at 300min. Furthermore, an exposure for technicians or engineers is

considered with the CS-15 with a duration of 60min in order to cover occasional visit

of in the plating shop.

Thus, the following table is presented with the estimated duration and frequencies

for each contributing scenarios.


104

Use-1 :

Time/frequency

CS-4: Other, next to the

bath CS-5:

Repackaging,

solid

CS-8:

Repackaging,

liquid

CS-9: Manual

addition, liquid

CS-10: Manual

addition, solid

CS-13: Dipping in

chromium bath,

near field

CS-14:

Dipping in

rinsing bath,

near field

CS-15:

Treatment


Duration of the task 15 min 120 min 420 min 5 min 5 min 5 min 15 min for a whole

day 10 min for a whole day

60 or 300 min

Frequency

(for 10 workers of the plating shop)

1 per week 1 per month 1 per year 1 per week 1 per week 1 per month 5*51 per year 5*51 per year

5*44 per year (300 min)

Per worker

Frequency

(for 1 of the 4 technicians or engineers)

Not concerned

Not concerned

Not concerned Not concerned Not concerned Not concerned Not concerned Not concerned 5*44 per year (60

min)

Table 91: Table with durations and frequencies at Amphenol Socapex – Use-1

Use-2 :

Time/frequency

CS-2:

Sampling of

bath

CS-3: Lab

analysis


bath CS-8:

Repackaging,

liquid

CS-9: Manual

addition, liquid

CS-13: Dipping in

chromium bath,

near field

CS-14: Dipping

in rinsing

bath, near

field

CS-15:

Treatment bath,

far field For drain Others

Duration of the task 2 min 120 min 15 min 120 min 5 min 5 min 15 min for a whole day 10 min for a whole day

60 or 300 min

Frequency


Not concerned Not

concerned 1 per week 1 per month 1 per day 1 per day 5*51 per year 5*51 per year


Per worker

Frequency (for 1 lab worker)

2 per month 2 per month Not

concerned Not concerned Not concerned Not concerned Not concerned Not concerned Not concerned

Frequency

(for 1 of the 4 technicians or engineers)

Not concerned Not

concerned Not

concerned Not concerned Not concerned Not concerned Not concerned Not concerned


Table 92: Table with durations and frequencies at Amphenol Socapex – Use-2


105

10.1.1.3. ITT Cannon

On the site of ITT cannon, the following contributing scenarios are involved:


- CS-11: Addition of liquid in bath via a pumping system




It should be noted that on the site of ITT Cannon, only one chromium bath is used for

both Use-1 and Use-2. According to the quantity of connector parts treated for each

used, it appears to be equal between the two uses. Thus, in order to identify what

could be the exposure due to Use-1 or Use-2 separately, the frequencies were

spread evenly.

Consequently, the duration and frequencies are presented in the following table:

For Use-1:

Time/frequency CS-4: other, next

to the bath

CS-11: Automatic

addition, liquid

CS-13: Dipping in

chromium bath,

near field

CS-14: Dipping in

rinsing bath, near

field

CS-15:

Treatment bath,

far field

Duration of the task 5 min 30 min 10 min 5 min 5 min 420 min

Frequency


1 per week, 51 weeks per year

1 per year


year

2 times a year

(Sample production)

2 times a year

(Sample production)

Everyday

(5 days per week, 44 weeks per

year)

Frequency

(for 1 of the 6 workers of the plating shop)

(51)/6 per year

(1)/6 per year

255/6 per year 2/6 per year 2/6 per year 220 per year

Table 93: Table with durations and frequencies at ITT Cannon – Use-1

For Use-2:

The exact same table than the one presented for Use-1 will be used for Use-2.

For the contributing scenario 4, the estimation is based on the following:

- partial emptying the bath (by pressing a button) when adding new solution

(included in the 5 minutes presented, once per week)

- cleaning LEV (included in the 5 minutes presented, once a week)

- maintenance operations (30 min, once a year)

It should be noted that, even if the treatment line is automated and designed to

avoid any manual dipping, there are still exceptional manual dipping in order to treat

connector parts for sample production. The sample productions are exceptional and

a small batch of connectors are made for research and testing.


106

It has to be stressed that on the site of ITT Cannon collective protective equipment

are preferred against individual protective equipement. That is why no respiratory

protective equipement is worn, and that there are several ventilations in the plating

shop.


107

10.1.1.4. Souriau

On the site of ITT cannon, the following contributing scenarios are involved:




- CS-6: Repackaging of solid by using other local ventilation


- CS-10: Addition of solid to bath




All these contributing scenarios are involved for the three uses, except for Use-3, for

which the CS-9 is not performed because no liquid mixture is used for the addition in

the baths, and except the CS-13 & 15 because the treatment line involved on Use-3 is

an automated line. Consequently, there is no manual dipping and no addition of

liquid into bath involved for Use-3.

In order to consider the frequencies for each contributing scenarios, the treatment

lines have been considered with the following different populations of workers:

1. Operators of the treatment lines dedicated to Use-1



4. Operators for repackaging solid (involved on the 3 uses)

5. Internal maintenance team (involved on the 3 uses)

6. External Maintenance Team (involved on the 3 uses)

7. Lab operators (involved on the 3 uses)

The operators working on the treatment lines are composed of 6 or 9 workers for

each use. For each use, the 3 most experienced workers are the ones involved in the

operations of manual dipping (CS-13 & 15) and the additions of mixtures (CS-9 & 10).

The other 3 (less experienced) mainly work on the extremity of the treatment lines.

The duration and frequencies are presented as follow:


108

Use-1:

Time/frequency

CS-2:

Sampling of

bath

CS-3: Lab

analysis


bath CS-6:

Repackaging,

solid

CS-9:

Manual

addition,

liquid

CS-10:

Manual

addition,

solid

CS-13: Manual

dipping in

chromium bath,

near field

CS-14: Manual

dipping in

rinsing bath,

near field

CS-15:

Treatment

bath, far field For

drain Others

Duration of the task 2 min 5 min 2 min 60 min 300 min

(2workers) 15 min 5 min 5 min

5 min for a whole day per worker

5 min for a whole day per worker

420 min per worker

Frequency for all the workers

50/year 50/year 111/year 18/year 0.5/an 89/year 22/year 89/year 5*44 per year for

each worker 5*44 per year for

each worker 5*44 per year for

each worker

6 w

ork

ers

on

th

e

tre

atm

en

t lin

e

Frequency

(for 1 of the 3 more experienced)

- - (111/6)

per year - - -

(22/3)

per year

(89/3)

per year 5*44 per year 5*44 per year 5*44 per year

Frequency

(for 1 of the 3 less experienced)

- - (111/6)

per year - - - - - - - 5*44 per year

Frequency for 1 of the 3 workers of the internal team dedicated to the repackaging

- - - - - 89/3 per year - - - - -

Frequency for 1 of the 2 workers of internal maintenance team

- - - 18/2 per

year - - - - - - -

Frequency for 1 of the 2 workers of external maintenance team

- - - - 0.5 per

year (per workers)

- - - - - -

Frequency for 1 of the 3 worker of laboratory team

50/3 per year 50/3 per

year - -

-

- - - - - -

Table 94:Table with durations and frequencies at Souriau – Use-1


109

Use-2:

Time/frequency

CS-2:

Sampling of

bath

CS-3: Lab

analysis

CS-4: Other, next to

the bath CS-6:

Repackaging,

solid

CS-9:

Manual

addition,

liquid

CS-10:

Manual

addition,

solid

CS-13: Manual

dipping in

chromium bath,

near field

CS-14: Manual

dipping in

rinsing bath,

near field

CS-15:

Treatment

bath, far

field For

drain Others

Duration of the task 2 min 5 min 2 min 60 min

300 min

(2 workers)

15 min 5 min 5 min 5 min for a whole day

per worker 5 min for a whole day per worker

420 min per worker

Frequency for all the workers 25/year 25/year 187/year 36/year 0.5/year 115/year 72/year 115/year 5*44 per year for each

worker 5*44 per year for

each worker 5*44 per year

for each worker

9 w

ork

ers

on

th

e

tre

atm

en

t lin

e Frequency

(for 1 of the 3 more experienced)

- - 187/9

per year - - - 72/3 per year 115/3 per year

5*44 per year for each worker



Frequency

(for 1 of the 6 less experienced)

- - 187/9

per year - - - - - - -



- - - - - 115/3 per year - - - - -


- - - 36/2 per

year - - - - - - -


- - - - 0.5 per

year (per workers)

- - - - - -


25/3 per year 25/3 per

year - -

- - - - - - -

Table 95: Table with durations and frequencies at Souriau – Use-2


110

Use-3 :

Time/frequency CS-2: Sampling

of bath

CS-3: Lab

analysis

CS-4: Other, next to the bath CS-6: Repackaging,

solid

CS-10: Manual

addition, solid

CS-15: Treatment


Duration of the task 2 min 5 min 2 min 60 min 300 min

(2 workers) 15 min 5 min 420 min

Frequency for all the workers 150/an 150/an 67/year 6/year 0.5/year 67/year 67/year 5*44 per year for each

worker

6 w

ork

ers

on

th

e

tre

atm

en

t lin

e Frequency

(for 1 of the 3 more experienced) - - 67/6 per year - - - 67/3 per year


Frequency

(for 1 of the 3 less experienced) - - 67/6 per year - - - -



- - - - - (67/3) per year - -


- - - 6/2 per

year - - - -


- - - 0.5/year (per

worker) - - -


150/3

per year

150/3

per year - - - - - -

Table 96: Table with durations and frequencies at Souriau – Use-3


111

10.1.1.5. Connecteurs Electriques Deutsch (TE Connectivity Evreux - FR)

On the TE Connectivity’s site of Evreux, the following contributing scenarios are

involved:


- CS-9: Addition of liquid to bath (for Use-1only)

- CS-10: Addition of solid to bath (for Use-2 only)


(for Use-1 only)



It should be noted that:

- No sampling or lab analyses are performed for the Use-1 on the site of TE

Connectivity at Evreux (Connecteurs Electriques Deutsch).

- Partial drain of bath and partial maintenance are performed 6 times a year

and they are grouped into contributing scenario 4. All these operations are

included in the 15 minutes presented below.

- Additional manual dipping can occur for Use-1 in order to adjust the

automatic treatment of connector parts. This activity does not exist in the

context of Use-2.


Use-1

Time/frequency

CS-4: Other, next to

the bath

CS-9:

Manual

addition,

liquid

CS-13: Manual

dipping in

chromium bath,

near field

CS-14: Manual

dipping in rinsing

bath, near field

CS-15:

Treatment

bath, far

field For drain Others

Duration of the task 15 min 300min 15 min 10 min for a whole day

for one worker 10 min for a whole day for one worker

420 min per worker

Frequency

(for 1 main technician of the plating shop)

6 per year Not

concerned 6 per year 44 per year 44 per year 5*44 per year

Frequency

(for 1 substitute technician of the plating shop)

1 per year Not

concerned 1 per year 5 per year 5 per year 5*5 per year

Frequency


Not concerned

Not concerned

Not concerned Not concerned Not concerned 5*44 per year

Frequency

(for 1 of the 2 workers for maintenance)

Not concerned

1 per year Not concerned Not concerned Not concerned Not concerned

Table 97: Table with durations and frequencies at Connecteurs Electriques Deutsch – Use-1


112

For the Use-1, there is 1 main technician working on the automated treatment line.

The duration of work during one year is considered as 44weeks per year. One more

technician is substituted for the actual one in case of vacation or departure. The

frequencies for the substitute worker are considered for 5 weeks of work per year on

the treatment line.

Use-2

Time/frequency

CS-2:

Sampling

of bath

CS-3: Lab

analysis


bath CS-10: Manual

addition, solid

CS-15:

Treatment


Duration of the task 2 min 5 min 15 min 30 min 15 min 420 min

Frequency

(for 2 technician of the plating shop)

Not concerned

Not concerned

6 pear year Not concerned 6 pear year 5*44 per year/

worker

Frequency

(for 1 substitute technician of the plating shop)

Not concerned

Not concerned

1 per year Not concerned 1 per year 5*5 per year

Frequency

(for 1 worker of the laboratory)

1 per week

(44 per year) 1 per week

(44 per year) Not concerned Not concerned Not concerned Not concerned

Frequency


Not concerned

Not concerned

Not concerned Not concerned Not concerned 5*44 per year /

worker

Frequency

(for 1 of the 2 workers for maintenance)

Not concerned

Not concerned

Not concerned 1/year Not concerned Not concerned

Table 98: Table with durations and frequencies at Connecteurs Electriques Deutsch – Use-2

As for Use-1, for the Use-2 there is one substitute technician and the frequencies are

considered for 5 weeks of work on the treatment line.


113

10.1.1.6. Tyco Electronics UK Ltd (TE Connectivity Hastings - UK)

On the TE Connectivity’s site of Hasting, the following contributing scenarios are

involved:




- CS-6: Repackaging of solid by using other local ventilation





It should be noted that partial drain of bath and maintenance are performed every

days and they are grouped into contributing scenario 4. All these operations are

included in the 10 minutes presented below.


Use-1

Time/frequency

CS-2:

Sampling

of bath

CS-3: Lab

analysis

Cs-4:

Other,

next to the

bath

CS-9:

Manual

addition,

liquid

CS-13: Manual

dipping in

chromium

bath, near

field

CS-14:

Manual

dipping in

rinsing bath,

near field

CS-15:

Treatment

bath, far

field

Duration of the task

2 min 10 min 10 min 10 min 15 min for a whole

day 30 min for a whole day

420 min

Frequency


1 per day 1 per day 1 per day 1 per day 1 per day 1 per day 5*44 per year/

worker

Frequency


(1*5*51)/11 per year

(1*5*51)/11 per year

(1*5*51)/11 per year

(1*5*51)/11 per year

(1*5*51)/11 per year

(1*5*51)/11

per year

5*44

per year

Table 99: Table with durations and frequencies at Tyco Electronics UK Ltd – Use-1

Use-2

The duration and frequencies presented for Use-1 are identical for Use-2.


114

10.1.2. Comparison between modelling and monitoring


Air monitoring of the workplace was undertaken on the site of Amphenol Ltd in

2015 in order to control exposure to hexavalent chromium compounds. These results

are compared to modelling results in the table below. Two measurements were

performed: one by sampling air with a pump worn by an operator (personal sample),

the other one by using a pump fixed on a support in the centre of the plating area

(static sample).

In order to compare the modelled results with measured concentrations,

according to the section 10.1.1.1. the following description of activity is given as

follow:

- Sampling of bath,

- Addition of liquid to the bath

- dipping in chromium bath,

- dipping in rinsing bath,

- treatment bath in the worker’s far field

- drying of connector parts.

Consequently, the measured and modelled exposures are as follows:

Monitoring results (µg/m3) Modelling results (µg/m3)

Static measurement (sampled during 240mins)

<2 (DL*) Worker far field 0,0053

Personal measurement (average over 480mins)

<1 (DL*) Main activities of plater (average over 480mins)

0,145

*DL = Detection Limit (used by the laboratory that is carrying out the analysis

and converted to µg/m3)

N.B. All the original reports are presented in annex IV

Consequently the results presented in the 2015 monitoring report indicate that

the level of exposure at Amphenol Limited seems to be as low as the modelled

exposures, as they are below the detection limit of the methodology usually used in

the UK.

It should be emphasised that total chromium (whatever the oxidation state) was

also measured, both in 2015 and in 2014. During the monitoring campaigns of the

last 2 years (2015 & 2014), no measurement results of total chromium exceeded the

detection limit of 1 µg/m3 for static samples (1 sample considered)and 1 µg/m3

(considering a 480 min exposure) for personal samples (a total of 5 samples being

considered).

The monitoring results on the site of Amphenol Limited indicate that the level of exposure

at Amphenol Limited seems to be as low as the modelled exposures.


115


On the site of Amphenol Socapex, since 2015, air monitoring at the workplace is

performed each year in order to control the exposure to hexavalent chromium

compounds. The results of the 2015 campaign are thus compared to modelling

results in the following table.


according to the section 10.1.1.2. the following description of activity is given in the

table according to the title of contributing scenario except for the workers of the

plating shop at a treatment line with chromium for who the following tasks have

been considered : activities next to the bath, dipping in chromium bath, dipping in

rinsing baths and far field exposure.

Measured concentrations (µg/m3) Modelling concentrations (µg/m3)

Workers of the plating shop with addition of liquid (Personal measurement, average on 480mins)

0.009 0.77

Workers of the plating shop - treatment line with chromium

(Personal measurement, average on 480mins)

<0.030 (QL)

0.065

<0.010 (QL)

Laboratory worker (Personal measurement, average on 480mins)

<0.009 (QL) 0.019

Static measurement in the centre of the plating shop (far field exposure to chromium)

<0.010 (QL)

0.0053 Workers of the plating shop - not at a treatment line with chromium (far field exposure to chromium)

(Personal measurement, average on 480mins)

<0.011 (QL)

<0.011 (QL)

Addition of liquid (Personal measurement, sampled 15mins)

<0.327 (QL) 6.0

*QL = Quantification Limit (used by the laboratory that is carrying out the analysis and converted to µg/m3)


Consequently the results presented in the monitoring report of the 2015

campaign indicate that the level of exposures at Amphenol Socapex seems to be as

low as the modelled exposures because they are below the quantification limit.

The monitoring results on the site of Amphenol Socapex attest that the modelling approach

is mainly an over-estimation and tie in with a precautionary approach.


116


Air monitoring of the workplace was undertaken on the site of ITT Cannon in

2009 in order to control exposure to hexavalent chromium compounds in the

context of national compliance. The sample was performed in order to measure the

ambient air concentration in the working area next to the operators considered in

this CSR. The result is compared to modelling results in the table below.

Monitoring results (µg/m3) Modelling results (µg/m3)

Static measurement (sampled during 120mins)

<5 (DL*) Worker’s far field exposure 0,0053

*DL = Detection Limit (used by the laboratory that is carrying out the analysis

and converted to µg/m3)



the level of exposure at ITT Cannon seems to be as low as the modelled exposures,

as they are below the detection limit of the methodology usually used in Germany.

It should be emphasised that in Germany there is no official occupational

exposure limit at the workplace for hexavalent chromium. Nevertheless ITT Cannon

will perform new measurement campaign at the workplace in order to verify the

compliance with the exposure level described in this CSR.

The monitoring results on the site of ITT Cannon indicate that the level of exposure at ITT

Cannon seems to be as low as the modelled exposures.


117

10.1.2.4. Souriau

On the site of Souriau, air monitoring at the workplace is performed each year in

order to control the exposure to hexavalent chromium compounds. In the following

table, the results of three different monitoring campaign performed during the years

2014 and 2015 are compared with modelling results. All these results are performed

by sampling air with a pump worn by operator except for “treatment bath, far field”

for which the pump was on a fixed support in the plating shop.

As presented in section 10.1.1.4., the more experienced workers are the most

highly exposed workers of the treatment line (compared to the less experienced).

Consequently, during a monitoring campaign, the strategy for controlling the highest

possible exposure at the workplace is to control the more experienced worker. Thus

the device for sampling (pump with filter) is worn by the more experienced worker.

During the three last campaigns the measurement were performed on automated

lines only.


according to the section 10.1.1.4. the following description of activity is given as

follow:

- Repackaging : One worker of the team dedicated to repackaging

performed one repackaging of solid

- Activities on automated line, more experienced worker 1: activity next to

the bath (for drain), manual addition of liquid, treatment bath in the

worker’s far field.

- Activities on automated line, more experienced worker 2: activity next to

the bath (for drain), manual addition of solid, treatment bath in the

worker’s far field.

Consequently, the measured and modelled exposures are presented as follow:


118

Activity Measured concentration (µg.m-

3) Modelled concentration (µg.m-3)

Measurement of the 2015 campaign

Repackaging 0,153 0,191

Activities on automated line

more experienced worker experienced worker

1 experienced worker

2

0,026

0,199 0,147 0,035

0,027

Measurement of the 2014 campaign 2

Repackaging <0,156 (QL*) 0,191




2

<0,184 (QL)

0,199 0,147 <0,152 (QL)

<0,156 (QL)

<0,159 (QL)

treatment bath, far field <0,17 (QL) 0,0053

Measurement of the 2014 campaign 1




2

<0,156 (QL)

0,199 0,147 <0,157 (QL)

<0,155 (QL) *QL = Quantification limit


As presented in this table, the measured air concentration is much lower than

the modelled exposure. The quantification limit (QL) is too high to provide an exact

level of hexavalent chromium measured before 2015, but most of these results are

still lower than the modelling results.

Consequently, the monitoring reports attest that the level of hexavalent

chromium estimated with the modelling approach on the site of Souriau is an over-

estimation. Thus, using the modelling approach tie in with a precautionary approach.

The monitoring results on the site of Souriau attest that the modelling approach is mainly

an over-estimation and tie in with a precautionary approach.


119


Air monitoring of the workplace was undertaken on the site of Connecteurs

Electriques Deutsch in 2015 in order to control exposure to hexavalent chromium

compounds. These results are compared to modelling results in the table below. Six

measurements were performed by sampling air with a pump worn by operators

(personal sample). Some measurements are performed during 480mins whereas

others are short term values.

In order to compare the modelled results with measured concentrations, according

to the section 10.1.1.5. the following description of activity is given in the table

according to the title of contributing scenarios. Consequently, the measured and

modelled exposures are as follows:

Population Measured concentration

(µg.m-3) Modelled concentration

(µg.m-3)

Main technician of the plating shop 0,02 0.06

Workers of the plating shop <0,03 (QL)

0.0053 <0,02 (QL)

Manual addition, liquid <0,73 (QL)

18.00 0,93

Manual dipping in chromium bath, near field

<0,57 (QL) 0.11

*QL = Quantification Limit (used by the laboratory that is carrying out the analysis and converted to µg/m3)



the level of exposure at Connecteurs Electriques Deutsch seems to be lower or as

low as the modelled exposures, as they are below the quantification limit.

The monitoring results on the site of Connecteurs Electriques Deutsch attest that the

modelling approach is mainly an over-estimation and tie in with a precautionary approach.


120


Monitoring results are not communicated by the site of TE Connectivity at Hasting

because the monitoring report has been judged too sensitive. This is to protect

the personal information of the employees on site.


121

10.1.3. Risk characterisation

As discussed previously in chapter 9.1.2.3, the risk characterisation will be based on

the RAC/27/2013/06 Rev.1, which establishes a reference dose response

relationship for the carcinogenicity of hexavalent chromium.

Excess of lung cancer risk: 4*10-3 per μg Cr(VI)/m3 based on a 40-year working life

(8h/day, 220 days per year).

Moreover, and since chromium exposures are due to the volatility of a liquid

mixture, we estimated the cancer risk mainly for lung cancer and maximised the

excess of cancer risk without considering the risk for small intestine cancer.

Based on all of this information, the tables below show the calculation of the excess

risk for lung cancer weighted by the working conditions on the industrial site.

Weighted excess risk of lung cancer Value

Excess risk of lung cancer. per µg/m3 of Cr(VI)

based on 40 working years. 220 days per year.

8h per day (RAC 2013) 4x10-3


based on 1 working year. 220 days per year. 8h

per day 1x10-4



8h per day 4x10-4



8h per day 7x10-4



8h per day 1.2x10-3

Table 100: Excess risk of lung cancer calculation

Considering the data presented in the above table and the exposure estimations

based on the modelling approach, the excess risks are calculated for each use in the

following tables.

In the following sections the global exposure and risks for each uses considered are

presented for each site. It has to be stressed that the average of exposure is

calculated by taking into account the respiratory protective equipment (RPE) if it is

used as indicated in the previous sections.

The raw exposure estimations considered for each contributing scenario are

summarised in the following table:


122

Contributing Scenario Raw exposure without RPE

(µg.m-3) Raw exposure with RPE

(µg.m-3)

CS-2 Sampling of bath 1,7 No RPE used

CS-3 Lab analysis 0,046 No RPE used

CS-4 Other activities next to the bath 1,7 No RPE used

CS-5 Repackaging of solid by using fume cupboard

1,1 0,11

CS-6 Repackaging of solid by using other local ventilation

6,1 0,61

CS-7 Repackaging of solid without local ventilation

140 3,5

CS-8 Repackaging of liquid 50 5

CS-9 Addition of liquid to bath 18 1,8

CS-10 Addition of solid to bath 13 1,3

CS-11 Addition of liquid in bath via pumping system

0,67 No RPE used

CS-12 Handling of articles Not for inhalation exposure

(dermal exposure only) Not for inhalation exposure

(dermal exposure only)

CS-13 Dipping connector parts in treatment bath, in the worker’s near field

0,17 No RPE used

CS-14 Dipping connector parts in rinsing baths, in the worker’s near field

0,17 No RPE used

CS-15 Treatment baths in the workers’ far field

0,0053 No RPE used

CS-16 Drying connector parts 6,7 0,67

Table 101: Summary of the raw exposures (modelled concentrations)


123


Use-1

Population Average of exposure (µg.m-3)

Lab analysts 8.29E-05

Platers 1.30E-02

Maintenance team 3.86E-03

Table 102: Average exposures at Amphenol Limited – Use-1

Population Individual excess risk of lung

cancer Total excess risk of lung cancer

Lab analysts 9.94E-08 1.99E-07

Platers 1.56E-05 1.56E-04

Maintenance team 4.64E-06 9.27E-06

Total 1.65E-04

Table 103: Excess risks at Amphenol Ltd - Use-1

Use-2


Lab analysts 5.49E-04

Platers 2.34E-02

Maintenance team 1.93E-03

Table 104: Average exposures at Amphenol Ltd – Use-2




Platers 1.64E-05 1.64E-04


Total 1.67E-04

Table 105: Excess risks at Amphenol Ltd - Use-2

Excess risks due to combined exposures




Platers 3.20E-05 3.20E-04


Total 3.33E-04

Table 106: Excess risks at Amphenol Ltd – combined exposure


124


Use-1


workers of the plating shop 9.65E-03

Technicians or enginneers 6.63E-04

Table 107: Average exposures at Amphenol Socapex – Use-1

Population Individual excess risk of lung cancer Total excess risk of lung cancer

workers of the plating shop 1.16E-05 1.16E-04

Technicians or enginneers 7.95E-07 3.18E-06

Total 1.19E-04

Table 108: Excess risks at Amphenol Socapex - Use-1

Use-2



Lab worker 2.03E-03

Technicians or enginneers 6.63E-04

Table 109: Average exposures at Amphenol Socapex – Use-2



Lab worker 1.42E-06 1.42E-06


Total 9.51E-05

Table 110: Excess risks at Amphenol Socapex - Use-2





Total 2.13E-04

Table 111: Excess risks at Amphenol Socapex - combined exposure


125


Use-1



Table 112: Average exposures at ITT Cannon – Use-1

Population Individual excess risk of lung cancer Total excess risk of

lung cancer


Table 113: Excess risks at ITT Cannon - Use-1

Use-2



Table 114: Average exposures at ITT Cannon – Use-2

Population Individual excess risk of lung cancer Total excess risk of

lung cancer


Table 115: Excess risks at ITT Cannon - Use-2


Population Individual excess risk of lung cancer Total excess risk of lung

cancer


Table 116: Excess risks at ITT Cannon - combined exposure


126

10.1.3.4. Souriau

Use-1


Worker on the treatment line, experienced 1.12E-02

Worker on the treatment line, non-experienced 5.23E-03

Worker for repackaging 2.57E-03

Internal maintenance team 8.69E-03

external maintenance team 2.41E-03

laboratory team 5.73E-04

Table 117: Average exposures at Souriau – Use-1

Population Individual excess risk of

lung cancer Total excess risk of lung

cancer

Worker on the treatment line, experienced 1.35E-05 4.04E-05

Worker on the treatment line, non-experienced 6.28E-06 1.88E-05

Worker for repackaging 3.08E-06 9.25E-06

Internal maintenance team 1.04E-05 2.09E-05

external maintenance team 2.90E-06 5.80E-06

laboratory team 6.88E-07 2.06E-06

Total 9.72E-05

Table 118: Excess risks at Souriau - Use-1

Use-2









Population Individual excess risk

of lung cancer Total excess risk of lung

cancer







Total 8.89E-05

Table 120: Excess risks at Souriau - Use-2


127

Use-3

Population Average of exposure

(µg.m-3)








Population Individual excess

risk of lung cancer Total excess risk of

lung cancer







Total 2.23E-05

Table 122: Excess risks at Souriau –Use-3


Population Individual excess

risk of lung cancer Total excess risk of

lung cancer





Table 123: Excess risks at Souriau – combined exposure


128


Use-1


main technician of the plating shop 9.04E-03

substitute technician 1.19E-03


worker for maintenance 4.83E-03

Table 124: Average exposures at Connecteurs Electriques Deutsch – Use-1

Population

Individual excess risk of lung cancer

Total excess risk of lung cancer

main technician of the plating shop 1.08E-05 1.08E-05

substitute technician 1.42E-06 1.42E-06


worker for maintenance 5.80E-06 1.16E-05

Total 1.35E-04

Table 125: Excess risks at Connecteurs Electriques Deutsch – Use-1-

Use-2


main technician of the plating shop 1.72E-02

substitute technician 2.62E-03

laboratory worker 1.51E-03


worker for maintenance 4.83E-04

Table 126: Average exposures at Connecteurs Electriques Deutsch – Use-2

Population

Individual excess risk of lung cancer

Total excess risk of lung cancer



laboratory worker 1.06E-06 1.06E-06



Total 9.25E-05

Table 127: Excess risks at Connecteurs Electriques Deutsch – Use-2


129


Population Individual excess risk of lung cancer

Total excess risk of lung

cancer





Total 2.27E-04

Table 128: Excess risks at Connecteurs Electriques Deutsch –combined exposure


130


Use-1



Table 129: Average exposures at Tyco Electronics UK Ltd – Use-1



Table 130: Excess risks at Tyco Electronics UK Ltd – Use-1

Use-2



Table 131: Average exposures at Tyco Electronics UK Ltd – Use-2



Table 132: Excess risks at Tyco Electronics UK Ltd – Use-2




Table 133: Excess risks at Tyco Electronics UK Ltd – combined exposure


131

10.1.3.7. General conclusion

The total excess risks per use are presented for each legal entity in the table below :

Site Total excess risk for

Use-1 Total excess risk for

Use-2 Total excess risk for

Use-3

Amphenol Limited 1,65E-04 1,67E-04 -

Amphenol Socapex 1,19E-04 9,51E-05 -

ITT Cannon 5,83E-05 3,40E-05 -

Souriau 9,72E-05 8,89E-05 2,23E-05

Connecteurs electriques Deutsch 1,35E-04 9,25E-05 -

Tyco Electronics UK Ltd 1,96E-04 1,14E-04 -

Table 134: Summary of total excess risks

The maximal individual excess risks considered for each use and for each legal entity

are presented in the table below:

Site Maximal individual

excess risk for Use-1 Maximal individual

excess risk for Use-2 Maximal individual

excess risk for Use-3

Amphenol Limited 1,56E-05 1,64E-05 -

Amphenol Socapex 1,16E-05 9,18E-06 -

ITT Cannon 9,72E-06 5,67E-06 -

Souriau 1,35E-05 9,28E-06 2,55E-06

Connecteurs electriques Deutsch 1,08E-05 1,20E-05 -

Tyco Electronics UK Ltd 1,78E-05 1,04E-05 -

Table 135: Summary of maximal individual excess risks

The decision point for 'acceptable' lifetime (i.e., a working life of 40 years) cancer risk

levels used for individual risk levels for workers are generally around 10-5 but higher

or lower levels have been considered to be tolerable under certain circumstances22.

All the individual excess of risk for all the workers involved in the operations using

hexavalent chromium as described in this CSR does not exceed the order of

magnitude of 10-5.

22 ECHA Guidance on information requirements and chemical safety assessment,

chapiter R8, Appendix R. 8-14 page 141.


132

10.1.4. Analysis of uncertainties and improvement of management

The exposures considered in this CSR for the Uses-1,2&3 are based on several

hypotheses. They were made in order to respect a conservative approach and

consequently, led to an overestimation of the exposure. They mainly concern the

following items:

1. Definition of the APF:

The applicant made the choice to tie in with a precautionary approach by

using an APF of 10 for all the RPE used, except for the specific case of

Amphenol Limited where an APF of 40 is used for one specific RPE. These

APF used would have been higher depending of the country considered (for

example in Germany where an APF of 30 can be used), but the applicant

made the choice to present an assessment with no potential doubt on the

RPE used.

2. Modelling approach

All measurements performed on CMG’ sites and presented in this CSR show

lower values than the modelling estimations. Consequently, modelling

estimations are considered as the maximum level of exposures at the

workplace. Even if the modelling approach is demonstrated to be an over

estimation, the applicant made the choice to use this approach in order to be

sure that the assessment is covering all the tasks involved in the use of

hexavalent chromium.

3. Inputs for modelling

The inputs used for modelling cannot be strictly representative of the

realistic use performed on site. In order to be completely transparent, for all

the contributing scenarios, the inputs used are compared to the condition of

use on all the CMG’ sites in a columns table in annex I. All the inputs have

been chosen in order not to both over-estimate the exposure estimation for

each contributing scenario and consider the worst case scenario in order to

cover all the sites. Consequently, the inputs for each contributing scenarios

are the worst inputs to be considered and thus leading to an over-

estimation.

4. Duration of tasks and frequency used

The duration and the frequencies of the tasks were considered by taking into

account the maximum possible increase of activity presented in accordance

with the tonnage estimation. It does not probably reflect the exact

frequencies and duration involved during the review period, but the

applicant made the choice to present the maximum realistic estimation in

order to cover potential future activities. Furthermore, the exposure due to

ambient air in the plating shop considered through the contributing scenario

15 (CS-15) is not split between the Uses-1, 2 & 3. Consequently, for this far

field exposure, there is a double count in the global excess risk calculation.


133

Hence, the excess risk previously presented can be considered as the

maximum consideration, taking into account all uncertainties.

Furthermore, the compliance with the operating conditions described in this

CSR will be periodically controlled and the efficiency of the risk management

measures (mainly ventilations and RPE) will be regularly verified according to a

written procedure for each site. New protective equipment are available for all

workers in order to maintain the possibility to change them easily.

All workers involved are made aware of the best practices of work to ensure

that the level of exposure is as low as possible. They are also trained adequately to

the identification of the hazardous substances and associated practices through

formal education procedure.

By now, the applicant will furthermore perform measurements adapted to the

contributing scenarios in order to confirm that the measured level of exposure will

be lower than the levels estimated in this CSR by modelling approach. Consequently,

measurement at the workplace will be regularly performed in order to verify the

main raw exposures estimated with the modelling approach.

The applicant therefore took the opportunity of this CSR to critically assess

RMMs and OCs in place. In spite of the encouraging results obtained, CMG members

will engage in the improvements described above so as to continuously reduce the

risk over the review period.

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