EC number: Chromium trioxide CAS number: 215-607-8 1333-82-0

CHEMICAL SAFETY REPORT

9.Feb.2016

Substance Name: chromium trioxide

EC Number: 215-607-8

CAS Number: 1333-82-0

Applicants's Identity: Abloy Oy

EC number: Chromium trioxide CAS number: 215-607-8 1333-82-0

Part B 9. EXPOSURE ASSESSMENT (and related risk characterisation) 9.0 Introduction This exposure assessment will be part of an application for authorisation of Chromium trioxide (CAS 1333-82- 0, EC: 215-607-8) for a specific use and therefore the assessment is focused mainly on the Annex XIV properties (Carcinogenic (category 1A) and Mutagenic (category 1B)). However, the initial assessment of environmental exposure and concequent initial assesment of man via the environment has also been carried out to figure out exposure levels for the general population.

9.0.1 Overview of uses and Exposure Scenarios

Use and tonnage information:

This exposure assessment covers use of chromium trioxide in chrome electroplating of locking devices at Abloy Oy company´s industrial site located in the town of Joensuu in Finland. The manufactured products cover wide range of padlocks, stationary locks, locking devices, keys, handles, mountings, fittings and complete door locking/opening solutions.

The manufacturing process at the Joensuu site can be divided in three main phases.

1) manufacturing of metallic parts (forge/mechanize parts and components)

2) finish the parts by plating by different means

3) assembly of the finished parts/components to final products

The surface treatment plant, at its contemporary design/form, started its operation in the year 2010. The annual use volume of chromium trioxide is 650 kg. Chromium trioxide is exclusively used at the surface treatment plant, the department carrying out the phase 2 tasks. The annual production capacity is about 7-10 million products. In general the weight of the products is relatively small ranging from less than 50 grams to a few kilograms. The surface treatment plant is 2130 m2 in area. The surface treatment plant is a part of larger (17 000 m2) industrial building.

All the chromium trioxide used in the site is purchased from the EU internal market. Assessed tonnage of chromium trioxide in total is 650 kg/year. This mass contains 338 kg chromium (VI) (52 % chromium by weight). The use of chromium trioxide is “end use” since chromium (VI) is reduced by electric current to metallic form and no Cr(VI) enters the final products.

The following table lists titles for the exposure scenario and site specific contributing environmental exposure scenario (ECS) and worker exposure scenarios (WCS) and tonnage assessed.

Table 1. Overview of the exposure scenario and contributing scenarios Identifiers ES Titles of exposure scenarios and the related contributing scenarios Tonnage *) identifiers (tonnes per year) IW-1 ES1 Use of chromium trioxide in electroplating of locksets and fittings 0.65 t/a IW WCS1 Electroplating (PROC 2, 4, 13) 0.65 t/a IW WCS2 Preparation and maintaining the electroplating baths (PROC 8a, 15) 0.65 t/a

CHEMICAL SAFETY REPORT 4 EC number: Chromium trioxide CAS number: 215-607-8 1333-82-0

Identifiers ES Titles of exposure scenarios and the related contributing scenarios Tonnage *) identifiers (tonnes per year) IW WCS3 Maintenance (PROC 8a) 0.65 t/a IW ECS1 Use of chrome (VI) in surface treatment plant (ERC5/SpERC) 0.65 t/a *) Manufacture: M-#, Formulation: F-#, Industrial end use at site: IW-#, Professional end use: PW-#, Consumer end use: C-#, Service life (by workers in industrial site): SL-IW-#, Service life (by professional workers): SL-PW-#, Service life (by consumers): SL-C-#.)

The actual electroplating process at the site is automated. Automated process line is modular and assembled from a series of open or partly covered tanks. The same processing line is used for multipurpose plating needs (chrome, nickel, zinc and copper).

9.0.2 Introduction to the assessment

9.0.2.1 Environment

Scope and type of assessment:

The site specific exposure scenario generated is intended to be a part of application for authorisation. Chromium trioxide is carcinogenic and mutagenic substance and therefore the main focus is in assessment and demonstration of safe use of the substance in relation to human health to these Annex XIV properties. Therefore the detailed assessment and quantification of ecotoxicological risks has no meaning.

This environmental assessment focuses on the potential local impact of emissions from handling and use of chromium (VI) at the site and from the waste generated. The importance of environmental assessment lies with the predicted (or measured) environmental concentrations of chromium in different environmental compartments at the local scale, since these PECs have influence on the exposure of human populations to Cr(VI) via the environment. The importance of spERC and ERC categories is low in this assessment, since measured release data is available for the Abloy site.

The release factors are derived based on site specific information available as far as possible and also taken into account the realistic worst case approach. The Abloy site was obliged to apply for environmental permission under national regulations (Ympäristölupa ISAVI/79/04.08/2010) and releases of chromium for instance to the sewer system have been monitored systemically. The predicted environmental concentrations (PECs) calculated in this assessment are local ones (as Clocal) and the assessment is based on the added risk which they may present.

Environmental exposure modelling

Even if the main focus in exposure assessment is in measured data over modelled results, certain data gaps, concentrations of chromium in relation to indirect human exposure via the environment is reasonable to fill by modelling. The predicted environmental concentrations of chromium in different environmental compartments at the local scale have been modelled using EUSES 2.1 model. Basic substance specific parameters used in the modelling are presented in Annex 1.

Comments on assessment approach:

Any chromium finally released to aquatic environment from the site within the effluents has gone through several purification treatment steps. The final recipient of the releases is a fresh water lake (lake Pyhäselkä).

The risk characterisation for the environment is made primarily for illustrative purposes and as supporting information for the analysis of alternatives part of the AfA to show that general release level and also the environmental risks regarding releases of chromium to the local environment are under control at the assessed site.

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The Predicted No Effect Concentration (PNEC) values, as presented in this chapter, are used in the environmental risk characterisation. The PNEC values are adopted from the EU risk assessment of chromates (ECB 2005).

Transformation reactions and bioaccumulation of Cr (VI/III) in the environment

Chromium (III) species dominate in nature, with high levels of chromium (VI) species generally only found as a result of man-made pollution.

For the risk assessment, a value for the BCF in fish was derived (ECB 2005). The available data indicated that the bioconcentration factor for chromium (VI) in fish is low at around 1 l/kg. Once in the organism, reduction of chromium (VI) to chromium (III) appears to occur, resulting in an accumulation of total chromium in the organisms to a factor of approximately 100 times the original concentration in water. Uptake of chromium (III) directly from water is likely to be very low due to the limited water solubility and strong adsorption to sediment under most conditions found in the environment.

Fate and existence of Cr in air

Chromium (VI) compounds are not volatile and therefore found in the atmosphere mainly associated with aerosols or particulate matter. In the atmosphere, chromium (VI) can be reduced to chromium (III) if suitable reductants are present. However, it is likely that in most situations chromium (VI) will be relatively stable under the conditions present in the atmosphere. The chromium present on particulate matter and in aerosols can be transported to land surfaces via wet and dry deposition.

9.0.2.2 Man via environment

Scope and type of assessment:

The scope of exposure assessment and type of risk characterisation required for man via the environment are described in the following table based on the reported hazard conclusions.

Table 2. Type of risk characterisation required for man via the environment Route of exposure and type of Type of risk characterisation Hazard conclusion effects Inhalation: Systemic Long Term Quantitative (cancer) 29 x 10-3 per µg Cr(VI)/m3 (70 years, 24h/day) Oral: Systemic Long Term Quantitative (cancer) 8 x 10-4 per µg Cr(VI)/kg bw/day (70 years exposure)

Comments on assessment approach:

The focus in this exposure assessment for general population is in the REACH Annex XIV properties of the substance: carcinogenicity and mutagenicity.

Typically indirect exposure of humans via the environment may occur by consumption of food (fish, crops, meat and milk) or drinking water, inhalation of air and ingestion of soil/dust.

The predicted environmental concentrations of chromium in different environmental compartments and in locally produced and consumed foodstuff and breathed air have been modelled using EUSES 2.1 model. Basic substance specific parameters used in the modelling are presented in Annex 1. The estimates of spreading and dilution of chromium in local air have been modelled by Gaussian Plume Model (GPM), a model developed for calculation of concentrations of pollutants in ground-level air.

Cancer risk- dose response for general population

For the risk characterisation a preliminary reference dose response relationship for carcinogenicity of hexavalent chromium has been given for general population and workers by ECHA/RAC.

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Lung cancer risk: For the general population the inhalative linear dose response relation of excess lifetime lung cancer mortality risk estimate is 29 x 10-3 per µg Cr(VI)/m3. This estimate is based on an exposure for 70 years, 24h/day, every day.

Intestinal cancer risk: For the general population a linear excess lifetime intestinal cancer risk = 8 x 10-4 per µg Cr(VI)/kg bw/day has been given. The estimate is based on an exposure for 70 years (24h/day, every day) and an 89-year life expectancy.

To estimate intestinal exposure from intake of inhalable, but non-respirable particles, the exposure to Cr(VI) can be converted into oral doses by applying the standard human resting breathing rate of 0.8 m3/hr and the standard average human body weight default value of 60 kg.

9.0.2.3 Workers

Scope and type of assessment:

The scope of exposure assessment and type of risk characterisation required for workers are described in the following table based on the hazard conclusions presented.

Table 3. Type of risk characterisation required for workers Route Type of effect Type of risk Hazard conclusion characterisation Systemic Long Term Quantitative (cancer) 1μg/m3 (Cr (VI)) results in 4 x 10-3 excess lung cancer lifetime risk, linear extrapolation to higher or lower concentrations Inhalation Systemic Acute Qualitative Acute Tox. 2 *) Local Long Term Qualitative Resp. Sens. 1 *) Local Acute Qualitative Corrosivity, Resp. Sens. 1) * Systemic Long Term Qualitative *) Systemic Acute Qualitative *) Dermal Local Long Term Qualitative *) Local Acute Qualitative corrosivity, Skin Corr. 1A *)

Eye Local Qualitative corrosivity *)

*) For most of the dermal and inhalation route endpoints qualitative assessment applies. The relevant critical effects are local and systemic effects, i.e. corrosivity, irritation and carcinogenicity. Chromium trioxide has the harmonized classification: Ox. Sol. 1, STOT SE 3; C ≥ 1%, Acute Tox. 2&3, Skin Corr. 1A, Skin Sens. 1, Resp. Sens. 1, Muta. 1B, Carc. 1A, Repr. 2, STOT RE 1, Aquatic Acute 1, Aquatic Chronic 1 (ref: CLP ATP 3)). Lung cancer is the most sensitive type of effects for humans and also the main driver in setting OC/RMM and the low limits of exposure. Therefore, the operational conditions, engineering controls and personal protective equipment will minimize inhalation/dermal exposure and be sufficient to protect from all other acute and/or systemic effects.

The following risk estimates are used in determining excess cancer risk levels in risk characterisation for workers based on a 40 year working life (8h/day, 5 days/week):

An excess lifetime lung cancer mortality risk = 4 x 10-3 per µg Cr(VI)/m3

An excess lifetime intestinal cancer risk = 3.3 x 10-4 per µg Cr(VI)/kg bw/day

Exposure to inhalable, non-respirable particles is first converted into oral doses by applying the standard worker breathing rate of 1.25 m3/hour, 8h per day, and the standard worker body weight default value of 70 kg. It is

2015-01-08 CSR-PI-5.5.2 CHEMICAL SAFETY REPORT 7 EC number: Chromium trioxide CAS number: 215-607-8 1333-82-0 assumed that there is 100% retention of particles that are inhaled (the gastro-intestinal absorption is not 100% and this may be reflected in the oral risk estimates).

Comments on assessment approach related to toxicological hazard:

The focus in the worker exposure assessment is in clarification of occupational exposure in relation to the carcinogenicity properties of Cr(VI) at the site.

Measured worker exposure data is available. Measured data comprises of static and personal sampler data from Cr(VI) in work place air under normal operational conditions of the site. In addition there are biological monitoring study results available (Cr(VI) in urine).

The reference occupational exposure limit and target values applied in Abloy measurements are presented in the table below.

Table 4. Finnish reference OELV and recommended target values for chromium Chromium (VI) in air Chromium (0/II/III) in Chromium in urine 8 hour mg/m3 air 8 hour mg/m3

OELV 0.05 as CrO4 0.5 0.20 μmol/l action limit (0.02 as Cr(VI)) (0.1 μmol/l until 1. Dec 2013)

1. target value <0.0005 <0.01 0.01 μmol/l (reference limit for non-exposed)

2. target value <0.001 <0.1 < 0.20 μmol/l

References: Ref:air: http://www.ttl.fi/fi/tyoturvallisuus_ja_riskien_hallinta/riskien_hallinta/ohjearvot_tavoitetasot_haittatekij%C3%B6ille/tavoite tasot/Documents/kromiVI_tavoitetasot_paiv032013.pdf Ref: Urine: Ministry of Health and Social Affairs Decree 268/2013, Finland

In parallel to limited number or lack of measured Cr(VI) in workplace air data regarding some of the contributing worker scenarios the recommended modeling tools are used to estimate worker exposure. Exposure assessment tool for metals and inorganic substances MEASE (1.0.2.01) (EBRC Consulting GmbH 2010) and Targeted risk Assessment TRA v. 3.10 (ECETOC 2014) and Advanced Reach Tool (ART 1.5, http://www.advancedreachtool.com) exposure assessment tools are used following recommendations of CSA R.14 guidance taking into account the specific needs for assessment of metals and inorganic substances.

Exposure estimates (8hr TWA) for three contributing worker scenarios applying variable working time, PPE/RPE and substance combinations are given in the Annex 2 of this report "Exposure estimates for surface treatment plant workers based on exposure models".

Solid CrO3 is coarse flakes and generally it is regarded as a low dustiness substance. Description for low dustiness means here that flakes may fall apart and crumble, resulting in only a very limited amount of fine particles. Handling the product does not result in a visible dust cloud, inhalable fraction: 101 - 500 mg/kg (ref: description for low dustiness from the ART 1.5 model).

Comments on assessment approach related to physicochemical hazard:

Chromium trioxide is hazardous chemical and physical chemical hazard properties meet the criteria to be classified as “oxidative solids” (Oxid. Solid 1). It is not classified related to its Explosive or Flammable properties. Chromium trioxide itself is not flammable and it cannot be ignited by a flame. However, chromium trioxide may intensify fire in contact with burning materials.

The reactivity of diluted chromic acid under controlled conditions in the actual electroplating use does not pose any specific physicochemical hazards that should be considered separately in the exposure scenario. The

2015-01-08 CSR-PI-5.5.2 CHEMICAL SAFETY REPORT 8 EC number: Chromium trioxide CAS number: 215-607-8 1333-82-0 oxidative hazard is not relevant for the reduced Cr(III) reaction product.

General information on risk management related to toxicological hazard:

For substances categorised as having a high hazard profile (i.e. category 1A and 1B carcinogens), a very high level of containment and appropriate PPE together with effective ventilation (LEVs) are recommended in occupational settings in order to avoid exposure. Therefore, in this ES the use of sufficient and relevant protective PPEs are regarded as default in tasks where the substance is handled manually or the potential for exposure is high.

When contact is possible with the solid CrO3 and concentrated solutions, Local Exhaust Ventilation should be standardly present (efficiency 90-95%, based on ECETOC 2009) and Respiratory Protective Equipment (RPE, efficiency ≥90%) should be used. The pattern of use for this substance is non-dispersive, only certain groups of trained workers are handling the material direct and contact level would be incidental or none. For most workers the use is non-direct and the contact level with diluted process solutions or products is at most intermittent and usually would be incidental or none. Properly designed gloves should be used to minimize the dermal exposure as the substance is sensitising and may be corrosive (depending on conditions).

General information on risk management related to physicochemical hazard:

Pure chromium trioxide is stored in its original package, galvanized steel drums (typically 50 kg CrO3 in each drum in a form of dark red flakes ca. 0.5-1.5 cm diameter), in separate locked chemical storage area of the process hall.

Chromium trioxide is classified for oxidising properties. Chromates may undergo vigorous redox reactions from its +VI oxidation state to the +III state. Vigorous oxidative reactions may take place if the substance is mixed with incompatible materials. Health hazards may be involved in use/storage of chromium trioxide with incompatible substances. Separate storage areas/sections are reserved for incompatible substances. The maximum amount of chromium trioxide stored at a time on site is 200 kg.

Abloy Joensuu plant has drawn up and supplied to the competent authorities a document in writing setting out the major-accident prevention policy (MAPP) in compliance with legislation on chemical accidents (e.g. the Seveso directive) for critical situations with hazardous substances (eg. chromium trioxide/chromic acid solutions in leaks, spillages, fire, explosion, etc). The latest update of the Abloy MAPP document is dated 27.2.2013.

9.0.2.4 Consumers

Scope and type of assessment:

The substance is entirely used in this industrial installation in strictly controlled conditions. Consumer exposure is ruled out, since Cr(VI) does not end up in any products of the factory. Therefore exposure assessment and risk characterization is not required here.

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9.1 Exposure scenario 1: Use of chromium trioxide in electroplating of locksets and fittings Description of the activities and technical processes covered in the exposure scenario:

Market sector: SU 3 Industrial uses: Uses of substances as such or in preparations at industrial sites

Sector of use: SU 15 Manufacture of fabricated metal products

Article categories: PC14 Metal surface treatment products, including galvanic and electroplating products

Environment contributing scenario(s):

ECS1 Use of chromium (VI) in surface treatment plant ERC 5

Worker contributing scenario(s):

WCS1 Electroplating PROC 2, 4, 13

WCS2 Preparation and maintaining the electroplating baths PROC 8a, 15

WCS3 Maintenance PROC 8a

Subsequent service life exposure scenario(s): 0

Exposure scenario(s) of the uses leading to the inclusion of the substance into the article(s): 0

Explanation on the approach taken for the ES:

This assessment is site specific and there is detailed information available on the processes and measured worker exposure as well as data on actual environmental releases from the site. The exposure scenario is divided into three worker contributing scenarios (WCS1,2,3) and one environmental scenario (ECS1). The contributing environmental scenario is presented first, since under the environmental exposure assessment a great deal of general site specific technical information, relevant also for worker exposure control, is described together with general information on the on-site risk management measures and operational conditions.

There are 24 permanent workers at the surface treatment plant working in 1-3 shifts. The surface treatment processes are operational ca. 260 days per year. The plant started its operation at the end of the year 2010.

Table 5.General work tasks and related expected exposure potential to Cr(VI) at the surface treatment plant is listed below Task Short description of tasks related to CrO3 use Process Exposure category potential to Cr(VI)

1 Transportation: Chromium trioxide is transported in sealed drums PROC 1 No exposure (ADR transportation). expected

2 Storage of substance: Chromium trioxide is stored in sealed drums PROC 1 No exposure inside a chemical storehouse. expected Unloading/Mixing of substance with other materials; preparation of 3 PROC 8a High - WCS2 chromic acid solutions, maintaining the baths, including cleaning of the working area 4 Sampling & analysing Cr(VI) concentration of the plating bath PROC 15 Medium – WCS2 Manual loading of items to hangers, Cr(VI) is not directly involved 5 PROC 2 Low - WCS1 in the task

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Automatic electroplating process: Pre-treatments, electroplating, 6 PROC 2, Low - WCS1 reduction of dragout Cr(VI) to Cr(III) and multi stage hot/cold 4, rinsing and drying, all phases remote controlled/automated, manual intervention by the process operators is possible if necessary Manual unloading items from hangers, post-treatments (packaging, 7 PROC 13 Low - WCS1 transfer, storage), after reduction and rinsing, Cr(VI) is not directly involved in any of the tasks Maintenance and cleaning, Maintenance/servicing work of 8 PROC8a Medium – High equipment: daily, weekly, monthly and annual maintenance of WCS3 gauges, electrodes, pumps, filters, cooling, ventilation and emission control equipment 9 Cleaning of tanks, removal and disposal of aggregated precipitates PROC 8a High – WCS3

10 Cleaning of site: Cleaning of process hall and the general waste PROC 8a Medium-High -> management WCS3

Table 6. Average number of workers per task and estimated time per tasks at Abloy Joensuu surface treatment plant Abloy Joensuu surface shift/hours/days Number of Number of Number of Number of treatment plant (5/7 days per year (a person - person - person - employees of a week and time of the person) Office hours Non-office Night time day) hours

Process operators 3/8/220 2 6 1 8

Loading/unloading 3/8/220 7 1 3-4 13 hangers

Laboratory workers 1/8/220 2 2 0 3

Cleaning 1/0.5/130 1 0 0 1*)

Maintenance workers 1/2/ 26 0 2 0 6*) (daily tasks, repairs when needed) (own staff and outsourced occasionally)

Maintenance workers 1/8/14 0 8 0 6 (outsourced) (Maintenance 2 times/year) (outsourced personnel) *) work includes also tasks in other departments of Abloy (other than the tasks at the surface treatment plant)

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9.1.1 Environmental contributing scenario 1: Use of chromium (VI) in surface treatment plant

This contributing environmental scenario covers all the uses and releases of chromium to the environment from the Abloy Oy Joensuu plant. The basic environmental release category is ERC 5: Industrial use resulting in inclusion into or onto a matrix. This ERC is regarded suitable for electroplating process since the description of this release category fits well with the activity: “Industrial use of substances as such or in preparations (non- processing aids), which will be physically or chemically bound into or onto a matrix (material) such as ...metals in coatings applied through plating and galvanizing processes“.

9.1.1.1 Conditions of use Product (article) characteristics

. Solid CrO3 and its water solutions (up to 25 % wt) Amount used, frequency and duration of use (or from service life)

. 650 kg/year CrO3 per site, use is continuous daily use, < 4 hr up to 8 hr/shift, 1-3 shifts/day Technical and organisational conditions and measures

. Storage of solid pure CrO3, the maximum amount in storage is 200 kg in small (50 kg) steel barrels . The total amount of Cr(VI) in the process bath at a time is ca. 750 kg . Automatic, computer steered/remotely controlled production line . The number of electroplating tank is one (1) (size (WxLxH) 1.2 m x 2.15 m x 1.2 m, volume 2500 litre) . Electroplating the items in chromic acid baths at elevated temperature (30 to 50 °C) . Unnecessary mist generation in the chrome bath is controlled by effective process control (voltage/current optimisation) and by mist suppressants (lowered surface tension & foam blanket) . Exhaust gas management system with integrated LEVs and wet scrubber . Multi stage automatic rinsing the items with water in the next tanks in the automatic production line . Collection of water from cleaning of equipment and maintaining/maintenance of the bath and other equipments (e.g. pumps, heat exchangers of the cooling systems, ventilation (LEV’s, filters and droplet separators)) Conditions and measures related to sewage treatment plant . Waste water of the electroplating processes is distributed to the on-site batch type physic-chemical waste water treatment plant . Efficiency of metals precipitation is monitored with chemical analysis so the 0.1 mg/l Cr(VI) and 0.5 mg/l Crtotal permission limits are met . After sufficient purification the waste waters are led to municipal sewer system, discharge rate of local STP is 25 000 m3/d Conditions and measures related to treatment of waste (including article waste) . Process waste is comprised of used electroplating bath and sludge from the tank and treated as hazardous waste after pre-treatment on site, packaged, sealed, labelled accordingly and distributed to authorised waste management company following local & EU regulations . Other waste: cleaned packages, cleaning & grinding waste, filters etc. is treated following local regulations

Other conditions affecting environmental exposure . The electroplating bath has specific LEV system to keep Cr(VI) containing gases/mists controlled . Exhaust air/mist from the LEVs is purified by droplet separators and a central scrubber (efficiency > 99%) prior to blowing into open air . The site follows site-specific environmental permit conditions . In the case of tank break, no chemicals are spilled to external sewer system or to the environment Additional good practice advice. Obligations according to Article 37(4) of REACH do not apply . Training of the operators and other employees on how to safely work with the substance, handle waste materials and how to use the emission control equipment to minimise releases and the amount of waste

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9.1.1.2 Releases

Surface water

The treatment rate of water in the surface treatment plant is ca. 4 m3/hour. Waste waters are treated on site in a compact waste water treatment plant (WWTP) that consist of a set of pools and batch process reactors. The waste water treatment capacity of the WWTP is 6 m3/h. There are no direct releases of process waters or chromium (VI) to surface water directly or to municipal sewer system without first treating the waste water in the on-site WWTP.

Waste waters are first fractioned to different storage pools/tanks (n=5, V=3-23 m3) based on their origin and source and expected quality. Flush/rinsing waters are treated with ion exchangers and returned back to process or led to the actual waste water treatment. The actual treatment specifically for Cr(VI) solutions includes reduction with sodium hydrogen sulphite, pH adjustment and chromium hydroxide precipitation. The metal precipitates are filtered and dried. The precipitates are distributed to authorized waste management company for further treatment and reuse as raw material for metals industry.

All the clarified effluents of the surface treatment plant are analysed for metals at the laboratory of the site. If the metal content is sufficiently low, water is led further to sand filtration, pH regulation, belt filtration and finally to ion exchange treatment before distribution to the municipal sewage system and sewage treatment plant (STP). The waste water treatment capacity of the municipal STP is 25 000 m3/d. A monthly summary of concentration of Cr(VI/III) in waste water led to sewer system from the years 2011-2015 is presented in the table below. For the years 2013 and 2014 total annual release to municipal sewer system is given on the last row.

Table 7. Concentration and release of chromium from Abloy Oy Joensuu to municipal sewer Year, concentration of chromium in waste water [mg/l] (monthly flow [m3]) 2011 2012 2013 2014 2015 January 0,06 0.01 0.07 (315) 0.01 (426) 0.03 (412) February 0,13 0.11 0.04 (322) 0.03 (380) 0.04 (436) March 0,12 0.08 0.11 (200) 0.02 (287) 0.03 (431) April 0,21 0.11 0.05 (298) 0.09 (351) May 0,65 0.01 0.01 (289) 0.01 (351) Juni 8,37 0.00 0.02 (509) 0.02 (408) July 3,86 0.05 0.05 (238) 0.04 (302) August 0,08 0.21 (308) 0.03 (307) 0.03 (416) September 0,09 0.08 (320) 0.01 (461) 0.04 (378) October 0,06 0.07 (298) 0.01 (335) 0.03 (354) November 0,10 0.05 (325) 0.05 (333) 0.03 (304) December 0,42 0.06 (303) 0.05 (608) 0.04 (301) release Cr nd. nd. 161 g/a 136 g/a nd. [g/year]

Waste waters are released to sewer/to municipal STP following local site specific environmental permissions.

A release factor to surface water can be calculated by using site specific information. By applying the higher release from the year 2013 (161 g/a) in combination to the CrO3 use volumes 650 kg/a (i.e. 338 kg Cr(VI)) gives a chromium release factor of 4.76 * 10-4 to sewer system (0.048%).

The average concentration of dissolved chromium in the waste water leaving the Abloy site in the year 2013 is consequently 38 µg/l (161g/4215 m3). The daily waste water flow at the municipal STP is 25 000 m3 per day (Kuhasalo STP) and therefore the daily dilution factor of Abloy Oy (7-20 m3/day) waste waters is about 1.2-3.6 *103. For the modelling purposes a dilution factor of 1* 103 for the STP and a further dilution factor of 10 for the lake recipient have been used. The estimated surface water PECadd for chromium is at 1-3 ng level.

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Air

Emission of chromium as a gas is not likely as chromic acid has a high melting point, is not volatile and dustiness is low. Abloy Oy Joensuu plant has effective exhaust air ventilation and purification system. Handling of dry CrO3 is one, although minimal, source of chromium (VI) to the local air from the surface treatment plant. Despite of effective emission control measures, generation of mists in the electroplating bath is expected to be the major emission source of chromium (VI) to local air.

General ventilation

The surface treatment plant has a ventilation and gas purification system of its own. The surface treatment plant is kept under pressurised in comparison to other parts of the building. Overall maximum air intake flow rate of the general ventilation of the factory is 75 000 m3/h and the exhaust air ventilation rate capacity is 85 000 m3/h.

The designed air exchange rate of the surface treatment plant hall is 4 times per hour at minimum. Surface treatment plant includes also the chemical storehouse and waste water treatment plant. Air exchange rate of the chemical storehouse is 5 times per hour at minimum. The tanks of the waste water treatment plant are equipped with LEVs.

The maximum flow rate of chromium containing gases through the general ventilation of the surface treatment electroplating line is 8500 m3/h (combined flow rates, all local LEVs included). The capacity of the scrubber to handle these ventilation gases is 11 000 m3/h.

Waste gas washer system

Exhaust air plant consists of the lines “Chrome”, “Alkaline” and “Acid” with heat recovery and the associated supply air (fresh air) plant. The complete plant consists of three exhaust air plants with their associated hot water heated supply air (fresh air). The control system for the complete plant is located centrally in a control cabinet inside the technical centre.

Exhaust air plant 1, “chrome”, is an exhaust air plant for the chrome electro-plating line with an exhaust air ventilator and exhaust air washer (scrubber type MAN-12-PVC). The washer is fitted upstream of the ventilator with an integral fresh wash water reservoir to clean the exhaust air. Circulation pumps pass the exhaust air through the nozzle system using the same direction flow and countercurrent flow principle.

The water lost through evaporation is automatically replaced by fresh water and the washer remains fully functional during the water exchange. Level switches are installed in the washer reservoirs to allow controlling of the filling process, refilling as well as the disposal process. The pH value of the wash water is measured automatically. Lye is added to the wash water so that a preset pH value is maintained.

The washing fluid circulating in the pumps is constantly monitored during operation with the aid of underload monitors so that both increasing blocking of the spray nozzles and dry running of the pumps are recognised and reported automatically.

Emission control of the chrome baths

At the site under evaluation there are permanent technical means for control of exposure from the chrome electroplating bath. First, there is only one electroplating bath in the electroplating line. Secondly, the surface area of electroplating bath liquid in contact with open air is controlled by physical means and by applying surface active chemicals (mist supressants). The physical means include relatively small surface area of the liquid in contact with open air (2.6 m2). The dimensions of the tank are 1.2 m x 2.15 m x 1.2 m (WxLxH) and volume 2500 liter.

Local exhaust ventilation is used in connection to the hard chrome electroplating bath. The tank is equipped with a long row of suction nozzles (LEVs) on the top of both long sides of the tank (see pictures in Annex 6).

Drag chain conveyors move the hangers through the automatic surface treatment production line. Electric lift arms (pulleys) move the hangers by lowering/lifting the lock parts from bath to another. The lift arms are also equipped with integral LEVs to remove gases and mists emitted from the treated parts.

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Mist and fume suppressants

Chemical means in controlling exposure include surface active chemicals. A wetting agent is a chemically stable (anionic) surfactant that acts as chemical fume suppressant that reduces the surface tension of the plating bath liquid. When wetting agents lower the surface tension of a plating bath, less mist is formed and emissions are reduced. During electrolysis of the chromium plating solution a foam blanket is formed on the surface of the solution, which coupled with the drop in surface tension, cuts direct contact of the chrome bath surface with open air and minimizes the escape of chromic acid mists and sprays into the plating bath atmosphere. Currently the supressant in use at Abloy is ANTISPRAY S (www.coventya.com).

Operational conditions in rinsing

Methods for rinsing plated items at Abloy includes automated remote operated traverse/tackle systems that lift the plated items from plating bath to a series of rinsing baths. A multi step rinsing (4-8 rinsing baths in total) ensures complete flushing of concentrated and viscous chromic acid solution out of the plated items with pure water.Therefore, there is no need for manual rinsing.

After rinsing baths the plated items are transferred to a sodiumhydrogen sulfite bath. In this bath any Cr(VI) left in the plated items is reduced to Cr(III) form.

Releases of Cr(VI) to air

Emissions of Cr(VI) to local air from the surface treatment plant of Abloy Joensuu has been measured twice (years 2011 and 2015). The total release of chromium has been measured from the exhaust manifold after the scrubber under normal operational and production conditions of the surface treatment plant (sampling periods 3.5 hour in 26.10.2011 and 3 hour in 30.7.2015). (The production rate in the Cr electroplating line during the sampling period in 2011 was 27 units. The annual production in yr. 2011 was 19957 units.)

The sampling was carried out by sampling particles from the exhaust manifold via a sond by suction pump onto a filter. The gaseous phase of the exhaust air was not sampled, since the temperature of the gases was low. It was assumed that in practice almost all metals are bound into particles at room temperature. The laboratory carrying out the measurements has an accreditation for measurement of flow rates (SFS 3866 standard, within 5 – 30 m/s) and particles (SFS EN 13284-1 standard, within 0.1 mg/Nm3 – 5 g/Nm3 (particle concentration uncertainty ± 10 %, particle emission uncertainty ± 20 %)) in ventilation manifolds/exhaust channels.

Cr analysis and the annual release

The analysing of total chromium and other metals from the sampled particles was made by ICP-MS and ICP- 3 OES methods after HNO3 extraction (SFS-EN 17025). The concentration Crtot in the manifold was 1.9 ug/Nm (2011) and 5.9 ± 1.5 μg/m3 (2015) and the calculated hourly Cr release to air 10 mg/h (2011) and 29 mg/h (2015). Taking into account the annual working hours (6000 h) the estimated release is:

release of Crtot to local air 30-174 g/year (± 25%)

By applying the annual CrO3 use volume 650 kg the release factor to air for annual 338 kg Cr(VI) use (52 % -5 -4 Cr(VI) in CrO3) is 0.009 % - 0.05% (9*10 -5*10 ). Soil

Normal operation of the surface treatment plant of Abloy Joensuu does not have any direct releases to soil or ground water.

Releases to waste

According to SpERC 5.1.v2.1 (Industrial use of metals and metal compounds in metallic coating) the initial default release factor of metals to waste is 1 %.

Based on site specific data, a fraction of initially applied amount of Cr is sent to external waste treatment. This

2015-01-08 CSR-PI-5.5.2 CHEMICAL SAFETY REPORT 15 EC number: Chromium trioxide CAS number: 215-607-8 1333-82-0 is the sum of direct losses from processes to waste and the sludge and residues from onsite process water and waste gas treatment. The minimisation of waste is dealt with by drag-out control and resource effective solution maintenance techniques. The main waste streams are sludges from rinse water treatment and wastes from periodical process maintenance (sludges and used solutions that are not recoverable back to process).

The waste waters containing chromic acid are collected into the waste tanks of on-site WWTP. To minimize the amount of waste water delivered to WWTP, various methods are used to circulate the solutions back to process. Concentrated solutions are time to time delivered to authorised hazardous waste management company.

Process waste

Precipitates are slowly generated on the bottom of process and rinsing water tanks and are time to time (normally 1 times/year) separated and treated as hazardous waste.

A fraction of the Cr(VI/III) solid sludge will be retained at the bottom of electroplating tank. The sludge is removed periodically (1-2 times/year). The sludge is regarded as hazardous process waste and treated accordingly.

Release factor to waste from the process: A very coarse estimate can be made that 10-15 % of used chromium (VI) is wasted and enters to the bottom precipitates of electroplating tanks (in Cr VI/III forms) or enters as precipitates in the WWTP waste water tanks of the site.

Secondary waste

Secondary waste means here other than process waste. The amount of Cr(VI) contaminated secondary waste is very low.

These include contaminated cleaning materials, used wipes and gloves, RPE filters. Secondary waste is disposed off following local regulations and sent to external hazardous waste treatment.

Emptied CrO3 containers (50 kg steel barrels) are washed by the process operators after emptying. Washed and dried barrels are treated as recyclable metal waste and delivered to metals recovery company (Stena) following local regulations.

Release factor to secondary waste: A coarse estimate can be made that annually less than 1 kg of CrO3 enters to secondary waste at the Abloy surface treatment plant. This means that emission factor for Cr(VI) would be < 0.003 (< 0.3 % wt.) by applying the known consumption volumes 650 kg/a CrO3 (52 % chromium (VI) by weight in CrO3).

Table 8. Local releases to the environment Release Release factor estimation Explanation / Justification method Water Final release factor: 0.05 % (to municipal sewer of Cr(VI) use) Final: Site specific data Local release rates: 0.163 kg/a (year 2012) Explanation / Justification: Final factors: measured data Air Final release factor: 0.009 - 0.05 % (release after RMM) Final: Site specific data Local release rate: 0.030 – 0.174 kg/a (Crtot) Explanation / Justification: Final factors: measured data Soil Initial: SpERC Final release factor: 0 % Final: Site specific data Explanation / Justification: According to the industry sector specific SpERC, release factor to soil is not applicable to local scale. Site specific information: no known direct releases of Cr(VI) to soil.

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9.1.1.3 Exposure and risks for the environment and man via the environment

Exposure and risks for the environment and man via the environment has been evaluated based on the measured data applying Euses model. Results of the initial Tier 0 calculation and further iterated Tier 1 with justifications are reported in Annex 5. Summary of the results is given in table below.

Table 9. Modelled exposure concentrations and local risks for man via the environment Man via Environment – Route Exposure concentration of Cr (VI) Risk characterisation of exposure Inhalation Air - Annual average local PEC 0.13 *10-3 µg/m-3, 100 m from the point 3.8 * 10-6 lung cancer risk Crtot in air source, modelled EUSES (worst case estimation) Air- Annual average local PEC 0.0065*10-3 µg/m-3, 1000 m from point 1.9 * 10-7 lung cancer risk Crtot in air source Man via Environment – 6.5 * 10-4 µg/kg/d 5.2 * 10-7 (excess intestinal Oral exposure cancer risk)

Lung cancer risk: For the general population inhalative linear dose response relation of excess lifetime lung cancer mortality risk estimate 29 x 10-3 per µg Cr(VI)/m3. This estimate is based on an exposure for 70 years, 24h/day, every day.

Intestinal cancer risk: For the general population linear excess lifetime intestinal cancer risk = 8 x 10-4 per µg Cr(VI)/kg bw/day. The estimate is based on an exposure for 70 years (24h/day, every day) and an 89-year life expectancy.

In the calculation of man via environment concentrations of Cr(VI) in food and drinking water has been evaluated and since the releases and consequent concentrations of Cr(VI) in local food is very low. In addition the default food basket of the model was adjusted to better suit with existing information on known fate of Cr(VI) in the environment.

Concentration of Cr(VI) in air and exposure through inhalation route is also taken into account as a relevant exposure route for general population. The annual 174 g release of Crtot emission to local air leads to a calculated excess lung cancer risk level 3.8 * 10-6 (Annex 5).

The nearest residential buildings are located > 1 km distance from the site (Mutala (1,2 km-SE), Kanervala (1,3 km-SW)). Therefore the actual annual average local PEC in air at the100 m from point source could be divided at least by a factor 20 (ref: GPM model) to get the concentration at the distance 1000 m from the point source. This iteration route is regarded relevant and applied here, even if the estimated concentration of Crtot in local air close to the point source is already at a very low level (< 0.2 ng/m3).

In summary the estimated lung and intestinal cancer risks for the general population are:

Lung cancer risk via inhalation route: 1.9 * 10-7

Intestinal cancer risk via oral route: 5.2 * 10-7

Remarks on man via the environment from local contribution

For comparison to the measured and calculated on-site concentrations, general background levels of chromium can be given. Generally, worldwide chromium (total) concentrations in air are in the range 10-50 ng/m3 in urban areas, with lower levels (annual means <10 ng/m3) found in rural areas. Most of the chromium in air is associated with the particle phase (Bencko, 1985) (Merian et al. 2004). The calculated site specific (CrO3 use at Abloy) concentrations in local air are clearly below the reported natural/ambient background values.

Regarding total chromium concentrations in (fresh) surface waters in the Nordic countries, a very comprehensive study was performed in 1995, in Norway, Sweden and Finland with regard to heavy metal concentrations in lakes. Nearly 3,000 lakes were sampled. The study found a median Cr concentration of 0.07 μg/l in Norway, 0.13 μg/l in Sweden and 0.29 μg/l in Finland (Skjelkvåle et al., 1999). The calculated site specific (CrO3 use at Abloy) concentrations in local surface water are clearly below the reported natural/ambient

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Conclusion on risk characterisation

The calculated local concentrations of Cr(VI) arising from the use of CrO3 at Abloy Joensuu site under evaluation are low. The assessment and conclusions are based mainly on measured and reliable release data. Excess lung and intestinal cancer mortality risk estimate is at the level of 2-5 *10-7.

9.1.2 Worker contributing scenario WCS 1, Electroplating

This contributing worker scenario covers all normal and continuous operation at the surface treatment plant related to the actual chrome electroplating (PROC4, PROC13). This scenario does not cover maintenance of electroplating baths and maintenance of equipment. These operations are covered by the WCS 2 and WCS 3.

The site under evaluation has a high level of containment of worker exposure and general operational conditions in relation to operation of the automatic surface treatment line. Low level of worker (and environmental) exposure to chromium at the site is visible from all measured worker exposure data.

Transferring items to be plated from bath to another needs no manual operations (some of these general operational conditions and exposure controls have already been described earlier under the ECS1). Chrome electroplating takes place in one tank only and worker exposure to gases and mists is controlled by effective general ventilation and LEVs installed on sides of the electroplating tank (picture 7, Annex 6). In the conveyor lift system there are plastic walls around the hangers and LEV for controlling gases (in upright part of picture 6). Electricity is automatically turned off from the cathode/anode system of the chrome bath except when hanger is in the bath. The true running time of the chrome bath (i.e. the electric current is on) is about 4 hours per shift.

These operational conditions help to prevent any dispersion of gases and mists to the workplace air and lead the chromium containing gases in a controlled way to the waste gas scrubber. The distance of working area where hangers and plating drums are manually filled/emptied (picture 3, i.e. the closest stationary working area) to the chromium bath is more than 10 meters.

9.1.2.1 Conditions of use Method Product (article) characteristics . Chromic acid in aquatic electroplating baths (300 g/l chromium) General . Electroplating process temperature 30-50 °C info . The electroplating liquids are highly acidic (pH ca. 1) Amount used (or contained in articles), frequency and duration of use/exposure

. At maximum 0.65 ton/a CrO3 (max 0.34 ton/a as Cr(VI)) is used, full shift exposure (use 1-3 shift Site- per day), 300 days/year spec . Cr(VI) is reduced to metallic chromium in the process to form a thin layer on articles Technical and organisational conditions and measures . The only manual phases of electroplating are loading/unloading of hangers or plating drums by General items to be plated (lock parts). Loading/unloading area is located outside the process area info & . Automatic programmed and remotely operated pretreatment steps: cleaning of items to be plated site to remove surface impurities specific . Automatic flushing in degreasing baths (hot treatment, anodic & cathodic treatments, activation info baths, nickel plating) . Automatic placement into the chrome plating bath (300 g/l Cr) and automatic application of plating current for the required time (few minutes) to attain the desired Cr layer . Automatic four stage rinsing with water in separate (4) rinsing tanks . Automatic reduction of rest Cr(VI) to Cr(III) in sodium sulphide bath

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Method . Automatic five stage rinsing in separate (3) ordinary rinsing tanks and in (2) hot rinsing tanks followed by drying in air . Post treatments: manual removal of items from hangers, checking/packaging Conditions and measures related to personal protection, hygiene and health evaluation . Evolution of hydrogen and oxygen gas and toxic mist of water and hexavalent chromium from Site- chrome plating bath is controlled by effective LEVs in baths and in conveyor lift spec . Surface active antispray chemicals are used to limit mist generation in the electroplating bath . Design of general ventilation and LEV prevents the flow of air towards the workers . Design of the production line keeps the distance of process tanks to workers long . Process operators (1 person/shift): Wear a protective suit (washable or disposable overalls), safety boots, chemical goggles, chemically resistant gloves (Nitrile rubber, chloroprene rubber, butyl rubber or other suitable gloves, complying with the requirements of EN 374 (breakthrough time: 480 min)) . Process operators: RPE is not needed in normal working conditions . Other workers at surface treatment plant (5-7 person/shift), persons - at the processing area: chemical goggles and gloves, protective clothing - non processing area: gloves for unloading/loading work, no other PPEs required Other conditions affecting workers exposure . Avoid any direct contact with the electroplating bath solution Site- . Avoid any direct contact with rinsing waters spec . Avoid any unnecessary exposure to mists/gases by not staying long periods close to active baths . Training: employees are trained how to safely work at the surface treatment plant incl. how to use the necessary personal protection equipment Additional good practice advice. Obligations according to Article 37(4) of REACH do not apply . Work under a high standard of personal hygiene. Wash hands and face before breaks. When using the product, do not eat, drink or smoke.

9.1.2.2 Exposure and risks for workers

General operational conditions affecting worker exposure to Cr(VI) at the site

At the site under evaluation there are permanent technical means for exposure control. The surface treatment process line is situated aside from the personal working areas and not on the floor level. During orinary work shift the area where chrome tank is located is intented to be accessible by the process operators only. Chemical storage area is completely separated from the normal working area. Local exhaust ventilation is assembled to all critical points where exposure to Cr(VI) or other toxicants might arise.

The open surface area of the chrome plating tank is small in comparison to the volume of the tank. The open surface area of the electroplating bath to open air is limited (2.6 m2) and fugitive emissions are controlled by physical means (LEVs) and by applying surface active chemicals. The mechanical walls/covers of the conveyor lift reduces fugitive emissions when the electroplating tank is under operation (electric current is on).

Mist and fume suppressants

Chemical means in controlling exposure include surface active chemicals. A wetting agent is a chemically stable (anionic) surfactant that acts as chemical fume suppressant that reduces the surface tension of the plating bath liquid. When wetting agents lower the surface tension of a plating bath, less mist is formed and emissions are reduced. During electrolysis of the chromium plating solutions a foam blanket is formed on the surface of the solution, which coupled with the drop in surface tension, cuts direct contact of the chrome bath surface with open air and minimizes the escape of chromic acid mist into the plating bath atmosphere.

Operational conditions and risk management measures in rinsing and chrome reduction stages

Rinsing is carried out by using remote operated traverse/tackle systems to lift the plated item from plating bath to several rinsing baths (8-10 rinsing baths). One of the last rinsing baths is aqueous sodiumhydrogen sulfite bath where any Cr(VI) left in the plated items is reduced to Cr(III) form.

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Methods for the multi stage rinsing of the plated items is fully automatic and therefore this phase has no influence on worker exposure regarding this contributing worker scenario.

Measurements

Concentration of Cr(VI) in process hall air have been measured during normal operational conditions of chrome electroplating for the site.

The main focus in systematic occupational Cr(VI) exposure measurements in the site has been in biomonitoring studies. Therefore results for biomonitoring are available. In these studies Cr(VI) in urine has been sampled and analysed following guidance given by national occupational safety organization (FIOH (2014a, 2014b)) (for details see Annex 3, Results of biomonitoring and method for specimen collection). Modeled exposure estimates are used to support the measured values and later on the conclusions that risks are controlled to a level of low concern.

Chromium in air measurements

Static sampling

Chromium in workplace air measurements using stationary sampling method has been carried out in five locations of the surface treatment plant of Abloy Oy. The most recent measurements (n=10) of total Cr and Cr(VI) in electroplating hall by the stationary hanger filling area (outside the process area) and also close to the chromium plating bath (process area) have been carried out (31.10.2013 and 08.10.2015) under the normal production and ventilation conditions. The number of measurements is limited since biological monitoring has been regarded as more advanced and the preferred method in occupational exposure measurements for Cr(VI) and more suitable method than concentration in air measurement.

Details of the sampling and analyzing methods and results of Cr(VI) in workplace air have been given in Annex 4. (Measured concentrations of Cr(VI) in work place air). As a summary the highest measured value (2013 and 2015) for the site is:

Cr (VI) in air 0.0001 mg/m³ (static samplers (n=10)).

The measured concentration is low. It has also to be pointed out that the highest measured value 0.1 µg/m3 was measured in the plating line, close to the chrome plating bath (2013) and at the waste water treatment plant area (2015). Process operators are the only persons who might be working in these areas during work shifts and normally operators stay there only a short period of time.

Methods used in the measurements: Sampler: celluloseacetate filter (IOM sampler), modified NIOSH 7013- 7901/TYOS-TY-707, ICP-MS analysis (accredited sampling and analysis methods).

Table 10. Results of chromium (VI) concentration in workplace air, static sampling sampling location/task sapling time result result point (minutes) Cr(VI) Cr(II/III) mg/m3 mg/m3 static 1. loading plating drums 9.10-12.05 (175) < 0.0001 < 0.0001 static 2. filling/emptying hangers 9.05-12.55 (230) < 0.0001 0.0001 static 3. maintenance/service passageway 9.13-13.05 (232) < 0.0001 < 0.0001 static 4. plating line, close to the chrome plating tank 9.15-13.13 (238) 0.0001 0.0002 static 5. filling/emptying hangers 9.30-14.23 (297) < 0.0001 < 0.0001 static 6. emptying plating drums 9.32-14.23 (291) < 0.0001 < 0.0001 static 7. maintenance/service passageway 9.36-14.33 (297) < 0.0001 < 0.0001 static 8. plating line, close to the chrome plating tank 10.02-14.42 (280) < 0.0001 < 0.0001 static 9. waste water treatment plant 9.38-14.25 (287) 0.0001 0.0002 static 10. plating line 9.43-14.37 (294) < 0.0001 < 0.0001

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Personal sampling

Personal sampler data (4) from breathing zone for electroplating workers/operators at surface treatment plant of Abloy Joensuu is available (sampling days 31.10.2013 (1-2) and 08.10.2015 (3-4)). The measured values are given in the table below.

Table 11. Results of personal sampling of chromium (VI) concentration in breathing zone air Sample Location/task Sapling time Result Result (minutes) Cr(VI) Cr(II/III) mg/m3 mg/m3 personal 1. filling/emptying hangers 8.29-11.02 (151) < 0.0001 < 0.0001 personal 2. process operator 8.47-11.56 (189) < 0.0001 0.0002 personal 3. process operator 9.07-12.05 (178) < 0.0001 < 0.0001 personal 4. filling/emptying hangers 9.17-14.11 (294) < 0.0001 < 0.0001

Cr (VI) in air < 0.1 μg/m3 (personal sampling (n=4))

The Cr(VI) concentration in breathing zone in personal sampling did not reach the detection limit of the used sampling/analysis methods.

Biomonitoring

Chromium in urine measurements results for the surface treatment plant workers of Abloy Oy Joensuu are available for the time period 2010-2014, excluding 2011 and 2012 when sampling was not done. The plant started its operation in the year 2010.

Manual hang up of items to hangers (or plaiting drums) prior to electroplating and manual removal of the items after electroplating is a task where a relatively high potential for exposure arise. These workers are in contact with the plated items and they normally stay full shift at the working area located in the electroplating process hall. In addition, number of workers is highest in comparison to other tasks at the surface treatment plant.

All results from the measurements were below 0.01 µmol/l Cr(VI) in urine, at the same level as for the non- exposed population.

The table below summarises the biomonitoring results for the surface treatment plant workers of Abloy Oy.

Table 12. Chromium in urine biomonitoring results Cr(VI) µmol/l at electroplating work Year Number of Task Maximum 90 th Median measurements percentile 2010 3 hanger <0.01 <0.01 <0.01 (load/unl.) 2013 2 hanger <0.01 <0.01 <0.01 (load/unl.) 2014 6 hanger <0.01 <0.01 <0.01 (load/unl.)

The relationship of Cr(VI) concentration in air to Cr(VI) µmol/l in urine has been clarified and reported estimates are available (FIOH 2014b). The relationship is most relevant for highly water soluble fractions of Cr(VI). In electroplating plants the chromium present in air close to electroplating baths is normally in highly water soluble form (mists from the warm baths). Exposure to a concentration 5 µg Cr(VI)/m3 has been observed to respond to about 0.2 µmol/l Cr(VI) in urine. Consequently 0.5 µg Cr(VI)/m3 responds to about 0.01 µmol/l Cr(VI) in urine.

At the Abloy surface treatment plant, all the measured biomonitoring results are below 0.01 µmol/l and thus the concentration of Cr(VI) in work place air would be < 0.5 µg Cr(VI)/m3. This is also in line with the observations from measured Cr(VI) concentration in workplace air (all results are below the detection limit < 0.1 µg Cr(VI)/m3).

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Exposure concentrations and risks for worker

Summary of measured exposure concentrations have been given in the table below. The data presented in the next table is just a summary for risk characterisation purposes applying existing data. Results of the biomonitoring results are included (applying also Cr urine (µmol/l) to air (µg/m3) conversion).

Table 13. Exposure concentrations and risks for worker Route of exposure and type of Exposure concentration Risk characterisation effects Inhalation, systemic, long-term < 0.1 μg/m3 (all Cr(VI) median-maximum & 90th < 4* 10-4 excess lung perc. measured, static and personal air sampling cancer risk, based on a 40 (measured static and personal data for electroplating tasks below the detection year working life (8h/day, air sampling, all, yr. 2010-2014) limits) 5 days/week) Inhalation, systemic, long-term 2 μg/m3 (TWA8, PROC 2, no RPE, TRA 3.1) 8* 10-3 excess cancer risk Inhalation, systemic, long-term 1 μg/m3 (TWA8, PROC 2, no RPE, MEASE) 4* 10-3 excess cancer risk Inhalation, systemic, long-term 5 μg/m3 (TWA8, PROC 4, no RPE, MEASE) 20* 10-3 excess cancer risk Inhalation, systemic, long-term 1 μg/m3 (TWA8, PROC 13, no RPE, TRA 3.1) 4* 10-3 excess cancer risk Inhalation, systemic, acute Inhalation, local, long-term Inhalation, local, acute Dermal, systemic, long-term 0.014 mg/day (modeled, PROC 4, full shift nd MEASE) Dermal, systemic, acute Dermal, local, long-term Dermal, local, acute Eye, local Combined routes, systemic, nd. nd. long-term Combined routes, systemic, acute

Remarks on exposure data:

In general, sufficient and high quality information is available on worker exposure to Cr(VI) in electroplating work (WCS1). This information covers results of Crtot/Cr(VI) in work place air and/or biomonitoring results (Cr(VI) in urine).

Based on the existing site specific data concentration of Cr(VI) in work place air, separation of workers from the potential to inhale process mists or be exposed to chromium via other routes is very well under control.

The design of the automated production line is modern, thus taking occupational safety issues into account properly.

Based on the results of all on-site measurements, it can be concluded that worker exposure to (VI) is at the same level as for non exposed population.

Modelled data:

Exposure evaluations for WCS1 has been made using MEASE and TRA models. Summary results are reported in Annex 2. Worker exposure estimates are given for different combinations of operational conditions (PROCs

2015-01-08 CSR-PI-5.5.2 CHEMICAL SAFETY REPORT 22 EC number: Chromium trioxide CAS number: 215-607-8 1333-82-0 and task duration) and risk management PPE/RPEs options. In general the measured concentrations in the working place air at Abloy site are clearly lower than the modelled concentrations.

Conclusion on risk characterisation:

Based on the on-site measured exposure information available, the risk management measures at the site are effective and cancer risks to workers for this contributing worker scenario can be considered to be controlled to low excess lung cancer risk level of < 4* 10-4.

9.1.3 Worker contributing scenario WCS 2, Preparation and maintaining the electroplating bath

Chromium acid is consumed in the electroplating process by reduction and electrodeposition of metallic chromium on to the surfaces of treated items. The preparation of the basic solution is made at the same time as the tank is taken into operation or after full maintenance. Water is added to the warm baths even daily to compensate evaporation of water from warm bath. This addition of water through stationary fitted pipings does not pose higher exposure potential than the ordinary electroplating tasks (no RPE in use comp. WCS1).

The concentration of chromium in the bath is reduced and therefore the electroplating bath needs to be maintained and the bath is refreshed by adding a proper amount of CrO3 to maintain Cr(VI) at ca. 300 g/l level.

To maintain the proper concentration of chromium and chromium to catalyst ratio at desired levels, monitoring of the bath solution is done daily. Laboratory personnel take small samples daily from the Cr bath manually. Concentration of Cr(VI), Cr(III) and sulphate are analysed at the laboratory of the surface treatment plant.

Interval to add CrO3 is dependent on the results of the analysis (ie. the consumption rate of chromium). The added amount of CrO3 is typically few kg at a time.

The CrO3 addition is carried out by the process operator. Following written work instructions the operator puts on PPE’s. Respiratory protection mask, safety shoes, gloves and chemical protective suit are always used by the workers when making CrO3 additions (see PPEs in picture 12, Annex 6).

In the chemicals storehouse the operator opens manually metallic CrO3 barrels. Normally few kg are added only. The work is done by weighting the amount CrO3 needed into a pail, carried to the process area and poured directly to the baths and allowed CrO3 to dissolve and dilute into the larger volume of the electroplating bath.

In the case of complete replacement of a chrome bath solution and making a new solution, high amounts of chromium acid is handled (> 500 kg) at a time. To carry out a complete replacement of the solution at minimum two persons are always required to carry out the task (operator and supervisor).

Chromium (VI) containing waste generated during the task is used/recycled in the process as far as possible. If that is not possible, the residues are disposed of as hazardous waste.

9.1.3.1 Conditions of use

Method Product (article) characteristics

. Chromium trioxide coarse grains (5-15 mm diam.), substance as such, low dustiness Site-spec. . Dissolved chromate solutions at room temperature and elevated process temperature (30-50°C) Amount used (or contained in articles), frequency and duration of use/exposure

. 1-10 kg CrO3, one worker 1-5 times per week per chrome bath, duration <30 min per time. Site-spec . > 500 kg CrO3 at a time per chrome bath, yearly or more seldom, two workers Technical and organisational conditions and measures

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Method . Indoors at normal room temperature, good general ventilation in store house and process hall Site-spec . Local exhaust ventilation operational in the plating tanks Conditions and measures related to personal protection, hygiene and health evaluation . Respiration Protective Equipment is always used: (95% effic. full face pressurised mask (P3 Site-spec filter) . Skin and body protection: Protective suit (washable or disposable overalls), safety boots, chemical goggles or face shield, chemically resistant gloves (Nitrile rubber, chloroprene rubber, butyl rubber or other suitable gloves, complying with the requirements of EN 374 (breakthrough time: 480 min); Specific activity training in relation to use and maintenance of the gloves must be provided) [APF 40, Effectiveness Dermal: 95%] . Standard PPEs (protective goggles/cloves) are sufficient for sampling Cr(VI) solution for laboratory analysis (no RPE required) Other conditions affecting workers exposure . Trained employees on how to safely work with the substance, incl. how to use the necessary Site-spec personal protection equipment. . If a worker comes in contact with chromium trioxide dust or solution he has to change clothes and take a shower as soon as possible. . The employees who are allowed to handle chromium trioxide are guided how to safely handle the substance. . Work instructions and action in case of spilling are available for the personnel. . The operators have always access to SDS and written work instruction documents for handling and mixing of reagents Additional good practice advice. Obligations according to Article 37(4) of REACH do not apply . Work under a high standard of personal hygiene. Wash hands and face before breaks. When Site-spec using the substance, do not eat, drink or smoke.

9.1.3.2 Exposure and risks for workers

Exposure measurements

Chromium in workplace air measurement result is available for process operator. Personal sampler data (n=2) from breathing zone (sampling day 31.10.2013 (1.) and 08.10.2015 (2.)). Chromium (VI) and (II/III) were analysed. The results are given below.

Table 14. Exposure concentrations at workplace air sample location/task sapling time result result (minutes) Cr(VI) Cr(II/III) mg/m3 mg/m3 personal 1. process operator 8.47-11.56 (189) < 0.0001 0.0002 personal 2. process operator 9.07-12.05 (178) < 0.0001 < 0.0001

Cr (VI) in air < 0.1 μg/m3 (personal sampling (n=2))

The Cr(VI) concentrations in breathing zone in personal sampling did not reach the detection limit of the used sampling/analysis methods and therefore Cr(VI) could not be detected or quantified. Chromium at the oxidation states II/III were also analysed and could be quantified at a very low level.

Exposure modelling

Modeling tools MEASE (1.0.2.01) and Targeted risk Assessment TRA v. 3.10 has been used in worker exposure assessment.

Exposure estimates (8hr TWA) for this contributing worker scenarios applying variable working time, PPE/RPE and substance combinations are given in the Annex 2 of this report "Exposure estimates for surface treatment

2015-01-08 CSR-PI-5.5.2 CHEMICAL SAFETY REPORT 24 EC number: Chromium trioxide CAS number: 215-607-8 1333-82-0 plant workers based on exposure models". Use of skin/eye, and for this WCS2 also respiratory, protection is always required – due to corrosive, irritant, sensitising and toxic properties of chromic acid.

Table 15. Exposure concentrations and risks for worker Route of exposure and type of Exposure concentration Risk characterisation effects Inhalation, systemic, long-term < 0.1 µg/m3, personal sampling < 4*10-4 excess lung (measured) cancer risk

Inhalation, systemic, long-term weighing and decanting CrO3, PROC 8a excess lung cancer risk 3.5 µg/m3, task 15-60 min, low dustiness solid 14 *10-3 (modelled) (100%) RPE 95%, (TRA 3.1)(Dose 2.4 µg/kg (exposure is intermittent, (bw)/d) not continuous or daily) Inhalation, systemic, long-term 2 µg/m3 PROC 8a, task 15-60 min, low dustiness excess lung cancer risk solid (100%) RPE 95%, (MEASE 1.02) 8 *10-3 (modelled) (Dose 1.4 µg/kg (bw)/d) (exposure is intermittent, not continuous or daily)

Inhalation, systemic, long-term 0.4 µg/m3 (RPE 90%), 4 µg/m3 (no RPE) (TWA8) 1.6 * 10-4 excess lung (modelled) weighing and dissolving of CrO3, (ART 1.5) cancer risk Inhalation, local, long-term Inhalation, local, long-term

Inhalation, local, acute Dermal, systemic, long-term 10 µg/day PROC 8a, task 15-60 min, low dustiness nd solid (100%) RPE 95%, contact level incidential, total dermal exposure (MEASE 1.02) Eye, local Combined routes, systemic, 0.18 µg/kg/d 5.9 * 10-5 excess small long-term intestine cancer risk (Based on inhalation 0.4 µg/m3 (non respirable), dermal 0.14 µg/kg (bw)/d) Combined routes, systemic, acute

Remarks on exposure data:

Low dustiness of chromic acid and use of effective RPE keeps exposure controlled to a low level. In practice, this task is one of the routine tasks of the process operators at the site and the operational conditions and risk management measures (e.g. use of protective enough PPE/RPE) needed for this task are always in use.

Chromium (II/III) was detectable in the breathing zone measurement. However, this result gives some information on slightly higher general exposure to chromium of process operators in comparison to other workers. Process operators handle chromium chemicals and they stay short or longer periods of time in the area where the electroplating equipments are located and the process takes place. However, even if some chromium was detectable (0.0002 mg/m3), the exposure is still at very low level at the applied operational conditions and risk management measures.

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Conclusion on risk characterisation:

Based on the information available, the risk management measures at the site are effective and risk to workers for this contributing worker scenario can be considered to be controlled to low excess lung cancer risk level of 1.6 * 10-4.

9.1.4 Worker contributing scenario WCS 3, Maintenance

Industrial maintenance of process equipment can be divided in different types: Preventive Maintenance (PM), Predictive Maintenance (PdM), Corrective Maintenance (CM), Situational Maintenance (SIT) (i.e. based on analysis results, special events, etc.)). Maintenance tasks at Abloy surface treatment plant include some procedures which must be done occasionally (CM: correction of pump breaks etc.) or tasks which must be carried out systematically following a predefined schedule e.g. changing pumps/sealants after they have been running a certain time (PM).

Maintenance may be also needed based on situational conditions after the need of maintenance has been observed (SIT/PdM). These tasks include emptying and removing sludge and precipitates from the electroplating tanks or pipings and maintenance of heaters/coolers and process control devices of the baths. These occasionally made operations may include cleaning of LEVs and exhaust gas manifolds, scrubbers, droplet separators and filters.

Emptying, cleaning and maintenance of Cr(VI) solution containing tanks is a task where high potential for expose to Cr(VI) exists. Maintenance of tanks is carried out by the own personnel of the site.

Maintenance at the surface treatment plant

Maintenance of ventilation system, mainly purification/flushing the chrome gas scrubber and droplet separator by water is done often, even daily, but this is remotely operated and a task of low hazard potential (no direct contact possible to flushing water or mists). All these tasks are carried out by the own staff who normally operate the electroplating process. Before performing maintenance in the area where chromium (VI) compounds appear in the process liquids or solids, all equipment has to be cleaned by an authorized and skilled person. Maintenance and cleaning i.e. removal of residues from electroplating tank is possible during longer intervals (e.g. during annual break off or more seldom).

There is a need to follow precautionary procedures and stringent safety measures, when cleaning of electroplating and activation tanks takes place. These include the use of chemical safety suit, boots, full skin protection and effective respiratory protection. The regular annual maintenance activities at the Abloy surface treatment plant take place two times a year for the chrome line (on week 10 and week 30).

Maintenance and cleaning, daily, weekly, monthly and annual include the following Preventive/Predictive tasks:

Daily routine maintenance checks/actions (related to chemical safety)

- Visual inspection of pumps for leaks - Checking the function of filters and changing if needed - Inspection of the ventilation controls at the engine room - Checking conductivity of the rinsing tank waters

Weekly routine maintenance checks/actions (related to chemical safety)

- Washing of floors and walking bridges - Checking functionality of temperature gauges of the baths - Removal of dropped items from the pools - Checking of rinsing waters/change if necessary

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- Washing of the heat exchanger of the ventilation system - Checking of filters, change if pressure drop > 2,5 bar (large filters) > 1.5 bar (small filters)

Monthly routine maintenance actions (related to chemical safety)

- Calibration of pH- and conductivity gauge - Service, cleaning and change of anodes if necessary - Washing and functional checking of electroplating tank LEVs and cases

Annual maintenance actions (related to chemical safety) - Emptying, cleaning and checking of electroplating and rinsing tanks and equipment (annually or twice a year) - Washing of filtering units, checking the pipings and joints - Changing and/or cleaning anodes - Washing of the conveyor system - General washing & cleaning of the surface treatment plant & chemical storage area - Checking of all chemical piping, checking of all WWTP piping – (recorded to inspection document) - Checking the condition and functionality of all leak-monitoring sensors – (recorded to inspection document)

The maintenance of mechanics (e.g. the automatic electroplating line) is outsourced to a specialised company. The maintenance of ventilation & air purification scrubber system is outsourced to a specialised company.

Maintenance of exhaust air scrubber includes:

-Fouling which accumulates as a result of the process must be checked at regular intervals and removed where necessary since the function of the washer is impaired by excessive fouling. The time intervals for checking vary depending on loading of the plant. -Monthly checking of the spray nozzles in the washer, visual inspection of irregular spray pattern and removal and cleaning of nozzles if needed. -Checking of the structured packings, separator profiles in the washer and the washer reservoir every 4 months for strong fouling or sludge. Clean the high pressure cleaner as necessary. -The liquid level regulation system in the reservoir should be cleaned at least once every 3 months to maintain good functionality. -All valves and motor-driven ball valves should be checked every 6 months for correct functioning (normally remotely operated, testing/checking manually).

Operational conditions in maintenance of electroplating tank in WCS3

Before maintenance the warm electroplating bath is cooled down to room temperature. After cooling, tank is emptied by pumping the liquid to another tank(s). LEVs are kept operational all the time during these operations.

Electric connectors/rails and anodes are removed and cleaned. Slots for LEVs along the tanks and LEV ducts are removed and cleaned.

Sludge from the bottom of the tank is removed manually by spades to buckets. Buckets are emptied to hazardous waste containers. After sludge removal tanks are cleaned thoroughly by the operators using proper safety equipment according to safety data sheets and other in house instructions to avoid exposure to chemicals. (PPE: safety boots and chemical suit (eg. Microchem 4000), safety goggles and RPE mask (ABEK/P3 filter) or full face mask (ABEK/P3 filter). After cleaning and drying the tanks are thoroughly checked and overhauled.

Waste management in WCS3

The risk management measures in an exposure scenario should cover waste management measures to reduce or avoid exposure during waste disposal and/or recycling. Chromium containing waste requiring external treatment is generated during the maintenance tasks of electroplating tank. Prior to maintenance the chromic acid process

2015-01-08 CSR-PI-5.5.2 CHEMICAL SAFETY REPORT 27 EC number: Chromium trioxide CAS number: 215-607-8 1333-82-0 liquids are transferred in a controlled way from the electroplating tanks to empty neighboring tanks for temporary storage. After sludge removal and maintenance chromic acid can normally be returned back to the original electroplating tank.

The separated Cr(III/VI) sludge may be handled as hazardous waste as such or pretreated first as appropriate. The pretreatment includes reduction of Cr(VI) to Cr(III) with sodium hydrogen sulphite and sludge dewatering. All this sludge is disposed according to local regulations and permissions and following the guidelines laid down in the EU legislation on waste and pollution prevention. In practice, a truck of authorised hazardous waste management company picks up the sludge and other process waste for further treatment for recycling and/or final storage.

9.1.0.1 Conditions of use

Method Product (article) characteristics . Chromium (VI) containing equipment (dry solids, solutions, wet precipitates, sludge) Amount used (or contained in articles), frequency and duration of use/exposure . Variable tasks and amount of chromium substances, duration of specific maintenance Site specific tasks 15 min-8h/d per person, 1-5 occasions a site per year. . Maintenance and cleaning of electroplating and rinsing tanks (1-2 times/a) . Maintenance/changing pumps, heaters, coolers (occasionally) . Maintenance of exhaust air scrubber (checks daily, maintenance at least monthly) . Maintenance/change sensors and other control equipment (occasionally) . Maintenance of LEV/general ventilation and waste gas purification systems (daily/monthly) Technical and organisational conditions and measures . Variable tasks, conditions are not always anticipatable Site specific . Before performing maintenance in the area where chromium (VI) exists, all equipment has to be cleaned by an authorised and skilled person. . In cleaning and maintenance of tanks and pipings where Cr(VI) compounds may appear strict conditions and measures have to be followed. Instruction for proper procedures for emptying, waste handling and cleaning of the equipment are in the possession of the work supervisor or the plant manager. Conditions and measures related to personal protection, hygiene and health evaluation . Regular preventive/predictive maintenance: Protective glasses, protective clothing and Site specific gloves, be prepared to use RPE whenever needed/anticipated if the potential of exposure to Cr(VI) containing dust/mist is high. . For known high exposure tasks, emptying and cleaning of electroplating tanks: full face mask ABEK/P3 (APF = 40) chemical protective gloves (APF 20) chemical protection suit (EN 468) and safety shoes, chemically resistant gloves (Nitrile rubber, chloroprene rubber, butyl rubber or other suitable gloves, complying with the requirements of EN 374 (breakthrough time: 480 min). . When working in closed or deep tanks/containers independent respirators need to be used to avoid risk of too low oxygen level. Avoid any dust/mist formation by technical means e.g. avoid handling of dry dusty waste, use RPE whenever dust/mist is generated. . If instructions for proper procedures for the work are not available, sufficiently protective PPEs must always be selected in use by a way of precaution. Other conditions affecting workers exposure . Variable conditions: physical form of the substance may be solid/dust/liquid/mist, Site specific pure/mixture at ambient or elevated 50-60 °C temperature. . All regular maintenance tasks are normally carried out by own staff. If outsourced personnel are needed in some specific maintenance task (and prior to the maintenance cleaning tasks), all requirements, conditions and measures related to personal protection apply also to outsourced personnel.

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Method Additional good practice advice. Obligations according to Article 37(4) of REACH do not apply . Training and awareness; Identify training needs to ensure that all personnel whose work General info may significantly affect worker safety and environmental impacts in the waste management activities have received appropriate training and have sufficient technical skills/practical experience of hazardous waste management. Awareness of the importance of following recommended operational conditions and risk management measures and use of proper and sufficient PPE/RPE whenever needed is key elements of the worker safety. . The employer and self-employed outsourced maintenance and cleaning persons have legal responsibilities for the maintenance and issue of personal protective equipments and respiratory protective devices if needed and the management of their correct use in the workplace including training of the workers.

9.1.4.1 Exposure and risks for workers

Biomonitoring results

Measured biomonitoring data related to maintenance tasks at the Abloy surface treatment plant is available. All results are below <0.01 µmol/l. Summary of results is given in table below.

Table 16. Exposure Chromium (VI) in urine results [µmol/l] for Abloy Joensuu maintenance workers Year Number of Task Maximum Median measurem Cr(VI) Cr(VI) ents µmol/l µmol/l 2010 5 maintenance <0.01 <0.01 2013 5 maintenance <0.01 <0.01 2014 3 maintenance <0.01 <0.01

Modelled exposure

Modeling tools MEASE (1.0.2.01) and Targeted risk Assessment TRA v. 3.10 have been used in exposure assessment for maintenance.

Exposure estimates (8hr TWA) for this contributing worker scenarios applying variable working time, PPE/RPE and substance combinations are given in the Annex 2 of this report "Exposure estimates for surface treatment plant workers based on exposure models". Use of skin and eye protection is always required for this WCS3. Respiratory protection (90/95% efficiency) and enhanced skin protection (gloves (APF20), chemical protective suit and boots are always required in cleaning of electroplating tanks – due to corrosive, irritant, sensitising and toxic properties of chromic acid.

Table 17. Exposure concentrations and risks for worker in maintenance and cleaning work Route of exposure and type of Exposure concentration Risk characterisation effects Inhalation, systemic, long term <0.01 Cr(VI) µmol/l (in urine) < 4*10-4 excess lung cancer risk (reference limit for non-exposed population (coarse estimate) (measured, biomonitoring) is 0.01 μmol/l) << 4*10-4 excess intestinal cancer risk (coarse estimate, exposure through non respirable particles) Inhalation, systemic, long-term 8.7 µg/m3, (TWA 8) PROC 8a, task 60- excess lung cancer risk 240 min, liquid (>25%), gloves 32 *10-3 (APF20), RPE 95%, (TRA 3.1) (exposure is intermittent, not

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Route of exposure and type of Exposure concentration Risk characterisation effects continuous or daily) (Dose 1.5 µg/kg (bw)/d) Inhalation, systemic, long-term 1 µg/m3, (TWA 8) PROC 8a, task 60- excess lung cancer risk 240 min, liquid (>25% Cr(VI) direct 4 *10-3 (exposure is intermittent, handling, contact level extensive, RPE not continuous or daily) 95%, (MEASE 1.02)

(Dose 0.17 µg/kg (bw)/d) Inhalation, systemic, acute Inhalation, local, long-term Inhalation, local, acute Dermal, local, acute Dermal, systemic, long-term 1.44 mg/kg/d, PROC 8a (task 1-4hr, nd liquid >25% Cr(VI)) contact level extensive (MEASE) Dermal, systemic, long-term 0.68 mg/kg/d PROC 8a (task 1-4hr, nd liquid >25% Cr(VI)) (TRA) Eye, local Combined routes, systemic, 1.6 - 2.2 µg/kg (bw)/d 4.8-6.6 *10-4 excess intestinal long-term (modelled) cancer risk (dermal 1.44 mg/kg/d, inh. 0.17 µg/kg

(bw)/d, MEASE)

(dermal 0.68 mg/kg/d, inh. 1.5 µg/kg (bw)/d, TRA) Combined routes, systemic, acute

Remarks on exposure data:

Maintenance work typically contains tasks which may lead to significant exposure if sufficient PPE are not used. In practice, the operational conditions may not always be completely justified in advance. Exposure may sometimes be sudden and unexpected and therefore PPEs should be used as a precautionary measure, so that the PPEs in use cover also these sudden occasions.

Use of skin/eye protection is always required – due to corrosive, irritant, sensitising and toxic properties of chromic acid and chromate solutions. Therefore quantitative assessment of dermal exposure or exposure to eyes is not regarded relevant. Use of skin protection is always recommended, even if hand protection requirements may often be difficult to comply with due to the nature of some of the maintenance work (e.g. in some mechanical engineering and assembly work).

Measured biomonitoring data is available for the maintenance work. This information indicates that exposure to chromium is well controlled and the PPE/RPE in use are sufficient to protect workers at maintenance work.

The modelled information (applying PROC 8a, gives also clear indication that normal PPEs and also RPE is needed to keep worker exposure levels at sufficiently low level whenever the process chemicals and liquids containing Cr(VI) are involved in the maintenance task. In the Annex 2 – Exposure estimates for surface treatment plant workers based on exposure models, the effect of different combinations of process category, working time, composition of the substance and PPE in use on the 8 hr TWA exposure levels for workers carrying out cleaning and maintenance of electroplating tanks can be seen. In tank maintenance work, the methods and PPEs in use are sufficient to keep exposure levels controlled to a low level of concern.

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If mists and aerosols are generated in air a full face RPE mask and chemical protective suit is recommended in these circumstances to keep the worker exposure levels controlled to a risk level of low concern.

In the cases where equipment breakages may lead to unfavourable exposure situations and instant maintenance/repair of equipment is needed it may be difficult to keep exposure levels completely under control. However, these situations are occasional/rare and in long term the exposure levels of individual workers stay at low level as they are for the normal work conditions (see WCS 1&2).

Conclusion on risk characterisation:

Based on the information available, risk to workers for this contributing worker scenario WCS3 can be considered to be controlled if the recommended risk management measures and PPE outlined in this contributing scenario are implemented by the users.

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10. RISK CHARACTERISATION RELATED TO COMBINED EXPOSURE

Risk characterisation for combined exposure is relevant in situations where 1) the same person is exposed to the same substance in the same setting via different routes of entry and via the environment. Combined time weighted one full shift exposure estimation is also relevant in all those cases where 2) the same person is carrying out different contributing sub scenario tasks during a same work shift.

In the first case combined risk characterisation can be performed by combining the current risk levels derived for the local population to the risk levels derived for workers. The combined exposure is relevant for persons living in the communities located close to the electroplating plant and at the same time being workers at the electroplating plant.

In the second case, worker exposure arsing from different tasks can be summed up. At Abloy operators are involved in WCS1 and WCS2 tasks and therefore summing up is relevant. For the WCS3 the summing is not that reasonable, since exposure in different WCS3 maintenance tasks are so heterogenous group of various tasks that cannot be easily splitted and summed up with other contributing sub scenarios. The maintenance of process equipment (pumps, gauges, hangers...) is carried out by specialised personnel and not by the process operators.

In practice the summed exposure does not change the excess cancer risk conclusions for Abloy Oy Joensuu surface treatment plant. Exposure levels are at so low level that no measurable distinctions could be made between different tasks. All measured Cr(VI) personal sampler and Cr(VI) biomonitoring exposure levels are below the detection limits of the analytical methods.

One static measurement only exceeded the detection limit and thus the highest measured value is Cr(VI) 0.1 µg/m3. In that case the static measuring point was very close to the electroplating bath. Process operators are the only persons who may be there during normal work shifts and normally operators stay there only a short period of time.

Biomonitoring results have also shown that exposure to Cr(VI) is very well under control, since Cr(VI) in urine levels are not elevated for anyone working at the plant. Exposure is at the same level (0.01 µmol/l) as for populations having no occupational exposure to Cr(VI).

Table 18. Summary of estimated cancer risk levels for different populations Exposed group or task Excess cancer risk Duration of exposure Worker WCS1 Electroplating < 4* 10-4 excess lung cancer risk, based ca. 220 days/a on a 40 year working life (8h/day, 5 days/week) Worker WCS2 Preparation and < 4*10-4 excess lung cancer risk, based 0.5-4 hr/d, ca.1-30 days/a maintaining the electroplating on a 40 year working life (8h/day, 5 bath days/week) Worker WCS3 Maintenance < 4*10-4 excess lung cancer risk, based from minutes to days, (including cleaning) on a 40 year working life (8h/day, 5 outsourced maintenance days/week) max 24 days/a for the site, cleaning 0.5 hr in 130 days/a General population (local) < 1.9 *10-7 excess lung cancer risk 24 hr/day/70 years < 5.2 * 10-7 excess intestinal cancer risk

It can be seen from the risk levels that the estimated lung cancer (and intestinal cancer) risk levels for workers and the general population are low. The sensitivity of methods of sampling and analysis methods are actually setting the limits how accurate estimates for exposure and risk estimates can be given.

For general population the calculated risk levels are even about two-three orders of magnitude lower than for workers, since releases to aquatic environment and to local air are also very well under control.

Without further consideration, risk in relation to combined exposure is at a very low level for all worker

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It is expected that the use of CrO3 at Abloy Joensuu surface treatment plant would grow 5-10 % annually and would be doubled to 1.3 t/a until the end of the year 2028. By applying the current operational conditions and risk management measures the annual increase in CrO3 use tonnage would not affect worker exposure. Instead, some increase in the emissions to atmosphere and releases of chromium to surface water is possible. Assuming linearity to current release status, releases could also be doubled to ca. 300-350 g/a to air and 350-400 g/a to surface water by the end of the year 2028. As a worst case scenario, this would also double exposure and excess cancer risk levels to general population to a level of 0.5-1*10-6 (still a conservative estimate).

Uncertainty Analysis

The hazard assessment (e.g. health effects) and also the site specific exposure assessment of CrO3 carry a degree of uncertainty that is integrated in all obtained cancer risk estimates. The uncertainties associated to human health hazard assessment and dose-response derivation is a general issue and certain intrinsic uncertainties are always present in risk estimation when it is a question of non-threshold carcinogenicity. However, the ECHA/RAC recommended dose-response relationships were used in the estimating the excess cancer risk estimates.

Regarding the site specific exposure estimates, current worker exposure and releases of chromium into the local environment are known well at Abloy Joensuu surface treatment plant.

Worker exposure is monitored systematically applying recommended biomonitoring Cr in urine methods and static and personal sampling methods in measurement of Cr(VI) concentration in workplace air. The sampling and analytical methods are accredited. In most cases the sensitivity of the analytical methods (ie. detection/quantification limits) in workplace air measurements are the limiting factor in determining the actual worker low level exposure to Cr(VI). Exposure cannot be accurately quantified, since measured concentrations are below the detection limits. All results of the biomonitoring measurements are also at low level and at the same level as for non-exposed population. All personal measurements are limited to Abloy personnel and the exposure levels for outsourced personnel (maintenance & cleaning) is one of the uncertainties involved in the occupational exposure estimates.

No significant uncertainties in environmental exposure assessment are identified. Monitoring of material balances and releases of chromium to surface water is effective. Releases of chromium to local air is effectively controlled by a modern scrubber system and release rates have been time to time (twice in five years) monitored by analytical methods. Releases of Cr to municipal sewer system are regulated by permission limits and systematically monitored (daily) by laboratory analysis.

Indirect human exposure to Cr(VI) via the environment utilises the release data available for the Abloy site. The release data is regarded reliable and in overall the releases are low. There are no known other sources of Cr(VI) in the industrial area or historical contamination by Cr(VI) by accidents or high release rates in the past decades.

Indirect human exposure was estimated by the recommended tool Euses model. The uncertainties associated in the modelled results cannot be quantified, since measured values are not available for validation of Cr(VI) exposure. Total daily intake of chromium (VI) from various foodstuffs was modelled by assuming Cr releases to air and surface water is completely in Cr(VI) form. In addition reduction of Cr(VI) to lower oxidation states in air and in surface water environment was by far ignored. Therefore indirect human exposure via the environment was regarded conservative and at least slightly an overestimate.

Overall the uncertainties in the outcome of this exposure assessment are believed to be relatively low and there are not any major factors in the exposure side that could be used to increase further the reliability of the assessment.

As a conclusion, the site specific exposure assessment of CrO3 can be finalised since unacceptable or significantly high uncertainties have not been identified in the exposure data and the reliability of the measured exposure data is regarded reliable and clearly meets the general quality criteria set for sampling and analysis of occupational exposure data and environmental release data.

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