The Restriction process for the 5 Co Salts has now been put to consultation (closing 25 May), following a meeting of the SEAC in March.
The RAC continues to recommend the use of a limit value for cancer (0.5 µg Co/m3 respirable, with cancer risk) based on a breakpoint approach and a limit value for non-cancer effects in the upper respiratory tract (1 µg Co/m3 inhalable). Both of these limit values are 8-hour time-weighted averages (TWAs), very much like that of an OEL.
SEAC agreed to put both RO1a (10 µg/m3) and RO1b (1 µg/m3) forward to public consultation but rejected RO1c (0.1 µg/m3) and RO1d (0.01µg/m3) as not proportionate, practical, or technically feasible. SEAC believes RO1b is likely not proportionate and it is uncertain about the proportionality of RO1a but concluded that both are enforceable and overall practical. SEAC supported re-applying a derogation for animal feeds and specifically asked about this in the public consultation.
However, SEAC said it does not think that the restriction initially proposed by the Dossier Submitter (ECHA) is the most appropriate EU wide measure, and additionally concluded that it is uncertain whether the restriction as amended by RAC is the most appropriate EU-wide measure. SEAC explicitly remains open to a bOEL being the more appropriate Risk Management Option (RMO).
A consultation was launched on 25 March, which CoRC-CI will be responding to. The industry position remains that an EU-wide binding OEL under the Carcinogens and Mutagens Directive for cobalt and compounds is a more appropriate RMO than the proposed restriction. CoRC-CI’s response will argue this, and that the current restriction options are all disproportionate.
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