Dave Elliot, CEO of the Surface Engineering Association (SEA) recently visited the European Chemicals Agency to find out more about the reclassification of Silver.

The European Chemicals Agency (ECHA) published the intention of the Swedish Chemicals Agency, KEMI, to classify silver metal as:

Skin Sens. 1, H317

Muta. 2, H341

Repr. 1B, H360FD

Aquatic Acute 1, M-factor=10 (powder <1mm) and M-factor=1000 (powder <0.0001mm)

Aquatic Chronic 1, M-factor=10 (powder <1mm)  and M-factor=100 (powder <0.0001mm)

This classification has been proposed in the context of the Biocidal Products Regulation but will apply to other regulations (e.g.: REACH) and other applications (e.g.: jewellery, electronics, solar energy etc.) as well. Skin sensitization cat 1 could trigger a restriction for skin contact materials like jewels. A classification as reprotoxicant category 1B can trigger a fast track restriction process banning all the consumer uses of silver and silver compounds (e.g.: no jewellery, no silverware anymore).

This classification will also qualify these substances for the authorisation process under REACH which could require an authorisation for each industrial and professional use. The final aim of these regulatory measures is the substitution of the classified substances by safer alternatives.

 I attended a meeting of the European Precious MetalsFederation (EPMF) last week and they are not supporting this classificationproposal because it is based on weak weight of evidence rather than robustscientific data. The EPMF has identified data gaps in the scientific databasefor silver, and has been proactive in filling this data gap. Under REACH, theEPMF submitted a Testing Proposal to perform an Extended One GenerationReproductive Toxicity study in 2015 for silver, which has been approved in June2019. The testing program has just started.

EPMF believes that great care is needed in making anyproposals for the Classification and Labelling of silver and silver compounds.

The EPMF profoundly regrets that the Swedish Chemical Agencyhas chosen to submit a classification proposal for silver nitrate in December2018 and for silver in July 2019, and that they will soon submit anotherseparate proposal for silver chloride without properly recognizing thescientific data gaps and without taking into account the Testing Proposal underREACH. It is frustrating for the precious metals industry to see two parallelbut separate processes which have an impact on each other working in isolationand, potentially, leading to different outcomes. 

France Capon france.capon@epmf.beis the Secretary General of the EPMF and I’m sure she will provided you withany further information.

Here is a link to the presentations from the meeting that wecan use to inform our members https://www.epmf.be/epmf-silver-workshop-2/