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Evaluation of the Danish Statutory Order on Lead 5 Applications of lead as a chemical compound - exemptions from regulation
5.1 Heat stabilisers in elastomersElastomers are defined as polymers which, when cross-linked, form a three-dimensional network which makes the material stable to many different impacts, for instance heat. The formation of cross-linking is initiated/catalysed by zinc oxide. The zinc oxide used contains 0.2 to 0.6 per cent lead, and the final rubber product will therefore contain up to 0.006 per cent [Wendsjö 2005]. Some actors on the market have used lead oxide to activate cross-linking. One of them has for several years been working to phase out lead oxide for such applications, without being able to find anything with the same heat-stabilising effect as lead oxide. In practice, a lower level of heat stability has been accepted, and this minimises the use of lead oxide as heat stabilisers in products regulated under the Lead Order [Thisgård 2005]. In the past, lead was used for vulcanising rubber, mainly for cables, but this process is probably no longer used in Western Europe [Nielsson, 2005]. Lead contents could have amounted to approx. 5 per cent PbO [Wendsjö 2005]. In the EU End-of-Life Vehicles Directive (cf. Annex 2 and [EU 2005a]), an exemption is granted for lead in elastomers for the following applications:
Evaluation This harmonises well with the fact that major Danish producers are of the opinion that the current exemption from the Lead Order is no longer required as regards heat stabilisers in polymers. However, it is possible that lead is being used in imported rubber products, including vehicles above 3.5 tonnes, which are not regulated in the EU End-of-Life Vehicles Directive. It is recommended to cancel the present exemption for elastomers. For some products there may still be a need to use lead. In such cases the possibility of applying for an exemption can always be used. 5.2 Stabilisers incorporated in electrical cables in productsStabilisers incorporated in electrical cables in electrical and electronic equipment are to a large extent covered by the RoHS Directive. The RoHS Directive (cf. Annex 2) and amendments and the Annex (cf. [EU 2005]) do not provide for exemptions for lead stabilisers in power cables. See also section 3.1 on special cables. NKT [Thiesen 2005/06] points out the special problem that the RoHS Directive sets out a limit value for the content of lead of 1000 ppm, while in the Lead Order, the limit value is 100 ppm. Lead stabilisers in concentrations of 900 mg/kg may in principle be applied deliberately in PVC with the purpose of reducing quantities of the more expensive lead-free stabilisers. Certain producers are therefore likely to do so for economic reasons. According to NKT [Thiesen 2005/06] it should therefore be considered to increase the limit value to 1000 ppm for lead in PVC in power cables incorporated in products. Evaluation: The fact that the RoHS Directive does not provide for exemptions for lead stabilisers in electrical cables may be considered as documentation that the EU is of the opinion that satisfactory alternatives to lead as stabilisers are available (probably Ca/Zn stabilisers) which are considered suitable for power cables in the types of electrical and electronic equipment covered by the Directive. These alternatives should actually be suitable in most other types of equipment. In accordance with section 3.1, it is probable that lead-free stabilisers are used for the majority of all cables. It is therefore recommended that the exemption for electrical cables incorporated in products be repealed. It is, however, possible that some products that are not identified in this study contain cables for which alternatives to lead are difficult to find (cf. section 3.1). In such cases it should be possible to apply for an exemption from the Lead Order. At international level, there is probably no doubt that - as stated by NKT – the producers will pay more attention to the limit value for lead in the RoHS Directive than in the Lead Order. Therefore, lead in PVC insulation of electrical cables incorporated in products may very well occur in quantities that do not violate the RoHS Directive, but which exceed the limits set in the Lead Order. This scenario – if it became general practice – might very well cause difficulties in relation to imports of important equipment into Denmark. However, the general impression is that producers have introduced lead-free stabilisers (cf. section 3.1). Besides, the problem can be minimised by effective inspection. It is true that the NKT proposal to raise the limit value for lead in power cables incorporated in products to 1000 ppm will reduce the need for inspection, but it would also be in conflict with the intentions behind the Lead Order. It is therefore recommended to maintain the limit value of 100 ppm for lead stabilisers in electrical cables incorporated in products. 5.3 High-intensity discharge lampsWhen consulted regarding the RoHS Directive, industry and other stakeholders stated that high-intensity discharge lamps (HID) contain lead iodide in order to have the proper light spectrum, and, further, that the lamps are used for conservation, reprography, and printing of labels [FIA 2004]. Each lamp contains 0.5-5 mg lead iodide, depending on the type and size of the lamp [FIA 2004]. Lead consumption in Europe for such purposes is estimated at a total of 10 kg/year [ELC 2005]. There is no information on alternatives [ELC 2005]. The EU Technical Advisory Committee has decided to recommend that lead in HID lamps for graphic applications and in HID lamps for specific purposes (see Annex 2) be exempt from the ban set out in the RoHS Directive. High-intensity discharge lamps are not produced in Denmark. According to information received, high-pressure sodium lamps, in the group of HID lamps, can be supplied with and without lead, and that, for lead-containing lamps, power consumption is lower than for lead-free lamps [Jensen 2005]. Evaluation Information is not available in Denmark to decide whether lead can be avoided in high-intensity discharge lamps. At European level, this issue is being evaluated in connection with the RoHS Directive, and it is therefore considered natural to follow the decisions and evaluations made at European level. It should be noted that in the Directive it has been proposed to exempt high-intensity discharge lamps for a number of specific applications (see Annex 2) from the ban, and this can be considered as documentation for the fact that at EU level suitable alternatives for such applications are not considered available. Since the RoHS Directive applies in Denmark, it should be considered whether there is a need to maintain the exemption granted for HID lamps. If it is decided to uphold the exemption, it should be defined in more detail in order to correspond to the exemption set out in the RoHS Directive. 5.4 Paint for special usesAccording to Hempel [Makholm 2005] substitutions have not been developed for lead in corrosion protection and anti-fouling agents. The current limits to the content of lead - below 250 ppm – in paint for corrosion protection, and less than 1250 ppm in anti-fouling agents (cf. section 2), are based on the content of lead as a natural impurity in the zinc and copper compounds in the paints. It is possible to use zinc compounds that have been treated in order to remove lead. However, the price will be substantially higher, and given the modest amount of lead, this solution does not pay off. The problem complex is the same for copper [Makholm & Spove 2005]. The major part of production is exported [Makholm & Spove 2005]. In corrosion inhibitor used to protect iron and steel, the active pigment is zinc phosphate. This type of paint is used for objects that are difficult to clean properly, or that are to be painted in bad weather conditions (cold weather etc.) [Makholm & Spove 2005]. An alternative to zinc phosphate is zinc dust paint containing lead impurities, but exempt from the Lead Order because lead for such purposes is considered as a metal, and not as a chemical compound. In addition, epoxy paint or water-based thick-coat acrylic paint [Makholm & Spove 2005, Meyer and Brix 2005], which require better preparation treatment to clean the objects to be painted, or more favourable weather conditions. Anti-fouling paints contain zinc oxide and copper oxide, which help regulate solubility. Alternatives include other techniques, for instance manual or mechanical cleaning, which are generally more expensive. New silicone-based anti-fouling agents are being developed, but are only efficient on fast-moving vessels, because algae cannot stick to the surface when the vessel is moving at a certain speed. Therefore, silicone-based paints do not work on leisure boats which are in harbour for much of the time [Makholm & Spove 2005]. Evaluation Alternatives are not available for all applications of paints containing too much lead, neither for corrosion inhibition, nor for anti-fouling purposes. Given the lack of such products on the market, it is expected that some users are buying the paints outside Denmark. It is recommended that the current exemption be upheld. The exemption should be reassessed within a few years. It should be noted that the problem complex indicates that problems with zinc compounds might occur in relation to the Lead Order in other contexts. 5.5 Glass for special usesSpecial uses of glass include the following: - picture tubes - light sources - optics - radiation protection - car windows - plates in photocopy machines - coating of plane glass - crystal - silicate glass for sand blasting Current applications of lead for such purposes are described below. Picture tubes However, developments are moving towards phasing out picture tubes, and introducing flat-screen panels. It is impossible to predict the speed of this development, but in the next decade, sales of new picture tubes are likely to fall substantially. Light sources Lead glass with lead oxide is used to seal the sockets of power conductors in fluorescent tubes. Lead glass is also used in the tube of compact fluorescent lamps and in certain neon advertisement signs. These applications are covered by the RoHS Directive. The EU Technical Advisory Committee has decided to recommend that lead oxide in glass for flat tubes in LCD screens should also be exempt from the ban provided for in the RoHS Directive (cf. Annex 2). Information is not available in Denmark to decide whether lead can be avoided for such applications. Since the issue will be evaluated at European level in connection with the RoHS Directive, it is natural to postpone decisions until these evaluations and decisions have been made. Lead glass is exempt from regulation under the RoHS Directive (cf. Annex 2). Since the RoHS Directive also applies in Denmark, it should be considered whether there is a need to uphold the Lead Order’s exemption applying to light sources. If it is decided to uphold the exemption, it should be defined in more detail in order to correspond to the exemption set out in the RoHS Directive. Optics Lead in optical and filter glass is covered by the RoHS Directive, but exempt from the ban on the use of lead (cf. Annex 2). This should be considered sufficient documentation that the EU finds that acceptable alternatives to lead do not exist for such applications. Since the RoHS Directive also applies in Denmark, it should be considered whether there is a need to uphold the Lead Order’s exemption applying to optical glass. Radiation protection Car windows The basis for the current exemption for car windows is not quite certain. However, the edges of car windows are known to contain a black ceramic material based on lead glass. The purpose of the black material is to protect the glue retaining the window pane from being degraded by solar UV radiation [Lassen et al 2003]. The fact that the EU End-of-Life Vehicles Directive (cf. Annex 2) prohibits the use of lead in car windows should be considered sufficient documentation that the use of lead for this purpose is not based on technical requirements. Thus, there is no need to uphold the exemption from the ban on lead for such applications. Plates in photocopy machines See section above on optical glass. Coating of plane glass Crystal The Danish glassworks Holmegård Glasværk substituted lead in crystal glass several years ago. However, lead is commonly used for the production of crystal glass in Europe, because the designation crystal is only allowed for glass containing a minimum of 24 per cent lead oxide [EU 1969]. Silicate glass for sand blasting Evaluation In line with the above, it is recommended that the exemption be repealed for car windows and coating of plane glass. It is also recommended to consider whether the exemption applying to picture tubes, light sources, optical glass and plates in photocopy machines should be repealed. For the remaining applications it is recommended to uphold the exemptions and to re-evaluate them within a couple of years. The reason for recommending whether the exemption for picture tubes, light sources, optical glass and plates for photocopy machines should be cancelled is that these applications are covered by the RoHS Directive and, until further notice, exempt from the ban on the use of lead under the Directive. Since the RoHS Directive also applies in Denmark, the applications are regulated twice. As is the case with the Lead Order, the RoHS Directive aims at minimising lead in the products involved, and under the Directive, the exemptions are being re-evaluated on a continuous basis. It is considered unlikely that Denmark will support less strict regulation of lead in electrical and electronic equipment. Thus, it serves no practical purpose to uphold separate Danish exemptions. 5.6 Glaze, enamels and pigments on art and handicrafts that are not likely to be used in connection with foodstuffsBoth Royal Copenhagen and Georg Jensen have used, and to a certain extent still use, lead in colouring, enamels and glazing on art and handicrafts. The following properties of lead compounds make them difficult to replace in some ceramic products [Eskildsen & Christoffersen 2005/06; Poulsen & Nielsen 2005]:
In Denmark, lead has been used especially in faience products, but this production has now ceased. Small amounts of lead silicate are used in the manufacture of items decorated over the glaze such as those made by Flora Danica and similar. It has not been possible to identify practicable alternatives. Otherwise, porcelain is manufactured traditionally without using lead compounds. Colouring containing lead silicate is only used to decorate fired porcelain. The enamels used today in modest quantities in, for example jewellery and silverware, still contain lead. It has not been possible to identify practicable alternatives here either, because of the melting point of the enamel and correct colour tones [Eskildsen & Christoffersen 2005/06]. Lead-free colouring for porcelain does exist and it is marketed in the hobby sector etc. According to the manufacturer it can be regarded as a perfect substitute, but users are conservative and prefer the products containing lead [Schjerning 2005]. Regarding ceramics, the market is dominated by private artists and any real industrial production in Denmark has ceased. A dominant supplier for this market in Denmark believes that previously lead was used to reduce melting points, but today for all intents and purposes it is not used in ceramic dyes, but only for special glass dyes [Markusen 2005]. Ceramics is therefore one of the uses where substitution of lead has actually been introduced. Another factor regarding use of porcelain and ceramics etc. colouring containing lead at hobby classes is that the colouring is a powder labelled toxic and it can only be purchased provided the Danish Working Environment Authority has been notified. However, it is possible to buy toxic ready-to-use porcelain colouring without submitting a signed notification or requisition to the police [Petersen 2005]. There have been no attempts to obtain information about the use of lead pigments and alternatives for other types of art such as paintings etc. Evaluation Art and handicrafts are traditionally an area granted exemptions in regulation on the use of hazardous substances, partly because there are significant cultural assets and partly because consumption is often relatively modest compared with most other uses. As described above, there are alternatives to lead on their market, at least with regard to handicrafts. It is not known whether these alternatives can cover all existing needs. Ultimately, however, the choice of pigments and other chemicals is always a question of the colours and textures that can be obtained. Therefore, excluding lead means that there may be certain nuances and textures that must also be excluded, but this does not otherwise prevent the production of porcelain, ceramics and enamel. Moreover it will always be possible to allow exemption for products of cultural-historical significance such as Flora Danica. In view of the fact that the continuing general exemption for these products is not motivating development of alternatives, it is recommended that the exemption for handicrafts be repealed. It is likely that there will be many applications for exemptions. It should be noted that ceramic articles intended to come into contact with foodstuffs are exempt from the ban, as these articles are covered by EU Directive 84/500/EEC. 5.7 Glaze on tiles, vitrified brick, brick and spark plugsGlazing containing lead is still used to glaze tiles, bricks and vitrified brick made in Denmark, as well as in imports of glazed products, especially from Germany and the Netherlands. Danish production includes in particular specialist products [Bisgård 2005; Kalmer 2005]. Use of glazing containing lead still dominates in Europe, because, as yet, alternatives have not been developed which give the same water-proofing in the long term. This is important as tiles, brick etc. are usually made to have a long lifetime outdoors and exposed to rain and frost [Bisgård 2005]. No development and tests of glazing have been carried out in Denmark. Developments in this area are primarily taking place in Germany, and in practice German initiatives and experience are directing development in the field [Bisgård 2005]. Spark plugs were removed from the list of exemptions from the EU End-of-Life Vehicles Directive with the amendment of 20 September 2005 to the Directive [EU 2005a]. This should be regarded as a definite indication that lead can be substituted in glaze on spark plugs. It is known that at least one dominant manufacturer has been working on substituting lead in spark plugs for a long time [Kløcker 2005]. Evaluation As there are currently no technically acceptable alternatives to lead glaze on tiles, bricks and vitrified bricks, it is necessary to maintain the exemption for these materials. This exemption should be reassessed after a certain number of years. The fact that it is now possible to substitute lead in the glaze on spark plugs, and that to a large extent it is possible to exclude lead from the glaze on porcelain and ceramics (cf. section 5.6) should be regarded as a sign that the technical problems involved in such substitution can be solved, at least for products for indoor use. Products for use indoors will usually not be exposed to frost, and in practice they will have a somewhat shorter lifetime than products for outdoor use. Therefore, possibilities should be considered to accelerate development and, for example, exploit the expertise existing in the porcelain and ceramics field in Denmark to develop acceptable alternatives for tiles, bricks and vitrified bricks. 5.8 Electronic componentsLead is used in electronic components, in solder, as a colouring, and in ceramic components. Electronic components are extensively covered by the RoHS Directive (cf. Annex 2). In fact, the RoHS Directive and the ongoing efforts to assess applications for exemptions are setting the pace and direction for substitution work in this field. Although the RoHS Directive focuses on ordinary electronic appliances used in households and the retail trade, primarily the same components are used in all other types of equipment, including industrial, military and other equipment which is today exempt from the RoHS Directive. Annex 2 lists the uses of lead in electronic components which today are exempt from the ban in the RoHS Directive. This list has been updated and it includes the final corrections adopted by the European Commission (cf. [EU 2005]) or recommended by the EU Technical Advisory Committee for the RoHS Directive [Nørlem 2006]. Evaluation 5.9 Other applicationsChemical compounds of lead in products to repair existing products and in products for research, development and laboratory use are exempt from the ban in the Lead Order (cf. section 2). The extent to which restrictions on the use of lead in this context have developed has not been examined. However, it is clear that it will not be possible to stop using lead in chemicals for chemical analysis, for example. Since December 2003 no applications for exemption of lead in lubricating oil have been submitted, and this may be because Danish users and manufacturers do not know the full composition of their raw materials (especially metal additives) and therefore the composition of their own products at substance level. Danish users and manufacturers therefore rely on their foreign suppliers knowing all details of Danish legislation, and experience shows that this is not always the case. However, in general the Danish mineral oils sector considers that lead is no longer intentionally added to lubricating agents, but metal additives can contain lead impurities and thus the final product may also contain small concentrations – probably much less than 100 ppm. The lubricating properties of lead are exploited in a number of alloys, e.g. red brass in taps, and this represents a larger quantity than in lubricants themselves [Olsen, 2005]. On 15 February 2006, the EU Technical Advisory Committee for the RoHS Directive decided to recommend introduction of an exemption for lead in incandescent lamps (defined as: "Lead in linear incandescent lamps with silicate coated tubes") - cf. Annex 2. This exemption covers all uses of lead as a chemical compound and as a metal in the relevant types of incandescent lamp. It is not immediately clear what uses of lead as a chemical compound could be covered by the ban. Evaluation It is recommended that the existing exemptions for products to repair existing products and lead in products for research, development and laboratory use be maintained. With regard to leads as a chemical compound in the types of incandescent lamp mentioned above, consideration is recommended on whether there is a need to introduce an exemption in the Lead Order, given that the use is already covered by the RoHS Directive. If it is decided to introduce an exemption, this should be worded so that it corresponds to the exemption in the RoHS Directive.
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