Comment onRAC Pb Env Clas consultation

WVMetalle would like to give comments on the questions mandated to RAC to review the opinion of 30 November 2018 in relation to the environmental classification of lead metal which concluded that this substance should be classified as Aquatic Acute 1, H400; M=1 and Aquatic Chronic 1, H410; M=10. WVMetalle especially is of the opinion that the same classifications for powder and massive forms of lead is not justified.

In general, WVMetalle plea for using all available high-quality information, including the latest update of the lead- and lead compounds registration dossiers. In addition, applying the metal specific guidance as it stands will ensure consistency with other metal dossiers previously assessed for their environmental classification. Taken together, this indicates that a chronic environmental classification of lead metal in massive form is not required.

For further information please see the attached document.

 

Gesamtverband der Deutschen Buntmetallindustrie (GDB) Gesamtverband der Aluminiumindustrie e.V. Bundesverband der Deutschen Gießerei-Industrie BDG WVM plus WVM plus Die Energieintensiven Industrien in Deutschland Metalle pro Klima