Name of org/company: Swedish Chemicals Agency Country: Sweden Applicants’ response: Applicants reply to comments 519 and 520 Contributing third party: KEMI (Swedish Chemical Agency) ECHA consultation numbers: 0012-11 and 0012-12 Reply applicant: It can be a corporate choice to use less performing pigments instead of PY.34 /PR.104 on airports, but the clear bright colours that can be made with these pigments will contribute to safety. Moreover, the longevity of the road marking is certainly a plus, especially on airports. It may be true that in Sweden only white permanent and yellow temporary road marking is used. However, other EU countries like UK and the Netherlands definitely use yellow road marking for long-duration road construction (which may last well over 1 year) or permanent yellow road marking (e.g. to indicate no parking zones). Therefore, longevity of the road marking is an issue. For airfield road markings in the UK specific regulations exist regarding permanent yellow marking. For example, the Runway 08L-26R Rehabilitation Regulation for Gatwick airport prescribes: “The pigment for yellow permanent marking shall be Lead Chromate or a suitable light fast alternative…….” In the Guide to Airfields Pavement Maintenance from the British (Defence Works Functional Standards), Ministry of Defense (page 134) it is stated that in replacing airfield markings in a similar colour as the original one, Requirements of MOD Specification TS10080 should be followed and “…..yellow paint shall contain at least 27% by mass of lead chromate”. Reference Submitter: Alternative: number Type Generic EC CAS Description of technical and date: name alternative and Labelling Ref.No: Affiliation: Please refer to the 467 BehalfOfAnOrganisation confidential attachment Date: Type/Role in the 2014/04/08 supply chain: Industry or trade association Name of org/company: Verband der Mineralfarbenindustrie e. V.
Name of org/company: Swedish Chemicals Agency Country: Sweden Applicants’ response: Applicants reply to comments 519 and 520 Contributing third party: KEMI (Swedish Chemical Agency) ECHA consultation numbers: 0012-11 and 0012-12 Reply applicant: It can be a corporate choice to use less performing pigments instead of PY.34 /PR.104 on airports, but the clear bright colours that can be made with these pigments will contribute to safety. Moreover, the longevity of the road marking is certainly a plus, especially on airports. It may be true that in Sweden only white permanent and yellow temporary road marking is used. However, other EU countries like UK and the Netherlands definitely use yellow road marking for long-duration road construction (which may last well over 1 year) or permanent yellow road marking (e.g. to indicate no parking zones). Therefore, longevity of the road marking is an issue. For airfield road markings in the UK specific regulations exist regarding permanent yellow marking. For example, the Runway 08L-26R Rehabilitation Regulation for Gatwick airport prescribes: “The pigment for yellow permanent marking shall be Lead Chromate or a suitable light fast alternative…….” In the Guide to Airfields Pavement Maintenance from the British (Defence Works Functional Standards), Ministry of Defense (page 134) it is stated that in replacing airfield markings in a similar colour as the original one, Requirements of MOD Specification TS10080 should be followed and “…..yellow paint shall contain at least 27% by mass of lead chromate”. Reference number and date: Submitter: Alternative: Type Generic name EC CAS Description of technical alternative and Labelling Ref.No: 467 Date: 2014/04/08 Affiliation: BehalfOfAnOrganisation Type/Role in the supply chain: Industry or trade association Name of org/company: Verband der Mineralfarbenindustrie e. V. Please refer to the attachment confidential
a4a_comment_response_88_0012-11_attachment_en.docx