Cobalt Institute
CI
The Cobalt Institute (CI) is a global non-profit trade association set up by industry representing close to 70% of the world-wide production of cobalt.
ID: 777244615994-94
Lobbying Activity
Response to Europe’s Beating Cancer Plan
2 Mar 2020
The Cobalt Institute (CI) welcomes this opportunity to provide input on the European Commission’s roadmap for “Europe’s Beating Cancer Plan”. The CI represents producers, users, recyclers, and traders of cobalt globally. Cobalt is listed in the EU as a critical raw material for a wide range of key industries and applications, including lithium-ion batteries, medical devices, high-performance tools and industrial catalysts, to name a few.
One important policy linked to beating cancer is effective occupational safety legislation. We support the proposal included in the roadmap to explore options to reduce exposure to carcinogenic substances in the workplace. This should include the introduction of binding occupational exposure limits (BOELs) for carcinogenic substances at the EU level. BOELs under occupational safety legislation should serve as a key instrument to support effective risk management of carcinogenic substances on the workplace, reducing exposure to these substances while creating a level-playing for industry across EU member states.
Occupational safety and health (OSH) legislation is also the best instrument in our view to promote social acceptance of measures designed to ensure the safe use of hazardous substances, thanks to the well-established processes that exist for tripartite discussions with social partners, including industry and trade unions.
The CI fully supports the Employment, Social Policy, Health and Consumer Affairs Council (EPSCO) conclusions on “A New EU Strategic Framework on Health and Safety at Work: Enhancing the implementation of Occupational Safety and Health in the EU” from 10 December 2019, including the objective to “work on identifying further carcinogens and mutagens at the workplace and setting limit values for them” as a high priority.
Moving forward, we strongly encourage the European Commission to continue in its efforts to strengthen the interface between OSH and REACH legislation when it comes to ensuring occupational safety. In the case of cobalt, the CI is advocating for a binding EU OEL value to be set for all cobalt substances under OSH legislation, as the most effective risk management measure to promote the safe use of these critical raw materials. Such an OEL would cover exposure to all forms of cobalt in all EU workplaces. We call on the European Commission, and DG Employment in particular, to act without delay to develop a mandate for such an OEL to be established.
Read full responseResponse to A new Circular Economy Action Plan
20 Jan 2020
Please see the attached file.
Read full responseMeeting with Dominique Ristori (Director-General Energy)
5 Jun 2019 · The role of cobalt in the clean energy transition
Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)
28 May 2019 · industrial policy, climate and the circular economy
Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)
28 May 2019 · Chemicals and Cobalt in particular
Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Rud Pedersen Public Affairs Brussels
28 May 2019 · Climate action and circular economy
8 Feb 2019
The Cobalt Institute (CI) and the Cobalt REACH Consortium (CoRC) represent the manufacturers, producers, users, traders and recyclers of cobalt in the EU (including for REACH matters) and globally, promoting the sustainable and responsible production and use of cobalt in all its forms.
The CI/CoRC are therefore pleased to convey their comments to the public consultation on the proposed harmonised classification and labelling (CLH) for cobalt metal (Co).
Key concerns:- see full response in Annex 1
The Co industry’s concerns about the classification proposal revolve mostly around the carcinogenicity endpoint as follows:
a. We request the correction of the typing error in the Annex A recital (4) for cobalt where ‘RAC proposed to classify that substance as Carcinogen category 1A…’ This should read ‘1B’ instead.
b. We support the classification proposal for Carc. 1B: indeed, as a responsible industry, our members have already self-classified cobalt metal (Co) as a Cat. 1B carcinogen (by inhalation) since 2014.
c. Concentration Limit: Although animal data show that Co has a high carcinogenic potency, there has been no correspondent observation of this high potency in humans. This and the use of a reference database based mainly on oral carcinogens raised questions about the suitability and the applicability of the methodology used to determine a specific concentration limit for cobalt and metal compounds after exposure by the inhalation route. We therefore support the use of the GCL instead of the SCL, and ECHA’s proposal to establish a carcinogenicity expert group to determine whether ‘an update of the CLP guidance is needed to reflect the most appropriate methodology to set SCLs for carcinogenicity potency and its applicability in the CLP context.
d. Bioavailability concept: The GCL alone will not be sufficient to mitigate the consequences for many mixtures impacted by the presence of Co (see further below). Under the current CLP guidance, there is no accounting for bioavailability / bioelution. This is an important area currently under development and the consideration of the bioavailability concept in the CLP would be a key to a permanent solution for many cobalt applications. A recognition of the bioavailability of cobalt contained in matrix forms (e.g. steels and other alloys) should be included in the Co ATP.
e. “All routes” of exposure notation:
Because the text of the CLP Regulation is too rigid and requires the need for ‘conclusive proof’ that each route shows no effect) it leads to an over-conservative ‘by default’ notation for ‘all routes’, which is of concern to a number of downstream users (see below). Meanwhile cobalt is an industrial chemical and the risk is limited to the workplace and mainly to the inhalation route. The Cobalt industry has already implemented the necessary exposure control measures in the workplace following the self-classification in 2014.
Exposure in the workplace is well controlled in the cobalt and hard-metal industry as shown by recent high-quality epidemiology studies on 30 000 workers where no excess lung cancer cases above background levels were observed.
Providing ‘conclusive proof’ that each route of exposure has no effect is also very difficult e.g. conducting new (oral) studies to demonstrate the lack of effect and would raise ethical considerations (animal welfare).
We ask the EU to therefore consider providing more guidance around the CLP regulatory text to reconsider the use of ‘relevant data’ such as epidemiology data, to allow the relevant routes of exposure to be reflected in the classification, rather than ‘by default’.
The consequences of the above aspects are far-reaching and would affect Downstream Users in a variety of key sectors and the Circular Economy . Finding a long-term solution to the aspects highlighted above is crucial in insuring that the EU maintains its ability to achieve its ambitions for the decarbonisation agenda/CE
Read full responseResponse to Sustainability requirements for batteries
6 Feb 2019
The Cobalt Institute (CI) is an international non-profit trade association composed of the major producers, users, recyclers, and traders of cobalt. The CI promotes the sustainable and responsible production and use of cobalt in all its forms. The CI welcomes this opportunity to provide some comments into this consultation on Sustainability requirements for batteries, and considers it is important to emphasise several key points regarding cobalt and the battery value chain, as outlined in the attached two-page Letter prepared by the CI (please refer to pdf file dated 6 Feb 2019). Thank you
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