Want to protect your cement workers from a nasty form of dermatitis? Well, now you can, with the launch of the European chromium VI directive. But where it stops itching the sector’s collective skin, it’ll start hurting pretty badly elsewhere …
The first construction sector to be bound up by European Union red tape in 2005 is the cement industry. The chromium VI directive, which came into force on Monday, requires that cement be treated to protect construction workers from a form of dermatitis caused by the presence of the metal chromium. The cement sector has already spent £10m conforming to the legislation and is set to spend another £28m over the next 10 years as industry comes to terms with the stringent restrictions.
As usual, the cost hikes will be passed on, and it is end users that will bear the brunt. Castle Cement estimates that cement prices will increase 2% as a result of the directive. And this is just the start of a series of major cost increases in 2005. Two other pieces of European regulations and rising energy costs will ratchet up cement prices 15% in the next few months to about £115 per tonne.
As well as cement manufacturers, the requirements of the directive apply to anyone who uses cement in the formulation of other materials such as concrete. It is these users who have yet to grasp the full implications of the directive because of the short timescale between the announcement of the directive and its implementation. Cement manufacturers already have equipment in place to treat cement, but those further down the supply chain are uncertain what measures they will need to take to meet the requirements. “The cement manufacturers are at the easy end of the supply chain,” says David Evans, director of business sustainability at cement manufacturer RMC Rugby. “It is downstream where problems will be more acute.”
Chromium compounds are found naturally in cement’s raw ingredients limestone and clay. When these compounds oxidise they become chromium VI, which causes an allergic reaction in some people. Chromium in cement causes at least 450 cases of allergic contact dermatitis a year according to the Health and Safety Executive. This is a painful itchy skin condition that occurs when workers who are sensitive to chromium come into contact with wet cement (see “Handle with care”, below). It is most likely to affect bricklayers, tile layers and workers laying concrete floors. A regulatory impact assessment estimated that the condition costs the industry up to £48m over a 10-year period.
To eliminate ACD, the EU introduced the chromium VI directive in the Controls of Substances Hazardous to Health (Amendment) Regulations on Monday. This requires that manufacturers of cement or products containing cement reduce the amount of chromium to no more than two parts in a million. This means that the cement manufacturers and formulators of products containing cement must treat the material with a reducing agent, which is commonly ferrous sulphate.
The main costs of implementation are the capital costs of the treatment equipment and the ongoing cost of ferrous sulphate. Two years ago, the regulatory impact assessment costed ferrous sulphate at £100/tonne. Mike Eberlin, commercial director at Castle Cement, says that costs are “substantially higher” now as demand from the cement manufacturers goes up. Under the EU legislation manufacturers will also incur the cost of regularly carrying out tests on their production line to ensure that chromium is being reduced to the legal amount.
The legislation also states that labels on cement products must indicate safe shelf life because the reducing agent is only effective for a limited period. The British Cement Association says that low levels of chromium will be maintained in treated cement for 61 days and RMC Rugby will not give a guarantee beyond two months.
This has serious repercussions for merchants and users further down the supply chain. David Evans says that RMC Rugby will not be able to re-treat any cement that goes beyond its shelf-life date. “It’s not feasible to collect out-of-date cement. We’re relying on customers having good stock control,” he says. Evans reckons most of his customers use cement within two months but other products containing cement, such as packed concrete and mortar products, typically have shelf lives of about six months.
These manufacturers face having to treat their product with ferrous sulphate a second time to ensure the amount of chromium remains within the legal limits. This creates potential problems, as cement-based products with high proportions of ferrous sulphate require more water to make them workable, which could affect their strength. A double dose of ferrous sulphate may also extend setting times.
The cost hikes will be passed on, and End users will bear the brunt. Cement prices will increase 2% as a result of the directive
To understand the effects of reducing agents, the manufacturers have to test samples of dosed cement to see whether it changes the properties of their products. This will take time because the treated cement samples have only recently become available to the formulators.
Steve Miller, head of technology and environment at Hanson Building Products does not think workability will be too much of an issue for packed products such as concrete and mortar, but he has concerns about the late arrival of the cement samples. “There is a degree of estimation about how much ferrous sulphate had to be added to products with six-month shelf lives,” he says. “You can’t prove six-month shelf lives if the new formulation hasn’t existed for six months.”
Miller says that doses would be adjusted depending on the results of tests over the coming months. “We are confident that we won’t be a million miles away, as we can make use of experience gained in Europe.”
The HSE, which is responsible for enforcing the legislation in the UK, is aware of the tight timeframe imposed by the EU and is sympathetic to industry’s concerns. Bill Macdonald, HSE’s spokesperson on skin disease reduction, says the HSE wants urgent action but understands the work involved. “It will take time for all the dosed material to work its way through the supply chain,” he said. “The last thing we want to see is undosed cement coming off the shelves and ending up in landfill. That would be illogical.”
Macdonald says he will look at every case on its individual merits, but warned the HSE would not be offering industry “a blank cheque”. The HSE has formed a joint chromium VI communications task force with the industry to make the implementation as painless as possible.
For the cement industry the directive could not have come at a worse time – two more hefty pieces of EU legislation are looming: the EU Emissions Trading Scheme and the Working Time Directive, which limits the number of hours worked by lorry drivers. Eberlin says the combination of three new pieces of legislation and rises in energy costs will result in an increase in cement of 15% in the next few months.
Evans says the steep price hikes could have been avoided if the EU had listened to the concerns of industry and stagger the introduction of the legislation. Miller says that the directive was implemented too quickly: “The EU didn’t understand the complexity of the packed products industry.” Construction will be hoping that the EU takes the cement industry’s criticisms on board and in future mix their proposals with a higher dose of reality.
Chromium: Handle with care
Allergic contact dermatitis (ACD) is a painful skin condition caused by an allergic reaction to certain materials coming into contact with the skin. Chromium and other allergens, such as nickel and rubber, can cause affected areas to become itchy and either red, swollen and blistered, or dry and bumpy.
Not everyone is sensitive to chromium and the HSE estimates that only 5-10% of construction workers could be susceptible to cement-related ACD. Nevertheless the HSE’s national skin surveillance project EPIDERM said it had evidence that on average chromates in cement caused 43 new cases of allergic dermatitis every year. EPIDERM says the true figure is at least 10 times higher as it believes many workers do not tell their GPs about problems.
An impact assessment estimated that ACD cost society up to £48m over a 10-year period in loss of income and medical treatment. This means that if 66-100% of ACD were prevented, there would be a cost benefit of £32m-48m over 10 years, which is similar to the costs of implementing the legislation.
ACD is distinct from irritant contact dermatitis, in which a similar skin condition is caused by excessive contact with irritants. These include soaps, detergents, solvents, acids, friction and alkalis, which are found in cement. Irritant contact dermatitis may affect anyone and excessive exposure to an irritant such as chromium is likely to lead to dermatitis.
Cement can also cause alkaline burns, and these inherent dangers means that the HSE is calling on workers to continue using protective equipment when handling cement. RMC’s David Evans believes introducing legislation reducing the amount chromium in cement could have been counter protective. He says: “There is a danger that end users will think that with the reduction of chromium, the cement would be safe to handle, but there is still a danger of other problems.”