A spontaneous update to the lead registration of manganese metal has been submitted to ECHA on 21st September 2021. The reason for the update was to ensure that the information on use and exposure in the CSR is representative of today’s supply chain activities and aligns with post 2010 ECHA guidance.

Background

It recently became clear that the 2010 life cycle tree and chemical safety report (CSR) for the manganese metal registration under the REACH Regulation, did not accurately reflect the current situation. Therefore, the Manganese REACH Administration (MARA) and Exponent as the lead registrant instigated a series of interviews with relevant organisations in the manganese metal business from within the Consortium covering the entire supply chain – mining, smelting and trading.

Following on from these interviews, a questionnaire was sent to all SIEF members in order increase the information pool with regards to uses and exposure. Based on the responses from the questionnairs and the interviews,  a revised understanding of the manganese metal processes, uses and exposure patterns was obtained and used as a basis for the CSR update.

In terms of REACH registration, manganese metal also includes the alloys of manganese (i.e. ferromanganese and silicomanganese). However, other manganese compounds (e.g. manganese sulphate, manganese oxide etc.) are registered separately and hence are not considered in the CSR. Similarly, by-products of the manganese-making process, such as ferromanganese slag and silicomanganese slag, are also registered separately and do not require further assessment as part of the manganese metal lifecycle.

 

Uses covered: The life-cycle stages covered are as follows:

Manufacture: Manufacture of FeMn and SiMn alloy; Mn metal

Formulation: 

Uses at industrial sites: Industrial production of steel - bulk, Industrial production of other metal articles - bulk, Industrial production of metal articles - small scale in specialist foundries

Use in the production of manganese sulphide

Industrial use in battery production

Uses by professional workers

Professional production of metal articles

Consumer uses

Consumer production of metal articles

Article service life

Service life of metal articles (industrial)

Service life of metal articles (professional)

Service life of metal articles (consumer)

Service life in welding, soldering and brazing applications by professionals

Service life of batteries by professional workers

Please note that you do not need to submit a CSR if you do not supply >10tpa in the EU market. Therefore, if you bought an LoA for Mn at >10tpa please request your updated CSR from reach@manganese.orgRegistrants receiving the CSR should check it carefully to ensure that their use of the substances falls within the scope of the exposure scenarios provided for these life-cycle stages.  They should add their  own specific details as indicated by XXXX in the CSR document.

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