Talk:Humidity indicator card

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I think the author's assessment of the impact of pending EU REACH on the use of Cobalt Dichloride [CoCl₂] desiccants and humidity indicator cards is poorly reasoned and may be based on outdated or incomplete information, mis-understanding or broad interpretation. I also question if commercial motives are at work, but don't assume so.

I offer the following as a counterpoint or supplement to the article.

(1) Under existing law 98/98/EU products containing >0.01% (1000ppm) Cobalt Dichloride are classified as Class 2 Carcinogens, requiring R49/T hazard labeling. This substantially agrees with the author's suggestions. However, how this should be applied is subject to interpretation as noted in (2).

(2) Some suppliers/uses of the Cobalt Dichloride products suggest it is sufficient to include R49/T warnings be included on bulk packages of such products (ie, that the user is the purchaser of the product in bulk) while others suggest each individual unit include R49/T warnings since ultimate users would include any party throughout the life-cycle of the product. Obviously the cradle to grave definition is more narrow, less interpretive and less risky (environmentally and legally).

(3) Furthermore, some suppliers of such products have even claimed HIC products are "exempt" to R49/T labeling since the Cobalt Dichloride is in a stable form which cannot be inhaled. Such statements are even included in sales literature and MSDS sheets. The reasoning is technically questionable since the producer does not control downstream use, and obviously motivated by commercial interests more than precautionary principles. Note the author does not take this position and I do not mean to imply so.

(4) In the current EU REACH legislation, there are significant changes I believe readers of this article should carefully consider:

(a) As of June 2008, the EU has proposed Cobalt Dichloride as one of sixteen substances to be designated SVHCs (Substance or Very High Concern), requiring it be subject to stronger controls and targeted for phase-out. The SVHC list is to confirmed in September 2008 with regulatory effectively from June 2009. The obligations of manufacturers, importers and mid-stream users (ie, anyone up-stream of a customer purchasing an end-use product containing the HIC as packaging) include hazard identification, a hazard information response system as well as oher REACH regulations applied at various levels.

(b) Under REACH definition, HIC can be classified as a "preparation" and "article" (although the second is more reasonable) since the function of product primarily depends on it's chemical properties (reactivity to moisture). While the interpretation of HICs as "preparation" is debatable, the regulations applied to preparations require pre-registration while articles do not. The dissenting opinions to the REACH guidelines by several EU countries (including Denmark and Germany) present considerable risk.

(c) The REACH guidelines clearly establish that packaging materials will be subject to regulations independent to the products they contain, meaning mid-stream users must handle packing materials with due diligence equal to the products they actually manufacture or import. In other words, one must maintain and be prepared to provide safety information for a HIC, and if Cobalt Dichloride is designated a SVHC, comply with the full extent of regulations applicable.

Therefore, users should carefully consider the legal and health risks involved in using Cobalt Dichloride HICs and the alternatives available.

In the interest of full disclosure, I am employed by a company that is a mid-stream user of HICs and we have decided to phase-out Cobalt Chloride products for safer alternatives. We (and I) have no commercial interest, in fact, the phase-out will increase our costs since the alternative products are more expensive and we cannot pass the cost along to our customers.

Other users should decide for themselves, but I suggest careful consideration of risks.

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