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You will no doubt be aware of the changes to be brought about by EU Directive 2008/58 on the way Cobalt is to be labelled and consequently, with its new hazard level, how it is to be risk assessed.

This 30^th Amendment to 67/548 (Dangerous Substances) brings all 1831 listed sources of Cobalt (Acetate, Carbonate, Chloride and Nitrate) into line with the Sulphate form as a category 2 Carcinogen and category 3 Mutagen. It will be a requirement that all products containing Cobalt at more than 0.01% will have to carry labels with Skull and Crossbones on the packaging. Obviously, this will not only include your raw material but it is likely to include many Ruminant Vitamin/ Mineral Premixes.

Recalling the alarm and reaction to Cobalt Sulphate being given this same Risk Status some years ago, we can anticipate many questions and requests for possible alternatives to be sought from Customers and Employees alike.

Unfortunately, legislation on labelling does not provide for differentiation between product forms that may present a lesser risk; for example low dust products. However, demonstrating that the safest presentation form of that material is in use will help to meet Health and Safety obligations and satisfy customers and employees that risks are being managed.

In a recent trial, we looked at dust emissions from a Ruminant Vitamin/ Mineral Premix utilising two product forms of Cobalt Carbonate. The first batch was produced with the Cobalt requirement coming from a commercially available oiled dilution of Cobalt Carbonate, the second batch (next in the same plant) was identical except that the Cobalt came from BMP Cobalt 5%. Dust was generated and collected using a Stauber Heubach machine and analysed for Cobalt content, both exercises carried out by independent laboratories. Cobalt dust from the batch containing BMP Cobalt 5% was 25% less than that from the batch containing the oiled Cobalt product.

This finding demonstrates that risk assessment cannot be left to a ‘calculation of material in use’ and that the product form should be taken into account.

Dust generation will be affected by many variables such as operating plant, base materials and time. However, we believe that BMP Cobalt 5% will prove the best alternative in all situations and would welcome the opportunity to run comparative tests using your formulations, plant and choice of materials.