Will the use of brass be restricted by the EU?

The amount of new environmental legislation continues to grow.  Stephen Wick, Chairman of Denis Wick and MIA Board member, brings us up-to-date with proposed new legislation which could negatively impact the making of brass instruments, and suggests appropriate action.

The EU imports and manufactures over one million metric tonnes of lead every year, the vast majority of which is used in industrial applications such as car batteries, glass making and so on. It is also used in paint, ceramics, ammunition and other more common products, including the alloys of copper from which brass instruments are made. The EU, through REACH (the EU organisation responsible for the registration, evaluation, authorisation and restriction of chemicals), wants to restrict the use of lead and has three main areas of concern where lead can cause harm. These are

  1. In the environment
  2. In the workplace, especially where workers are handling lead or substances that contain lead
  3. In products where lead can be ingested or otherwise absorbed into the body

New regulations will affect all these three areas. Lead is a Substance of Very High Concern (SVHC). It can have adverse effects on fertility and on the development of children. Exposure to high levels of lead may cause anaemia, weakness, and kidney and brain damage. Very high lead exposure can even cause death. So there is an obvious need to control this potentially dangerous substance.

The danger for the music industry is that new regulations are brought in without proper consultation. The EU is considering making companies who use lead to register for permission to use it.  If this becomes necessary, the registration fee (potentially many thousands of Euros) could be unaffordable for many small firms using alloys such as brass. There is also a danger that in the process of registering, the authorities would simply withhold permission to register, based on their opinion that lead-free alternatives are readily available. This might make sense if we are talking about lead shot in ammunition or other products where alternatives are widely accepted but try explaining that to a trumpet-player who has to adapt to a trumpet made out of lead-free brass. Brass containing small amounts of lead (normally about 2%-3%) has been used for centuries for making brass instruments, and the alternatives do not have the same tonal properties, so brass players would not be happy to be told that they have to seek out some new material for their instruments in the future. Lead-free brass is also largely unsuitable for manufacturing brass instruments as it lacks the malleability needed for processes such as turning and spinning.

If we accept that the very small amounts of lead contained in brass present no danger to the players of brass instruments (absorption rates into the body from playing a brass instrument have been shown to be negligible) then it is important to register this fact with REACH (in the EU) and UK REACH (in the UK) and to make sure that musical instruments made from brass or containing brass are exempted from any potential legislation. It would be sensible if any alloy containing less than 4% lead should also be exempted, as it currently is, in order to ensure a continued supply of these materials. The MIA is working with CAFIM and EMIA in Europe to ensure that we are not suddenly faced with new regulations which extinguish years of manufacturing tradition and will potentially have a negative impact on many musicians. Currently the decision on new REACH regulations for lead have been postponed, but we await their decision.

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