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Frequently asked questions

Below you can find different questions, when clicked on a question the answer appears beneath it.


Chromium 3 passivation

Will this change the prices that I'm paying now?

At Tri-Sure®, we believe this change is part of our drive to acting responsibly, reinforcing our brand values of protecting the environment and creating a safe workplace. We will endeavor to offset the higher costs with operational improvements, so the customer will not be penalized with higher costs.

Will the data sheets change with the introduction of CR3? What about the PDS declaration?

New data sheets will be available shortly.

Will the CR3 passivation perform equally well on flange curling and plug threading / unthreading?

Following extensive performance tests, we have concluded that our CR3 products perform equal or better than its CR6 counterpart.

Will lacquers adhere to CR3 as well as on CR6?

Tri-Sure® has conducted numerous production runs of various product types, and we confirm the lacquer adherence on the CR3 product is equal to CR6 product.

Will I have to go through homologation / UN approvals again?

As there are no mechanical or material changes to the product construction, new homologation / UN approvals are NOT needed.

Why has Tri-sure decided to switch from chromium 6 plating to chromium 3 plating?

Protecting the environment worldwide is a central brand value for Tri-Sure® and we applied our full technical expertise in order to implement this positive change ahead of the coming legislations.

Why has the color of the plugs/flanges changed?

With the improved CR3 passivation, the platinum finish provides better corrosion resistance than the gold finish. The color variation also helps to differentiate CR3 product from the CR6 product. However, it is important to note that not every platinum or silvery finish employs the advanced CR3 process, as some competitor products apply a similar appearance without the advanced CR3 process.

Why didn’t you add a gold colorant to the Cr3 passivation to make the change less visible?

Adding a yellow colorant to the new Cr3 to give it a “gold look” is not an option. Since the passivation layer is a very thin layer over the zinc, adding colorant to this layer would make it porous. This would then have a negative effect on the corrosion resistance of the product.

Why did the passivation color change from a gold color to a platinum color?

This color change is due to reflection; the reflection of Cr6 is a gold color and that of Cr3 is platinum.

What if my customers prefer the yellow passivation?

As we roll out globally with this transition, CR6 product with yellow passivation will no longer be available. We decided against the option of adding a colorant to the CR3 process to retain the gold finish, as this would reduce the corrosion resistance performance.

What are the regulations restricting CR6 passivation, and when do they come into effect?

Regulations banning CR6 already exist in the United States and European Union, and will come into full effect in the coming years (2015 through 2017).

Is this change happening worldwide?

Starting with our plant in Amsterdam, Netherlands, this new process will be implemented throughout our sites in Brazil, India, and China during the 2014 calendar year.

Is this an overnight switch? Will I receive mixed deliveries of CR3 and CR6 product?

During implementation at each Tri-Sure® plant, the transition will take place within a matter of days. However, there will be carried over inventory of yellow passivation products, and these will continued to be shipped. Mixing of products cannot be prevented during the changeover period, which is expected to take several months.

Is this a cost reduction measure?

CR3 passivation is an improvement which brings environmental and performance benefits.The precise process controls required and the chemicals used actually result in higher costs in production.

I thought the closures were zinc plated for rust protection, so why is there a chromium passivation and what does it do?

The Chromium passivation is a thin protective layer on top of the zinc plating, which prevents early oxidation of zinc in the form of white rust.

How will my customers (drum users) be effected by this change?

Besides the minor color variation, they will feel no difference in structural integrity or corrosion protection.

How long will CR3 and CR6 products be mixed in my shipments?

Length of time for mixed shipments will depend on the source factory and the total supply chain, but we expect the process to be completed during year 2014. Tri-Sure® will adhere to strict FIFO principles in order to shorten this transition period.

How is this process more environmentally friendly?

With prolonged exposure, CR6 is proven to be carcinogenic and harmful to human health.The shift to CR3 ensures a cleaner production process and less end-of-life impact on the earth.

How does the CR3 product achieve its superior anti-rust performance?

Our development team spent considerable time to fine-tune the total plating process, as CR3 passivation requires a high level of process control. The resulting layer of protection on the closure offers superior anti-rust performance

How does the CR3 drop test performance compare with CR6 product?

Drop test performance remains the same as our yellow passivation products since this is not a design change.

How does the corrosion resistance of CR3 product compare with the CR6 product?

The corrosion resistance for our CR3 product exceeds Tri-Sure® standards and offers industry leading protection.

How can we tell if the product I have is CR3 or CR6?

Tri-Sure® CR3 products have a new platinum finish, which looks different from the gold finish of our CR6 products. In addition, CR3 products feature a green label on the box to clearly differentiate from the white label of CR6 products.

How can we explain to our customers that this change does not require new homologation tests?

New homologation / UN approvals are only required for change of product design or input material, which does not apply in this case.

Does the Cr3 lacquered product looks different?

The lacquered products will result in a smooth uniform appearance, most notably with the transparent lacquers.

Do you recommend any change of setting in our insertion process with the CR3 product? Lubrication, die parts, press settings, etc.?

Our recommendation is to maintain the same settings in the insertion process using the same die parts, as there is no change to the design. In case of any questions, please contact our service department for support.

Can I expect the same or longer delivery lead time?

Your delivery lead times will not be impacted by our transition to CR3 passivation on the zinc plating process.

Are there differences on chemical resistance performance?

In our laboratory tests, the chemical resistance and compatibility of CR3 products are identical to CR6 products.

Are the CR3 lacquered products food grade compliant? Can you provide a declaration to this effect?

Both Cr6 and/or Cr3 Zinc plated components are NOT food grade compliant. Please refer to our product data sheet, available from your local Tri-Sure® representative.

Are any other manufacturers also doing this change?

Currently, we are not aware of any other steel closure manufacturers pursuing this improvement. However, we do expect them to follow in time due to coming regulatory requirements.

Coatings - lacquers / linings

What type of RDL® Lacquer do I need?

Two main types of drum closure lacquers (linings) are generally used; Epoxy Phenolic and pure Phenolic. 
In pure Phenolic lacquers the binder is a phenolic resin. 
In Epoxy Phenolic Lacquers it is usually a blend of 70% epoxy and 30% phenolic resin. Blending with Epoxy the flexibility of the lacquer and results in an optimal balance of mechanical and chemical performance. 
The RDL®, Regular Drum Lining, System offers a range of standard lacquers that adequately covers 80% of all customer needs. For the remaining 20% the system offers specialized and certified solutions. Choosing the best Lacquer for the closure/package is for specialists, through our worldwide database you may benefit from our vast experience in the field of specialized drum linings. Our engineers and researchers will ensure that the most suitable closure is recommended for a product.  Read more here in our guide for Packaging Advise.

Are Tri-Sure® RDL® lacquers FDA compliant?

The ingredients used of which the following Standard RDL® lacquers for Tri-Sure® Closures are made, meet the FDA-specification and requirements as described in paragraph and section: F175.300 for "Resinous and polymeric coatings" : 
RDL®05 - RDL®06 - RDL®16 - RDL®29 - RDL®36 - RDL®39 - RDL®44 - RDL®50 and RDL®55 
Read more about lacquers in our guide for Packaging Advice.

Directives - certificates - standards

Which UN regulations are applicable for the transport of dangerous goods?

The United Nations Model Regulations on the 
Transport of Dangerous Goods provide a basis for
the development of harmonized regulations for all
modes of transport, in order to facilitate trade and
the safe, efficient transport of hazardous materials. 

Responsibility for Classification:
The shipper is responsible for correct classification, packing, marking and declaration of the dangerous goods in accordance with the prevailing national and international regulations.

Responsibility – User:
It is the responsibility of the user, not the container manufacturer, to determine the proper package specification for each shipment.  The user may request a certificate of compliance from the manufacturer to demonstrate that each container conforms to the UN performance testing provisions. 

The UN Model Regulations cover all aspects of transportation necessary to provide international uniformity. They include a comprehensive criteria based classification system for substances that pose a significant hazard in transportation. Hazards addressed include explosiveness, flammability, toxicity (oral, dermal and inhalation), corrosivity to human tissue and metal, reactivity (e.g., oxidizing materials, self reactive materials, pyrophoric substances, substances that react with water), radioactivity, infectious substance hazards and environmental hazards. They prescribe standards for packagings and multimodal tanks used to transport hazardous materials. They also include a system of communicating the hazards of substances in transport through hazard communication requirements which cover labelling and marking of packages, placarding of tanks, freight containers and vehicles, and documentation and emergency response information that is required to accompany each shipment.

Legislation in the EU:

ADR, European Agreement regarding the International Carriage of Dangerous Goods by Road.
RID, European Agreement regarding the International Carriage of Dangerous Goods by Rail.
AND, European Agreement regarding the International Carriage of Dangerous Goods by Inland waterways.

Legislation in the USA:

Hazardous Materials Regulation of the Department of Transportation (DOT), the only packaging legislation in existence for air, road, rail and waterways.

Legislations Worldwide:

IMDG Code, for Transport of Dangerous Goods by Sea.

ICAO, the packaging legislation by air Annex 18 of the Convention on International Civil Aviation ("Safe Transport of Dangerous Goods by Air"). This legislation is used by different airlines to add their specific requirements, resulting in the IATA Dangerous Goods Regulations. 

What is the objective of the Montreal Environment Protocol?

The basic objective of the protocol is to protect the ozone layer by taking measures leading to total elimination of global emissions of ozone-depleting substances (ODS) on the basis of developments in scientific knowledge; taking into account technical and economic considerations and the needs of developing countries. Each Party shall ensure that for fixed periods its calculated level of consumption of the controlled substances in the Groups of the Annexes does not exceed a certain percentage of its calculated level of consumption in 1986.

What is Azodicarbonamide and Semicarbazide?

Azodicarbonamide is widely used in the production of foamed plastics and the manufacture of gaskets. The European Food Safety Authority (EFSA) publishes further evaluation on semicarbazide in food. A new opinioun has been adopted on the occurrence and risks associated with the chemical substance semicarbazide (SEM/ADC) in food. This follows earlier advice issued in 2003.

Are the compliances as mentioned in the EU directives and FDA regulations the same when it comes to products and articles intended to come into contact with food?

Tri-Sure Closures components which can be in direct contact with food have to comply with the applicable regulations on migration of chemical substances into food.  However there is some overlap in the two; these regulations in a worldwide perspective can be regional (as in the European Union) or national (as in de USA).

EU Directive regarding Food contact:
EU directive on food contact include containers and closures. That means the container including the closure needs to comply with the EU directives on food contact EC1935 / 2004   

The following EU Regulations are relevant when considering compliance 
on possible migration into food products:

- EC No.1935/2004 (Framework Directive)
- 2023/2006/EC (Good Manufacturing Practice)
- 2002/72/EC (Plastic Materials)
- 1895/2005/EC (Coatings)
- 372/2007/EC (Plasticisers in gaskets in lids)

EC No. 1935/2004 is the umbrella Directive for migration.

2023/2006/EC is dealing with Good Manufacturing Practice (GMP) and is relevant when components are manufactured from materials that will come into contact with food. Tri-Sure Closures has to manufacture its products (coatings, plastic closures) according to this Directive. Also the suppliers have to manufacture their products according to this Directive.

2002/72/EC (with its amendments) is dealing with migration from plastic materials.

1895/2005/EC is dealing with coatings, but is restricted to some specific substances (BADGE, BFDGE and NOGE).

372/2007/EC is dealing with specific plasticisers, but is also covered by the 4th amendment of 2002/72/EC (2007/19/EC).

As there are no regulations for rubber and only limited regulation for coatings, reference is often made to the following Resolutions of the European Council:
- Res (AP) 2004-4 (rubbers)
- Res (AP) 2004-1 (coatings)

It is noted that 2002/72/EG will be replaced by a new regulation EU no. 10/2011, which will also incorporate several other Directives and will be operative as from May 1, 2011 with a transitional period until January 1, 2016, when all compliance documents must be based on this new Regulation.

It is noted that there can be additional requirements on migration into food in individual member states of the European Union.

FDA Regulation regarding Food contact:
The US regulations on food contact include components and materials that will come into contact with food. This means that the container and closure needs to comply with the US FDA (Food and Drug Administration). The following FDA Regulations are relevant 
for the Tri-Sure Closures components when considering compliance on possible migration into food products: Code of Federal Regulations Title 21 (CFR 21). Although the jurisdiction of the FDA is restricted to the United States, FDA regulations are commonly adopted as international control standards. Through its Codes of Federal Regulations the FDA promulgates a list of materials and chemicals that are approved for contact with foodstuffs or intended for articles with repeated use. 

Metal closures

Packaging - Packaging law

Plugs - Closures components

Safety and environment

Does Tri-Sure® add substances or use manufacturing processes that require registration of any of the products under the REACH legislation?

On June 1st, 2007 the European Union’s Regulation EC 1907/2006 on the Registration, Evaluation, Authorisation and restriction of Chemicals (“REACH”) came into force. This EC Regulation applies to the whole value chain of the industry.

As Tri-Sure® we do not add substances or use manufacturing processes in our business that requires us to pre-register nor to register any of our products under the REACH legislation. If any, the registration requirement is imposed on our suppliers.

We assure that the chemical substances we use to manufacture our closures and packaging accessories are dealt with in accordance with the legislation. As part of our procedure we approach our suppliers, enquiring about their REACH compliance.

For more detailed information regarding our compliance to “REACH” we would like to refer to our Declaration on REACH – regulation EC 1907/2006 (Article 33) which can be made available from your local sales representative. 

  

More info at: http://echa.europa.eu/regulations/reach

What type of Tri-Sure® plug wrench or adaptor do I need for high risk flammable environments (drum filling in areas with increased explosion risk)?

You will need to use a plug wrench or an wrench adaptors made out of non- sparking material. Tri-Sure® Closure Systems has these ATEX certified spark free wrenches and adaptors available. 

For details please contact your nearest Tri-Sure® Sales & Support center . 

Tooling

Venting

Washers - Gaskets