20. Vehicle engines and engine compartments
D. Vehicles
The vehicle warnings link the industrial formation pathway with the automotive maintenance sector. describes formation on hot surfaces of chromium-containing exhaust components. names contamination actually detected, expressly addresses work in the engine compartment of all models and, in addition to inhalation, also takes into account skin contact and hand-to-mouth transfer. The two documents do not name a conclusive speciation as calcium or sodium chromate. [22, 23]
Specific automotive application: Morgan Superwool Plus Heat Shield
In its 09/2019 data sheet, Morgan expressly promotes Superwool Plus Heat Shield for vehicle heat shields subject to vibration. It is a flexible calcium/magnesium silicate fibre mat, not a rigid calcium silicate board. The sheet states the following oxide composition and service temperatures. [48]
| Information in the product data sheet | Value |
|---|---|
| SiO₂ | 62-68 % |
| CaO | 26-32 % |
| MgO | 3-7 % |
| Hot surface, continuous operation | 750 °C |
| Hot surface, short-term peak | 850 °C |
The safety section deals with biopersistence and fibre classification; a chromate warning is absent. The sheet's availability table names Europe. [48]
Morgan's system page describes Superwool Plus as an insulation option within stainless steel encapsulations. The applications named are catalytic converters, passenger car exhaust manifolds, turbo applications in off-road vehicles and exhaust manifolds in shipping/power generation. Austenitic and ferritic stainless steels, among others, are named as encapsulation materials. [49]
The targeted marketing of a calcium-containing insulation material for automotive hot component applications is thus documented. Fibre chemistry, chromium-containing contact/encapsulation surface and thermal stress must be assessed together. The content stated as CaO is an indication of a hazard; its reaction availability must be examined in the specific assembly. Exoneration of the original fibre does not cover subsequent formation of hazardous substances. The interface pathway demonstrated in section 10 gives rise to a specific question of compatibility and information. [11, 48, 49]
Consequences for vehicles
In the case of a vehicle demonstrably contaminated with Cr(VI), the hazardous substance finding is at the same time a characteristic of the vehicle and its components. It concerns safe handling, maintenance, reuse of components and the cost of any necessary remedy. This gives rise to a separate question regarding product condition and vehicle valuation. The available OEM warnings and surface findings provide a specific technical starting point for this. [5, 22, 23]
Which consequences for the vehicle must be recorded
| Area | Specific consequence for the vehicle | Verifiable basis |
|---|---|---|
| Maintenance and handling | Residues that can be touched or released during work may require special working procedures; roadside assistance and intended owner activities may also be affected. | Component- and activity-related findings, accessibility, release and manufacturer instructions. Contamination of the engine compartment must be recorded separately from contamination of the passenger compartment. |
| Remedy and recurrence | Decontamination, where applicable replacement of contaminated insulation elements and modification of the reactive contact. Recurring contamination may cause repeated expenditure. | Scope and cost of the work; verification of effectiveness and findings after renewed thermal operation. |
| Costs and vehicle value | Additional maintenance/disposal costs, downtime and, where applicable, residual loss in value despite remedy. | Invoices, documented restrictions of use and expert valuation. A flat-rate reduction in value based solely on the name of the substance is not a reliable quantification. |
| Owner and market information | Information on affected versions, relevant activities, protection and remedy; transmission to independent workshops, used car buyers and fleet operators. | Dated warnings, their actual distribution and allocation of the affected vehicle and component versions. |
A technically functional engine does not conclusively answer the question of safe handling and normal maintenance conditions. Likewise, a warning to authorised workshops must be assessed separately from whether owners, independent repairers and subsequent purchasers receive the necessary information. The specific activity is decisive: opening the bonnet, topping up fluids or roadside assistance must be examined with regard to the contaminated areas actually accessible; exposure during each of these activities is not presumed.
A lasting technical remedy must deal with existing contamination and the cause of possible re-formation together. If the reactive material combination remains, the effectiveness of a one-off cleaning must also be examined after renewed operation. Chromate may form only during use, even though the material/contact configuration decisive for this was already present at delivery. For attribution, the production status, thermal stress and subsequent modifications must be recorded. [11, 22, 23, 26, 38]
Legal points of reference in the EU
| Line of enquiry | EU |
|---|---|
| Vehicle as object of purchase | In consumer sales, expected safety and normal fitness for use form part of conformity with the contract. In the event of non-conformity, repair/replacement and, subject to the respective conditions, price reduction or termination of the contract come into consideration. [46] |
| Safety and regulatory measures | Vehicle Regulation 2018/858 governs remedial action and information in the event of non-conformity or serious risk. Classifying a chromate-contaminated vehicle type requires a specific risk assessment. [47] |
The EU consumer sales rules concern claims against the seller under national transposition; Art. 7, 10 and 13 of Directive 2019/771 link safety requirements with the time of delivery, the liability period and remedies. For corporate and public authority fleets, by contrast, the respective procurement/purchase contracts and national rules on defects must be applied. A material cause at the supplier does not cancel out the assessment of the vehicle sold as a whole. [46]
Art. 14 of Regulation 2018/858 is a specific starting point for examining the measures required of the manufacturer. Whether a specific Cr(VI) constellation is to be classified as non-conformity or serious risk is the assessment question to be addressed. [47]
A substantiated vehicle defect and the costs of remedying it open up an economic line of enquiry. A cancer diagnosis is not a prerequisite for claims for defects under sales law. Regulatory measures under Regulation 2018/858 are governed by its criteria. [46, 47]
Sources cited in this section
- 5.Passeron, J.; Maisant, S.; Patrascu, C. et al.: Évaluation par mesures atmosphériques, surfaciques et biologiques de l’exposition professionnelle au chrome VI via une équipe référente en toxicologie en SPST. Références en Santé au Travail, TF 329, September 2025. Submitted study
- 11.Sayano, A.; Kanno, H.; Inagaki, S.; Takahashi, M.; Yoshida, M.: The formation of Cr(VI) compound at the interface between metal and heat-insulating material and the approach to prevent the formation by sol-gel process. Journal of the Ceramic Society of Japan 2015, 123, 677-684. DOI: 10.2109/jcersj2.123.677. Submitted study
- 22.: Service Information: Work on component parts conducting exhaust gas with chrome(VI). , 7 August 2025. Submitted service information, one page.Available to the author, not publicly retrievable.
- 23.: Chromium VI Safety Information. Aftersales Bulletin , 27 August 2025, three pages. Submitted version; internal marking SECRET.Available to the author, not publicly retrievable.
- 26.Toshiba Corp.: Thermal apparatus structural member, and method of manufacturing the same. JP2011232021A, priority 8 April 2010, published 17 November 2011; description, prior art and prevention approach. Japanese patent family; English machine translation on Google Patents. Submitted translation additionally checked against the Japanese original, in particular Example 1 and the comparative examples.
- 38.Toshiba Corp.: Thermal equipment structure, JP2012220174A; priority 14 April 2011, published 12 November 2012. Submitted English machine translation. Experimental passages checked against the Japanese granted version JP5774355B2, 9 September 2015. In particular Example 1 and Comparative Example 1.
- 46.Directive (EU) 2019/771 on certain aspects concerning contracts for the sale of goods; consolidated version of 31 July 2026. Art. 7, 10, 13 and 14: safety, liability and remedies in consumer sales. Evaluated: officially indexed EUR-Lex passages; national transposition and specific conditions for claims to be assigned separately.
- 47.Regulation (EU) 2018/858 on the approval and market surveillance of motor vehicles; consolidated version of 2 August 2026. In particular Art. 13/14: manufacturers' obligations, non-conformity and serious risk. Evaluated: officially indexed EUR-Lex passages; no Cr(VI)-specific case decision.
- 48.Morgan Advanced Materials / Thermal Ceramics: Superwool Plus Heat Shield, Product Data Sheet, 09/2019, three pages. In particular pages 1-2: automotive application, oxide composition, hot surface temperatures and presentation of fibre safety; page 3: European availability table.
- 49.Morgan Thermal Ceramics: Heat Shields: Transportation & Industrial Heat Shield, official system page, accessed 7 October 2026. Shell Technology and Integrated Technology: Superwool Plus, stainless steel encapsulation and expressly named automotive hot component applications.