The Wide Reach of REACH

by francine Hardaway on April 14, 2008

REACH is a new standard and regulatory framework for environmental, health and safety characteristics of any chemical. All manufaturers of substances, all exporters to the EU, all US manufactures of substances, articles, or mixtures are impacted, as are people who buy or use products from the EU.

Awareness of REACH is low outside the EU and the chemicals industry. But failure to meet the terms of this European regulation could lead to a ban on exports to the EU. Period, end of story.

As a result of REACH, some substances will be withdrawn from the supply chain, and are already being withdrawn. REACH impacts chemical use and supply globally. There are opportunities and threats here.

REACH is not just technical, and can’t just be delegated to the HSE department. You have to data for all ingredients and safe use of chemicals pre-manufacture, not pre-marketing. There will be a greater sharing of information on substances in products, preparations, and articles, which will mean you have to share data up and down the supply chain and even with bitter competitors.

Business decisions will feed into technical decisions, and vice versa. And it’s a continuing obligation, not a one-time fix. You will need systems to keep on coping with reach. The goal of these regulations is to achieve a high level of health and environmental protection with the the goal of achieving sustainable development.

REACH stands for Registration, Evaluation, Authorization of Chemicals. It is a single coherent system for new and existing chemcials. Waste and radioactive substances are exempt.

All companies should be pre-registering now. Between June and December you must pre-register all the phase-in substances in intend to use in the future. All people will register the same substance to compile a single data set for that substances, to agree on a classification and labelling. Pre-registering a substance buys you time.

Not only do YOU have to register, but your suppliers must as well or you will lose supply of that substance. You must urge your suppliers to pre-register. Companies could decide to set up a consortium if you are registering the same substance.

It is the responsibility of the registrant to collect information, assess risks, and implement or recommend control measures. But you don’t have to share use information. You must, however, share animal data.

If you source in China, you identify substances subject to registration, pre register yourself or get China to register. Your use of the substance has to be covered when chemicals and substances are imported and exported several times during a manufacturing process. It is complicated. If you are dealing in, say, fire extinguishers, both the case (an article) and the substance inside have to be registered. And if you are importing, you have to check whether the companies who made the product have registered everything, because you are still responsible as the importer!

Bottom line: time is short to understand your supply chain. There are 20,000 pages of guidance on REACH already, so start reading

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