The Risk Management Tool Box Blog

Registration, Evaluation and Authorisation of Chemicals (REACH)

Graham Marshall - Tuesday, February 19, 2013

The UK manufacturers’ organization - EEF - has called on Britain’s manufacturers to get to grips with the requirements of the European Directive on the restriction of hazardous substances - "Registration, Evaluation and Authorization of Chemicals" - or "REACH" for short.

REACH is the European Community Regulation on chemicals and their safe use.

It entered into force on 1 June 2007 with implementation via staggered deadlines.

But a recent survey shows that awareness of the implications for manufacturers of the REACH regulations, especially amongst smaller companies, remains worryingly low.

REACH is gradually restricting the use of hazardous chemicals, including substances which have been commonly used in manufacturing processes for many years under controlled conditions.

This has major implications for all companies from requirements for worker safety, to controls on how substances are used, through to the need to potentially modify processes and substitute other materials.

There are also major implications for companies in the supply chain who must be in a position to advise their customers if such substances are present in the products they sell.

Where there is a strong enough argument for continued use of a banned substance, companies can apply to the European Commission to continue to use it.

The first such deadline is just a month away.

Furthermore, companies have just six months to make themselves aware of the implications of the next major deadline for registration of chemicals in June 2013.

Failure to comply with the regulations is a criminal offence with the possibility of unlimited fines and, up to two years in prison.

In response, EEF is calling on government to do more to raise awareness of the implications of REACH on businesses.

It is also calling for more user friendly guidance and a clearer understanding of when the Commission is likely to give permission for continued use of banned substances.

For many companies there is the very real risk of lost business if they are unable to advise their suppliers whether their products contain certain materials and, where they are, how their use is being monitored.

Furthermore, if companies don’t plan for substance bans, it could prevent production entirely.

There are currently 21 substances set for bans under the Regulation.

The first suite of bans takes place from February 2015.

Applications to continue to use these substances must be submitted from February or August this year if companies want to avoid business continuity issues.

In December the Commission announced a further suite of substances that will be banned, subject to clearance in the European Parliament.

More bans are expected and there are currently 153 substances on the list.

Any company using any of the substances in quantities greater than 0.1% w/w in the products they sell are required to notify their business customers to ensure its safe handling.

If companies place that substance on the market in quantities greater than a tonne they are also obliged to notify the European Chemicals Agency.

On the 1 June 2013, companies that place substances on the market in quantities between 1,000 and 100 tonnes a year are required to register them.

UK HSE Public Consuiltation on EU Chemicals Legislation

Graham Marshall - Sunday, January 27, 2013

The UK Health and Safety Executive (UK HSE) is holding a public consultation on regulatory measures to support EU chemicals legislation and proposals on reducing seven existing sets of domestic regulations into one statutory instrument.

The UK HSE is consulting on regulatory proposals for measures supporting three directly applicable EU chemicals Regulations on:

1.  Biocidal Products (EU no. 528/2012);

2.  The Export and Import of Hazardous Chemicals (commonly known as the Prior Informed Consent (PIC) Regulation) (EU no. 649/2012); and

3.  Classification, Labelling and Packaging (CLP) of substances and mixtures (EC no. 1272/2008).

The proposals implement a Löfstedt recommendation to consolidate biocides sector legislation, and also to meet EU requirements to establish competent authorities, designated national authorities and enforcement arrangements (as appropriate.

Overall the proposal will reduce seven existing statutory instruments into one.

The UK HSE also proposes to put in place new regulations to enable the UK HSE to charge for the work it carries out under the new Biocides Regulation.

This will, however, be covered in a separate consultation on  the proposed fee regime,  including the fee structure and fee levels.

The UK HSE also seek your views on the possibility of recovering HSE’s costs under CLP, and are further consulting on unrelated administrative amendments to other domestic chemicals regulations.

No changes are proposed to the main duties for Biocides, PIC and CLP, which are, or will be, established at EU level in directly applicable Regulations.

This consultation ends on 31 January 2013.

Responses should be sent to:

Deborah Traynor

Health and Safety Executive
Redgrave Court
Merton Road
Bootle
Liverpool
L20 7HS
Fax: 0151 951 3098

 

Globally Harmonized System 2012

Graham Marshall - Saturday, December 08, 2012

Enclosed here is a link to some important information about the Globally Harmonized System (GHS) for identifying and classifying hazardous substances.  The information was passed on to Risk Tool Box by Matthew Pelletier
Director of Public Relations at CS Safety Training.

If you're in the USA, you should care about this as the US is already transitioning to the GHS in 2012.  European countries and many other regions have already done so.

The objective of the GHS is to standardize the classification rules applicable to hazardous substances, and the rules for labels and Safety Data Sheets.

At the Risk Tool Box, we support the GHS and the attempt to standardize the way chemicals are labeled and classified.

 


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