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DOES REACH APPLY TO YOU?

With REACH, the burden of proof in demonstrating adequate control of the potential risks from the use of chemicals falls on industry rather than the Authorities. Members of the chemical industry primarily impacted by the scope of REACH include:

• Manufacturers (M): produce substances
• Importers (I): import substances from non-EU countries
• Downstream users (DUs): make articles using chemicals or use chemicals professionally.

  A single company may have more than one role under REACH, consequently it is of the utmost importance to understand how REACH applies to each chemical, either manufactured or used by your company.

  
  Manufacturers & Importers (M/I):

• Must register each substance manufactured or imported within the EU in quantities of 1 tonne per annum (tpa) per M/I.
• Must communicate information down the supply chain.

  
  Downstream users:

• Must ensure their uses are covered in the exposure scenario of the Safety Data Sheet (SDS) communicated to them.
• Must implement the risk management measures (RMMs) assigned for the chemicals they use.
• Must communicate information up and down the supply chain.

  
  There is a general obligation for M/I of substances to submit a registration to the European Chemicals Agency (ECA) for each substance manufactured/imported in quantities of 1 tpa.
  
  All phase-in (existing) substances must be pre-registered 12-18 months after entry into force (eif) of REACH. This is by end of 2008

  The volume of data required and the deadlines for submission are dependent on the tonnage and level of risk of the substance manufactured or imported per year.

  WHAT NEEDS TO BE DONE NOW?

  The first step is to determine if your business imports, manufactures or uses chemicals that will be covered by REACH:

• Prepare an inventory of all substances, their suppliers, customers and uses.
• Estimate the annual tonnage per chemical.
• Determine your position in the supply chain for each chemical (M/I/DU).
• Identify substances exempt from REACH and those falling within scope.
• Check the classification of each chemical.
• Check for restricted chemicals.
• Check for substances of very high concern that may need to be substituted in case of future banning.

  Remember that most of the information will be floating round somewhere within your organisation – you may to get a new  butterfly net to catch it though.  We can help at various stages now and in the future

  REACH is not a super COSHH although some information is common the scope is larger and the interpretation  will be different

  As you can see we all need a new dictionary of acronyms to read and understand what is being issued in the new REACH Code  

  AS ALWAYS PLEASE CONTACT ME IF YOU REQUIRE FURTHER INFORMATION OR ASSISTANCE WITH THIS ON ANY OTHER MATTER

  

  

  EFFICIENT, COST EFFECTIVE; HEALTH, SAFETY AND ENVIRONMENTAL MANAGEMENT SOLUTIONS.