LOCAL - NATIONAL - INTERNATIONAL
RISK ASSESSMENTS, HAZOP - FMEA- ETA- HRA STUDIES, 5s, HEALTH SAFETY ENVIRONMENTAL MANAGEMENT SYSTEM- FORMULATION- INTEGRATION- DOCUMENTATION- SUPPORT, AUDITS, EDUCATION AND TRAINING, OCCUPATIONAL EXPOSURE MEASUREMENT, CONTROL FORMULATION, LOCAL EXHAUST VENTILATION TESTING AND EXAMINATION.
NEWS
WEEE
TWO YEARS after being announced, regulations requiring electrical and electronic equipment producers to assume responsibility for recycling old equipment came into force on 2 January.
Under the WEEE legislation producers and importers of electrical and electronic goods will. from July have to meet the environmental costs of dealing with waste products.
The nature of the revised fee structure from the DTI, which is much improved from the original proposals. Small businesses are often disproportionately affected by both the administration and direct costs of legislation.
WEEE will present significant financial, operational and administrative challenges for all businesses affected by the regulations.
The regulations apply to electrical and electronic equipment (EEE) which falls within the 10 product categories listed in the WEEE directive: large household appliances; small household appliances; IT and telecommunications equipment; consumer equipment; lighting equipment; electrical and electronic tools; toys, leisure and sports equipment; medical devices; monitoring and control instruments; and automatic dispensers.
The WEEE regulations will apply to the following groups: producers (any business that manufactures imports or rebrands electrical and electronic products); retailers and distributors (any business that sells electrical and electronic equipment to end users);
local authorities; waste management industry; exporters and reprocessors; and businesses and other non-household users of EEE.
The cost of joining the DTS for those retailers with a smaller WEEE retail obligation will be a small fixed fee based upon their EEE turnover.
By registering with Valpak, members can quickly and simply comply with their company's obligations under the WEEE regulations.
As a member of the retail scheme, there will be no need to provide one-for-one, like-for-like take-back of WEEE, organise storage of waste electronics on site, or contract with a waste disposal company to remove it to a designated collection facility.
The current fee for small retailers with EEE turnover of less than £100,000 is £200 plus VAT.
POLLUTER PAYS
Government has recently issued a consultation document for implementing the Environmental Liability Directive. The directive strengthens the `polluter pays' principle for environmental damage caused by biodiversity, water and land contamination that threatens human health.
Under the Directive, companies that threaten or cause environmental damage will be held strictly liable for prevention of fixing the damage at their own expense. It will apply to damage occurring from 30 April 2007.
The document can be found at www.defra.gov.uklcorporate/consult/envliability/index.htm. Though the initial deadline for responses is 16 February 2007, a second consultation on draft legislation is likely to take place in the Spring.
THE REACH (Registration, Evaluation and Authorisation of Chemicals) regulation is due to come into force in June 2007. All manufacturers, importers and downstream users of chemicals must be fully aware of the impact this new legislation will have on their business.
REACH has one simple aim: to protect human health and the environment from the risks arising from the use of chemicals.
However, this goal has proved very difficult to achieve, and REACH has become one of the most complex and far-reaching pieces legislation ever to come out of Brussels.
Under the regulations, businesses will be required to fully ascertain and make public risks posed by the use of chemicals. For certain substances, this means that a company will have to define in detail, exactly how to safely use the chemical.
The Health and Safety Executive has be-asked to take on the role of competent authority.
It has set up a help desk in the run-up to REACH; telephone 0845 408 9575 or visit www.hse.gov.uk/chemicals.
You should also visit www.reachreadyco.uk for advice on what you need to do - if anything - to comply. `Thousands of organizations will be affected by these regulations. If a company uses chemical for their manufacturing process, as a cleaning. agent, or for printing purposes for example, it will have to make sure the chemical is listed.'
The REACHready website warns: `If you make or import a chemical substance, REACH is likely, to be one of the biggest programmes of work you will have to undertake over the next 11 years.
What is REACH?
The European Commission has proposed a new EU Chemicals Policy called REACH which is short for the Registration, Evaluation, and Authorisation of Chemicals. REACH will replace in a single regulation current EU legislation for supply of chemicals to the EU market. Current EU legislation to be replaced consists of the Existing Substances Regulation (ESR), the Notification of New Substances (NONS) and the Marketing and Use Directive. The proposal has passed through several legislative stages and is currently awaiting a second reading in the European Parliament. It is expected to come into force in April 2007.
The new system includes:
o Registration of chemical substances manufactured or imported and associated requirements for information and communication in the supply chain;
o Evaluation of the information supplied and safety in use of selected substances by Member States (MSs);
o Authorisation for CHemicals of high concern, based on health (e.g. carcinogens and mutagens) or environmental hazards (e.g. persistent and bio accumulative);
o Restrictions at EU-level triggered by other concerns; and
o A centralised European agency (in Helsinki) to manage the system.
REACH introduces some fundamental changes from the current legislation. There is a new responsibility for manufacturing companies (and those importing into the EU) to demonstrate that the substances they produce can be used safely both on their own premises and by their customers (called `Downstream Users' or DUs), throughout the entire life cycle of the substance. The principle is `no data, no market'
One of the main objectives of the new legislation is that dangerous substances (manufactured or imported in quantities above a certain tonnage) will have to be used under demonstrated safe conditions for workers, consumers and the environment. This requires a chemical safety report (CSR) to be prepared and identification of appropriate Risk Management Measures (RMM) by the manufacturer or importer (M/I). Hazard assessment of the chemical and identification of Exposure Scenarios (ES) are essential elements in
complying with these requirements. For REACH the term `Exposure Scenario' is currently defined as "the set of conditions that describe how the substance is manufactured or used during its lifecycle and how the manufacturer or importer controls, or recommends downstream users to control, exposures of humans and the environment". The ES in essence contains practical handling guidance for the substance.
A number of REACH Implementation Projects (RIPs) are currently underway and through one of these the Commission is developing the general framework of ESs and guidance on the implementation in practice. This requires an interaction between M/Is and downstream users (DUs) to understand in full how the substance under consideration is used and what RMMs are, or should be, in place. This is an essential step to produce effective and transparent ESs and to assist with their successful implementation. The resulting ESs will be communicated to DUs as appendices to the safety data sheet
REACH and the Existing Health and Safety at Work Legislation
REACH is not intended to change any of the existing provisions such as the Chemical Agents Directive (CAD) and the Carcinogens Directive (or the COSHH regulations in the UK).
However, there is a requirement for DUs to, as a minimum, comply with the RMMs recommended by the M/I/supplier, in the ES. This may cause difficulty for the chemical user in interpreting the RMMs to take into account site-specific considerations associated with their process or operation. There is an obvious overlap between the duties under COSHH to assess risks to health and apply Principles of Good Control Practice, and the production of ES and RMMs under REACH. Further consideration and guidance may be needed on how these legislative arrangements will work in tandem.
REACH will be applied progressively starting with the most hazardous (carcinogens, mutagens, reprotoxins) and the greatest tonnage on the EU market so that it will be some years before it is fully applied. However, as the most hazardous materials have to be registered within 3 years of the entry into force of the legislation there will be a need for work on ES for these materials in the near future.
NO VAT CONSULTANT.
With the rising thresholds for VAT in the UK we have decided as we are now consistently under the new threshold to de register therefore the fees charged from now on ( 1st February 2007) will be free of VAT –
As always if you wish to discuss any of the above and the implications to your company please make contact by e-mail or telephone.
