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The Registration,
Evaluation,
Authorisation
and Restriction
of
CHemicals
regulation (REACH), came into force in the
UK on
the 1st
June 2007. We have studied the regulations in great depth and it is
clear that action is required, to a greater or lesser extent, by all
companies.
REACH aims to ensure that the risks posed by the use of
chemicals are assessed, documented, minimised and communicated and that
unsafe substances are replaced with safe substances. It places the
responsibility for assessing chemicals with manufacturers and importers,
under the aegis of the newly created European Chemicals Agency, and
tasks users with ensuring that they inform upstream suppliers about the
uses of chemicals and pass relevant information downstream to other
users.
There are several important features to note:
1. Many businesses rely on chemicals to operate, but
may not realise it. Examples used by businesses on a day-to-day basis
include machinery oils, cleaning products, printer inks and toners,
paints, glues, solvents etc. REACH applies to ALL chemicals, not only
those used as chemicals in industrial processes, but also those examples
listed above;
2.
REACH applies to all businesses within the supply
chain. The criteria determining the level of compliance required are
often complex;
3.
One organisation can have
several different roles, and therefore different obligations, under
REACH. The terms used in REACH to describe a role may be quite
differently interpreted elsewhere. Our free White Paper includes a
glossary of terms. You can download it
here;
4.
REACH only applies to the chemicals within
products not to the products themselves;
5. A pre-registration “window” opened on
the 1st
June 2008. This offers a free and simple way of continuing production
and use of certain “phase-in” substances and extends registration
deadlines for those substances to 2010-2018. The window closes on
30th November 2008
after which a
full registration must take place;
6.
Substances, and uses, not complying with REACH
will not be able to be traded or used without either a pre-registration
or a full registration.
If you are not already actively dealing with REACH you
should take the following steps as soon as possible:
-
Identify any
chemical that is present in any product which you use within your
business;
-
Decide what kind
of user of chemicals you are, remember that you could be a
distributor of one chemical and a downstream user of another;
-
Review the status
of any chemicals you make, import, use or place on the market;
-
Identify your
obligations with respect to those chemicals;
-
Create full
upstream and downstream communications channels.
To help with Steps 1 and 2, please
download our free White Paper
here
and complete the short questionnaire or, if you know the names of the
chemicals you use, visit the
European Chemical Agency website and use the
NAVIGATOR
tool to help you. You can also get
information from the
UK Competent Authority
(Health and Safety
Executive) site.
If you suspect you have an obligation
and would like some further assistance to identify and respond to your
obligation(s), please email
Hazel Lobo or telephone 01491 682850
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