WHAT YOU NEED TO KNOW ABOUT REACH

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What is REACH?

Registration, Evaluation, Authorization and Restriction of Chemical substances (REACH) is a new European Community regulation that requires the registration and safe use of chemicals. The aim of REACH is to improve the protection of human health and the environment by placing greater responsibility on industry to identify and manage the risks from chemicals and to provide safety information on the substances.

Who Does REACH Impact?

REACH has very complex requirements that are dependent on the type of material being produced in or exported to the European Union (EU) and the role of the company with regard to the substance.

The designated roles are as follows:

• Manufacturer – manufacturer of a substance

• Importer - person established within the Community who is responsible for import

• Downstream user - person who uses a substance, either on its own or in a preparation, in the course of their industrial or professional activities

The types of materials that may be subject to REACH are:

• Chemical substance - a chemical element and its compounds

• Preparation - a mixture or solution composed of two or more substances (e.g., paints, varnishes, inks)

• Article - any object that has been given a specific shape, surface or design which determines its function to a greater degree than does its chemical composition (e.g., manufactured goods such as textiles, electronic chips, furniture, books, toys, kitchen equipment)

Producers or importers of articles may have to register substances if the conditions summarized are met:

• the substance is present in those articles in quantities totaling over 1 ton per producer or importer per year; and

• the substance is intended to be released under normal or reasonably foreseeable conditions of use

In addition, if the article contains above 0.1% (w/w) of certain Substances of High Concern, customers and the European Chemicals Agency (Agency) may need to be notified on the safe use of the Article.

Manufacturers and importers must also provide their downstream users with the risk information necessary to use the substance safely.

What Are the Requirements of REACH?

The main components of REACH are:

Pre-registration
Substances must be pre-registered between June 1, 2008 and November 30, 2008 in order to take advantage of the extended registration deadlines. As of January 2009, items not pre-registered cannot be marketed without a full registration.

Registration
Any substance not pre-registered by November 30, 2008 must be fully registered prior to being marketed in the EU. For all pre-registered substances, the following registration deadlines apply:
 

Dec 1, 2010	substances above 1,000 tons per year, or carcinogenic substances and substances that alter human DNA or damage human fertility above 1 ton per year
June 1, 2013	substances between 100 and 1,000 tons per year
June 1, 2018	substances between 1 and 100 tons per year

Evaluation
The Agency will examine, in more detail, registration dossiers (including safe use information, all physicochemical, toxicological and ecotoxicological information, etc.).

Authorization
Certain very dangerous substances will require authorization before they can be used and restrictions may be placed on the use of certain substances.

How HRP Can Help?

HRP can assist with REACH compliance by:

• Creation of compliance strategy and decision tree

• Collection of substance identification information

• Creation of Substance Pre-registration Information Packages (SPRIP)

• Expert consulting and on-call support for the duration of Registration

• On-site and web-based educational presentations

For more information contact Tom Seguljic, P.E. at 727-942-2115