REACH FOR FINISHING

“USES” AND “ARTICLES” JOHN OLIVER ANOCHROME GROUP

ANOCHROME GROUP

     Downstream User Approximately 200 suppliers of “preparations” and “substances” These include multi-nationals and one-person companies as well as distributors.

The individual who supplies the lubricant for a gear-box on a motor is as important as a multi-national who supplies proprietary brighteners for an alloy plating system EVERYONE MUST UNDERSTAND THEIR OBLIGATIONS

FINISHING INDUSTRY

     Examples of supplies affected by the REACH Directive include – Service agents for fork lifts and hoists Laboratory reagents Flocculants for effluent treatment Compressed gases for welding or cutting

Uses and Articles

  The two definitions under REACH are very much interdependent. The “use” of a product can define whether it is considered to be an “article” or a “preparation” and hence, whether or not it needs to be pre-registered and registered.

Pre-registration

 During the pre-registration period, 1 st June to 30 th November this year, it is necessary to submit relatively few details about substances and preparations that fall under the scope of the REACH Directive. (If pre-registration is missed; there is no second chance for companies that wish to supply after November 30 th ).

Registration

 When registration is carried out, the amount of detail that will be required to be submitted will vary according to the type of material concerned. When materials fall in to the “Substances of Very High Concern” category a very detailed dossier of properties will be required.

Substances of Very High Concern

 Under the Directive guidance as it stood at the beginning of June the maximum amount of a “substance of very high concern” that could be present in a substance, a preparation, or an article, without requiring authorisation would be 0.1%. However an article could be a car or some other complex end product.

Substances of Very High Concern

 Six member states of the European Union ( Austria, Belgium, Denmark, France Germany, Sweden) want this provision tightened.

 0.1% per component.

Registration – Articles and Preparations.

 (As has already been discussed) it is not necessary to register “Articles” that is items where, broadly speaking, their use is defined by their shape. Unfortunately the REACH Directive captures certain items in which the same thing could be defined as both a preparation or an article, dependent on its use

Example – Sheet of Steel

  Piece of steel – say 1m by 2m – bought to clad the side of a building or to form one side of a tank of those dimensions, would be an article – no registration.

Piece of the same steel – 1m by 2m – bought because it is a convenient size to fit a press in which “articles” are being formed – would be a preparation – it would need to be registered.

Example - Plastics

     Crude Oil – Natural Raw Material Ethylene - Monomer – substance – needs registering Polyethylene pellets – polymer – preparation – needs registering Polyethylene foils – articles Polyethylene bags - articles

Example - Paper

   Wood – Natural Raw Material Wood Chips – Natural Raw Material Kraft pulp – Substance – No registration

(add size, starch, water, bleach, etc)

 Stock – Preparation – needs registration  Kraft liner, coated liner, paper product articles

Registration requirements

 Often not obvious – in some cases advice will have to be sought from the Health and Safety Executive

Definition of Uses

 Fortunately the guidance we have about the definitions of “uses” is much more straightforward.

 The categories of “use” are fairly wide so should not require clarification in most cases for the finishing industry

Examples of Use Classifications

    PC14 – Metal Surface Treatment Products including Galvanic and Electro plating Products PC 15 – Non Metal Surface Treatment Products PC 21 – Laboratory Chemicals PC 37 – Water Treatment Chemicals

Exposure Scenarios

 Producers and importers of substances used under various conditions will have to prepare information about the likely exposure levels of personnel, animals and the Environment to these substances under reasonably foreseeable conditions