Transcript CHCS
CHCS
Aspects of REACH (2)
Peter Short
Chemical safety consultant
Safety Data Services
Poole
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CHCS
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Member of Society Council
Chairman Trainer Assessment Panel
Member of the Training Sub Group
CHCS
Chemical Hazards Communication Society
Founded 1994 with backing of HSE
>400 members
Promote and work to improve chemical hazard
communication.
Provide a forum for sharing experiences.
Promote and provide specific training.
http://www.chcs.org.uk/
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REACH
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Registration, Evaluation and Authorisation
and restriction of Chemicals
In principle REACH applies to nearly all
chemicals.
Not only chemicals used in industrial
processes but also in our day-to-day life.
e.g. cleaning products, paints and in articles
such as clothes, furniture and electrical
equipment.
REACH
Have you all heard about
REACH?
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Analysis by REACH awareness
„I have heard about a new legislation regarding the registration, evaluation and
approval of chemicals in Europe, called “REACH”“
Czech Rep
15,5
Sweden
15,5
12,1
Belgium
France
11,0
Hungary
9,9
9,0
Germany
PES 2008-11C
8,0
6,5
Italy
6,0
Spain
Great Britain
Netherlands
Poland
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5,0
4,3
3,8
REACH
Where are we now?
European Regulation into force 1st June 2007
No UK enforcement Regulation yet.
As of today, very little impact.
European Chemicals Agency formed – staff being
appointed and trained
Safety Data sheets amended by REACH.
E-mail address required
Sections 2 and 3 changed
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REACH
Pre-registration phase began 1st June this
year
Applies
to manufacturers and importers of
chemicals into Europe
Applies to chemical substances, substances
in preparations and substances in articles
The above must pre-register to continue
selling or making (with some exceptions)
Pre-registration is ‘free’
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Pre-registration
Do you import or manufacture chemicals?
Do you rely on others who do?
Remember chemicals in articles!
No pre-registration – limited availability
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Pre-registration
Consider
creating an inventory of every
chemical product you use.
Identify any key substances/products
Ensure your suppliers have pre-registered
any key substances
Or look for a different supplier!
Pre-register any substances as necessary
The consensus view is, ‘if in doubt, preregister’.
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Pre-registration
Some exemptions
less than 1 tonne per year generally exempt
Some substances exempt eg water, nitrogen
Some uses exempt eg food ingredients
Site
limited intermediates included
Waste included if re-used
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Waste under REACH
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There is no obligation to register chemical
wastes if the chemical waste is managed and
disposed of as waste.
However, if the waste is used to create other
substances, or it is supplied as a substance
or in a preparation, it will fall under REACH.
Residues from waste treatment operations
need not be registered as long as residues
are waste, i.e. that they are discarded and
disposed of (e.g. land filled).
It may be wise to pre-register waste solvents
distilled to a higher degree of purity.
REACH
What is coming?
th November – end of pre-registration
30
period.
Substances not pre-registered will only be
permitted limited uses unless fully registered.
Small
scale
Exempted use such as food
Pre-registration gives time before registration.
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Pre-registration
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1st January 2009 – list of pre-registered
substances published.
May contain 30-50,000 substances
Check that any key substances are on the
list.
Pre-registration number allocated for use on
SDS.
SIEFs and consortia formed
Registration
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The next stage is registration
Phased registration
Higher priority first.
Substances >1000 tonnes – end of 2010
Substances of concern - end 2010
All others >1 tonne per year phased in by
2018
Implications long term
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Registration will result in new hazard data.
Substances may become regarded as more
hazardous
Pre-registered substances may be withdrawn
at registration due to cost
Substances may be restricted or need
authorisation
Products you use may need to be
reformulated
Actions
If you need to use any
chemicals, check now before it
is too late.
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