Transcript CHCS
CHCS Aspects of REACH (2) Peter Short Chemical safety consultant Safety Data Services Poole © CHCS CHCS © CHCS 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/ © CHCS REACH © CHCS 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? © CHCS 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 © CHCS 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 © CHCS 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’ © CHCS Pre-registration Do you import or manufacture chemicals? Do you rely on others who do? Remember chemicals in articles! No pre-registration – limited availability © CHCS 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’. © CHCS 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 © CHCS Waste under REACH © CHCS 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. © CHCS Pre-registration © CHCS 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 © CHCS 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 © CHCS 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. © CHCS