"REACH" INFORMATION

WHAT IS REACH? DOES IT AFFECT MY COMPANY?

IST’s Managing Director, Andrew Watkinson attended a briefing session on REACH. So what is it all about?

REACH stands for Registration Evaluation Authorisation (and restriction) of CHemicals, and is the result of a European Directive intended to address the basic concern that hazardous chemicals cause problems. REACH applies to substances manufactured or imported into the EU in quantities of 1 tonne or more.

The REACH idea / plans / systems are literally being developed NOW so are subject to almost certain changes in the coming weeks / months – some of the information Andrew was given was only agreed 4-5 days before the conference was held in February 2008.

For the purpose of REACH:-

1. “Substances” are chemical elements and compounds including metals. IST have asked for clarification on metals and the constituent elements.

2. “Preparations” are blended chemicals containing several substances.

3. “Articles” are things made from substances where the form of the item is critical to its use – these are manufactured and sold items (Provided that the substance is intended to be released during normal and reasonably foreseeable conditions of use from an article).

The passage of information up and down the supply chain is a key feature of REACH, so ultimately it will affect your company. Users need to know what chemical manufacturers and importers know concerning the dangers of chemicals and the risk involved in their use. For suppliers to be able to assess any risks they need information from users about how they are used. The end result (in a few years) is expected to be a significant enhancement on the current MSDS sheets, and the replacement of hazardous chemicals with safer alternatives.

REACH applies to all substances except food, waste, medicines and nuclear elements (all of which are controlled by separate legislation). REACH is intended particularly to identify, control and reduce usage of chemicals that are classified as “Substances of Very High Concern” (SVHC). These include carcinogens, mutagens, toxic to reproduction (cmr’s), very persistent bioaccumulative (vPvBs) and persistent bioaccumulative and toxic (pbt’s) chemicals. A list of SVHC’s has yet to be published but approximately 4000 chemicals are likely to be called SVHC’s, with around 1700 being used in metal based manufacturing companies. Examples of chemicals that will definitely be included are Nickel, Chromium, Lead, Cadmium, Organic Chemicals (paints, coatings, trichloroethylene).

The European body controlling REACH is the European Chemical Agency (ECHA) based in Helsinki. REACH applies in all of the European Union, Norway and Iceland, and is enforced by one “competent authority” in each country. In the UK the Health and Safety Executive is that authority.

The current timetable for implementation is:-

1. Manufacturers and importers of chemicals to pre register their chemicals (from 1st June 2008 to 30th November 2008) – chemicals not pre registered by 1st December 2008 will be illegal to sell or import from this date. Customs will not allow such chemicals to enter the UK after that date. The HSE will also enforce the control of chemicals. Pre registration of a chemical is the only part of REACH that can be done at no cost, but it does mean that a company that pre – registers will have to bear a part of the cost of any testing required to qualify a chemical for safe use. The view from the organiser of the conference attended is that the majority of bulk substances or metals will be registered by the manufacturer or importer, so that no effort will be necessary by most companies at this stage. The major problems are expected to be encountered with smaller usage chemicals, such as adhesives, mould release agents, surface coatings etc, where the manufacturer will decide not to bother to register due to low usage (and will therefore no longer supply after December 2008). This could create problems with continuity of supply to Aerospace companies where there are long approval times, controlled parts and the need for First Article Inspections – a change to the processing of a part will trigger re-approval of the part! 

2. Registration of chemicals by manufacturers and importers. This will also require supporting technical chemical and test data to be submitted, and it is intended that this stage will be co-operative between companies through a system called SIEF. The full procedure for this system has yet to be determined, but the timetable is as follows:-

1000 Tonnes / yr from 30.6.08 to 2011
100 – 1000 Tonnes / yr by 2013
1 – 100 Tonnes / yr by 2018

3. Declarations - Companies will need to make submissions to ECHA – this will require companies to work with suppliers, customers and competitors.

4. Authorisations – where a substitute product cannot be found then the ECHA may authorise the use of SVHC’s for a fixed period of time, but the emphasis will be on the company proving the need for continued use.

The Declaration and Authorisation phases are rather vague at present, but these phases are being decided at present.

All of the major aerospace companies (Airbus, Rolls Royce, Pratt and Whitney, GEAE, Boeing and Goodrich) are cooperating together and producing a uniform strategy for handling REACH (effectively forming their own SIEF) – it is thought that automotive organisations are likely to follow a similar strategy, but not known whether they will reach the same outcome. Aerospace companies will definitely impose trading conditions into your purchase contracts that force you to participate in REACH. (Ultimately Airbus for example will have to inform a customer what a A380 is made from – X tonnes of Ni, Y tonnes chromium etc, which means that Rolls Royce have to know the make up of their engine, which means that engine component suppliers have to declare the make up of their components and so on down the supply chain).

The suggested actions (from the Aerospace REACH group) for down stream users (part of the supply chain) are:-

1. Write to your suppliers asking them to confirm that they will pre- register the chemicals that you use.

2. Prepare a letter ready to send out to enquirers that states what you are doing – this will need to be modified as you make progress.

3. Ensure that your chemical inventories / holding lists are up to date. What chemicals do you use and in what quantities? – You need sufficient MSDS information to identify constituents in a chemical down to 0.1% concentration (Apparently American MSDS data only goes down to 1% concentration and are not acceptable in Europe!).

4. Install IUCLID 5 software (type in IUCLID 5 on a search engine, and follow the link to the ECHA website) on a dedicated computer (apparently this will take 3-4 hours to install) This system will be needed to pre – register chemicals and register usage, obtain data, chemical classifications and “use codes”etc. It is also recommended that a specific dedicated email address is made available for handling REACH enquiries – it is expected that you will receive a large number of emails as the overall REACH system is established.

5. Appoint someone to handle these enquiries / monitor progress for your company.

6. There are some documents that are expected to be issued via SAE and Euronorm in March 2008 giving much more detail on chemicals and procedures.

IST will attempt to keep our Members up to date as REACH implementation progresses. It is the intention to attend a more generalised engineering related REACH event.

A WORD OF WARNING - There are apparently a number of software packages being marketed that claim to be REACH systems, but in the opinion of the Aerospace REACH group who have evaluated these packages NONE of these packages are particularly good or useful – and definitely not cheap to purchase.

IST are investigating the possibility of obtaining a membership to a “Reach Website”, this will enable REACH data enquires to be made. Initial information suggests that single company fees are at least £250 per year for this type of service – IST joining on behalf of UKSMA / IST members may be a cost effective way of sharing this.