1. EU Regulation 1907/2006 on the Registration Evaluation and Authorisation of CHemicals REACH Lunch & Learn Beach Ballroom, Aberdeen 29 th August 2007 R E ACH

2. Outline What is REACH? What are the implications? REACH timetable Chemical usage How does it effect us? REACH for suppliers (Huw Jones, Nalco) BMT Cordah & REACH

3. REACH Registration, Evaluation and Authorisation of Chemicals “The biggest shake-up in chemical legislation in 30 years” “REACH replaces 40 existing legal acts and creates a single system for the assessment of all chemical substances” Why new legislation? Over 30,000 substances on the EU market above 1 tonne per year Very limited information available on hazards and risks Current system very slow – 200 substances fully assessed in 20 years

4. Implications of REACH Substances may be withdrawn Chemical Industry estimate 40% of chemicals on the EU market could be withdrawn. No registration – no market Failure to register a substance means that the supplier cannot market the substance until it has been registered. Downstream Users (DU) have specific obligations DU must support risk assessment process. Estimated cost to all DU of chemicals €2.8 – 5.2 billion.

5. So What Does That Mean Will lead to product rationalisation (biocide example) Product costs from suppliers are likely to increase by on average 10% Suppliers may deal direct with customers reducing many distributor SMEs to agents LOSS not gain of intellectual development MELVYN WHYTE MD WHYTE CHEMICALS LIMITED 9 Slide taken from Chemical Business Association conference, January 2006

6. REACH Timetable Set-up Agency >1000 t >100 t N:R50-53 > 1 t CMR 100 – 1000 t 10 – 100 t 1 – 10 t Pre-reg. June 2007 June 2008 Nov. 2008 Nov. 2010 June 2013 June 2018 REACH Registration Deadlines

7. Chemical Usage Currently proposed chemical usage is notified through the PON system. Risk assessments are performed (generally on a PEC/PNEC basis) for the worst case component (WCC) only, using CHARM. REACH will require assessment of all components. Exposure modelling and risk assessment is required for all component substances DU may choose to perform their own exposure modelling Different timescales for registration based on annual tonnage and PBT properties

8. Downstream Users (DUs) Draft Guidance – RIP 3.5.1 Annex 3 http://ecb.jrc.it/documents/REACH/ A DU is defined by REACH as someone, other than a manufacturer or importer, “who uses a substance, either on its own or in a preparation, in the course of his industrial or professional activities”. The guidance identifies a number of types of DUs, Industrial User 1 (IU1): “actor using substances/preparations not incorporated into articles (in a preparatory process or as a processing aid)”

9. DU - Obligations Determine whether your use is included in the exposure scenarios in safety data sheet (SDS) If use not covered, will supplier include use or undertake own assessment (Chemical Safety Report, CSR) Apply operational conditions and risk management measures detailed in SDS Keep CSRs up to date Comply with any restrictions on use of substance/preparation Use authorised substances only within conditions of authorisation

10. DU - Communication Provide information to assist supplier in the preparation of registration Have the right to make use known to supplier for inclusion as an identified use Must provide information where risk management measures are inappropriate Inform supplier of any new information on hazardous properties of substance/preparation If you supply substances/preparations to further DUs you have further obligations

11. Operator’s Chemical Usage Facility AFacility B Chemical 160825 633 Chemical 2130359 489 Specific Chemical Details Chemical 1 WCC - 30-60% (285 T) ESIS data suggests there may be data availability issues? Quantities in tonnes

12. How does REACH effect us? Must make inventory of substances Must gain assurance that suppliers will meet REACH obligations (Reg. & RA) Gap analysis of data Implement REACH Strategy Suppliers must prepare and submit registration Check your use is covered, consider own exposure model 11 year phase-in period to harmonise OCNS (PON15s) Set-up Agency >1000 t >100 t N:R50-53 > 1 t CMR 100 – 1000 t 10 – 100 t 1 – 10 t Pre-reg. June 2007 June 2008 Nov. 2008 Nov. 2010 June 2013 June 2018 REACH Registration Deadlines

13. REACH from a Supplier’s point of view Huw Jones REACH Programme Manager Nalco

14. BMT Cordah & REACH Experienced and trained staff in the field of REACH Guide operators in producing a REACH strategy and assessing supplier commitment to product registration Highlight and address chemicals that are at risk of not being registered Assistance with risk assessment & exposure modelling if required Consortia management for chemical suppliers BMT Cordah act as Only Representative BMT Cordah committed to staying on top of changes to risk assessment process and the harmonisation of OCNS with REACH

15. Thank you