IMF REACH Symposium Organic Coatings - Keeping up appearances after REACH Jim Casper Manager, Product Stewardship – Europe PPG Industries

REACH COMPLIANCE THREE LEGS: SUBSTANCE SUPPLIER IDENTIFIED USE

REACH COMPLIANCE THREE LEGS: SUBSTANCE SUPPLIER IDENTIFIED USE

REACH - Registration SUBSTANCE REACH is a SUBSTANCE Regulation Estimated 30,000 substances used in Europe Toluene is a substance Xylene is a mixture of substances  most “raw materials” will be mixtures Polymers do not have to be registered (provided the monomers are registered)

WHAT IS PAINT? PIGMENT – for colour and opacity BINDER – for physical performance SOLVENT – to aid/allow application

WHAT IS PAINT? PIGMENT BINDER SOLVENT and: FLOW ADDITIVE THICKENER WETTING ADDITIVE CATALYST UV STABILISER SLIP/ANTI-SCRATCH ADDITIVE BRIGHTENER SPECIAL EFFECT ADDITIVE SLOW/FAST SOLVENT TO CHANGE DRYING SPEED FLEXIBILISER ……………………………….

ItemDescription% 1Thickener0.48% 2Flow aid0.01% 3Adhesion promoter0.15% 4Catalyst0.04% 5Catalyst0.04% 6Catalyst0.00% 7Binder resin (solid part)27.06% 8Pigment36.00% 9Solvent 10.09% 10Solvent % 11Solvent 39.59% 12Solvent % Total % PAINT – RAW MATERIAL LEVEL

PAINT – SUBSTANCE LEVEL (1)

PAINT – SUBSTANCE LEVEL (2) > 30 CHEMICAL SUBSTANCES

REACH COMPLIANCE THREE LEGS: SUBSTANCE SUPPLIER IDENTIFIED USE

SUPPLIER Manufacturer/Importer of Substance is responsible for REGISTRATION Most users of chemicals are “Downstream users”, according to REACH Your Supplier may not be the person responsible for Registration Requires communication up/down supply chain REACH COMPLIANCE

IMPACT THROUGH THE SUPPLY CHAIN Chemical Manufacturer Chemical Manufacturer Chemical manufacturer Chemical Manufacturer Raw Material Supplier Paint Manufacturer Customer (Paint User) MSDS Recommended protection methods Identified Use Exposure data REACH COMPLIANCE

THREE LEGS: SUBSTANCE SUPPLIER IDENTIFIED USE

Identified Use must be included in the registration Downstream user (e.g. PAINT) can only use the substance if his use is identified Requires communication up/down supply chain Identified Use not yet defined! (RIP 3.5 – Dec07/Jan08) REACH COMPLIANCE

MAJOR THREATS Increased price of raw materials – as REACH COST is passed on down the supply chain Substances which may not be supported by the supplier - REFORMULATION Substances of high risk that will require AUTHORISATION - use in your factory - se by your customers Workload/cost of collating data through the supply chain – PAPERWORK

Registration of new Substances Agency start-up >1000tonnes CMR 1, 2 > 1 t R50/53 > 100t tonnes tonnes 1 December June June June June December 2008 REACH - TIMELINE Phase-in substances registration Pre-registration

SO WHAT SHOULD I DO? AWARENESS: All key staff aware of REACH Impact on business understood ANALYSIS: Number of materials used understood Suppliers position recorded Business impact understood ACTION Product-specific actions (No change, Stop Sales, Re-formulate………….)

ACTIONS REQUIRED NOW (1): RAW MATERIALS SOURCED IN EUROPE Catalogue all raw materials used in products you manufacture Identify the supplier for each raw material Contact suppliers – confirm: pre-register Register include your identified use

ACTIONS REQUIRED NOW (2): CONSIDER OTHER MATERIALS Products/Resins/Raw materials you import into Europe Substances you manufacture Ancillary chemicals (cleaning materials….)

ACTIONS REQUIRED NOW (3): AUTHORISED SUBSTANCES Consider options: Reformulate Seek Authorisation (with supplier) Stop sales (from 2010……)

Examples of CMR 1&2 Strontium Chromate / Zinc Chromate Lead pigments (colour pigments, lead silicate) Di-Octyl Phthalate Dibutyltin compounds (new classification) N-methylPyrrolidine (new classification)

ACTIONS REQUIRED NOW (4): COMMUNICATION WITH CUSTOMERS Prepare to answer questions from your customers (continuity of supply…) Prepare to discuss “identified use” MSDS New requirements from 1 June 2007 ( address, Section 2 & 3 reversed) Check and implement the changes

SUMMARY Know your formulations Talk to your suppliers Anticipate questions from your customers COMMUNICATE!