© CHCS CHCS Aspects of REACH (2) Peter Short Chemical safety consultant Safety Data Services Poole

© CHCS CHCS n Member of Society Council n Chairman Trainer Assessment Panel n Member of the Training Sub Group

© CHCS CHCS n Chemical Hazards Communication Society n Founded 1994 with backing of HSE n >400 members n Promote and work to improve chemical hazard communication. n Provide a forum for sharing experiences. n Promote and provide specific training.

© CHCS REACH n Registration, Evaluation and Authorisation and restriction of Chemicals n In principle REACH applies to nearly all chemicals. n Not only chemicals used in industrial processes but also in our day-to-day life. n e.g. cleaning products, paints and in articles such as clothes, furniture and electrical equipment.

© CHCS 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”“

© CHCS REACH Where are we now? n European Regulation into force 1 st June 2007 n No UK enforcement Regulation yet. n As of today, very little impact. n European Chemicals Agency formed – staff being appointed and trained n Safety Data sheets amended by REACH. u address required u Sections 2 and 3 changed

© CHCS REACH n Pre-registration phase began 1 st June this year u Applies to manufacturers and importers of chemicals into Europe u Applies to chemical substances, substances in preparations and substances in articles u The above must pre-register to continue selling or making (with some exceptions) u Pre-registration is ‘free’

© CHCS Pre-registration n Do you import or manufacture chemicals? n Do you rely on others who do? Remember chemicals in articles! No pre-registration – limited availability

© CHCS Pre-registration u Consider creating an inventory of every chemical product you use. u Identify any key substances/products u Ensure your suppliers have pre-registered any key substances u Or look for a different supplier! u Pre-register any substances as necessary The consensus view is, ‘if in doubt, pre- register’.

© CHCS Pre-registration Some exemptions u less than 1 tonne per year generally exempt u Some substances exempt eg water, nitrogen u Some uses exempt eg food ingredients u Site limited intermediates included u Waste included if re-used

© CHCS Waste under REACH n There is no obligation to register chemical wastes if the chemical waste is managed and disposed of as waste. n 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. n 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). n It may be wise to pre-register waste solvents distilled to a higher degree of purity.

© CHCS REACH What is coming? n 30 th November – end of pre-registration period. n Substances not pre-registered will only be permitted limited uses unless fully registered. u Small scale u Exempted use such as food Pre-registration gives time before registration.

© CHCS Pre-registration n 1 st January 2009 – list of pre-registered substances published. n May contain 30-50,000 substances n Check that any key substances are on the list. n Pre-registration number allocated for use on SDS. n SIEFs and consortia formed

© CHCS Registration n The next stage is registration n Phased registration n Higher priority first. n Substances >1000 tonnes – end of 2010 n Substances of concern - end 2010 n All others >1 tonne per year phased in by 2018

© CHCS Implications long term Registration will result in new hazard data. n Substances may become regarded as more hazardous n Pre-registered substances may be withdrawn at registration due to cost n Substances may be restricted or need authorisation n Products you use may need to be reformulated

© CHCS Actions If you need to use any chemicals, check now before it is too late.