Tech Thursday – REACH (for the stars!)

Regulation (EC) No 1907/2006 of the European Parliament and of the Council on the Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH)

REACH came into force on 1st June 2007, essentially an environmental and health & safety initiative to identify where and how chemicals are used across all industries, and how they might impact both people (employees and users) and the environment.  It is an evolving regulation, and one to which depending on the position of the item in the “process chain”, differing responses are required.

Candidate List of Substances of Very High Concern (SVHC).

REACH has associated with it a list, entitled the Candidate List of Substances of Very High Concern, generally referred to as SVHC. The SVHC is a list of substances (predominantly chemicals), which have been identified as having a potentially detrimental effect on a person’s health if used in an uncontrolled manner.  According to set criteria, any preparation or article containing one of these SVHC must be accompanied by a Safety Data Sheet, clarifying how it should be used, under what circumstances it is “safe”, any Personal Protective Equipment (PPE) which should be worn, how to dispose of excess preparation with regard to the environment and personal safety, and how to deal with incidents involving the substance, such as fire, spills, accidents and so on.

The SVHC Candidate list is periodically updated, as substances are found or suspected to be detrimental to health or the environment.  As chemicals are added to the list, the supply chain is obligated to alert downstream users of any implications.  The latest update was 19th December 2012, when a further 54 substances were added.  At the date of this article SVHC now contains 138 substances.

Obligations under REACH

Depending on a company’s operation their obligations under REACH differ.  There are essentially three types of company as far as REACH is concerned – Manufacturer, Importer and Downstream User.

Manufacturers and Importers: From 1 June 2008, any company which manufactures any substance used on its own, or in preparations or in articles, in quantities of 1 tonne or more per year, must ensure that substance is registered with the European Chemicals Agency (ECHA) prior to its manufacture in the EU or placement on the market, subject to certain exemptions. This obligation is imposed on any manufacturer or importer of a substance on its own or in a preparation and to article producers / importers under certain conditions.

Where importers buy anything from outside the EU/EEA, be it chemicals, blends, or finished goods, for instance a “scratch and sniff” piece of clothing or toy, there are likely some responsibilities under REACH.

Downstream users: Under the REACH regulation, many companies, including D. G. Controls Ltd are classified as an end-user, since they produce nothing per se, they construct items based on previously processed parts.

The obligations of a downstream user are firstly to seek evidence from its component suppliers that all substances which need to be registered have been, and secondly to ensure that those component suppliers advise of any substances included in items supplied which are listed in the Candidate List of Substances of Very High Concern (SVHC).   Should this be the case, any preparation or article containing one of these SVHC must be accompanied by a Safety Data Sheet detailing the Safe Handling and Disposal methods for that substance.

If you have any particular enquiries regarding REACH and the deegee range of beacons and sounders, please make contact initially with our Sales Department and they can ensure your enquiry is dealt with by the most appropriate support member.

There is a wide range of information about REACH on the internet, but a particularly useful and easy to understand site is http://www.hse.gov.uk/REACH/about.htm