REACH – Challenges for the New Year.
By the time this is published we will have been back at the coal face for sometime, with the recent festivities a distant memory!! So can I take this opportunity to wish everyone a belated, Happy and hopefully, a prosperous New Year.
The New Year brings new challenges and NEW opportunities to us all. CE marking being the top of the agenda for most people, when I look over the social media output and press articles of recent weeks and months. There have been numerous presentations all over the country on the subject, provided by various organisations. Those that I have attended, I found very informative so hopefully the mist and fog that usually covers these things is becoming clearer for all.
However, there are another set of regulations that are also coming into effect this year. These do not just affect this industry but are for all organisations to comply with. They are the REACH regulation changes. REACH is a European Union regulation concerning the Registration, Evaluation, Authorisation and restriction of Chemicals. It came into force on the 1st of June 2007, so it is not new, but it is a strict legal requirement and the deadline for full compliance is now barely 6 months away.
The purpose of the REACH regulatory system is to increase the level of protection to human health and the environment from the use of chemicals. It also makes the people who put the chemicals onto the market more responsible for understanding and managing the risks associated with their use. Another intention of the regulations is to allow free movement of substances within the European Union.
REACH applies to substances manufactured or imported into the EU in volumes of 1 tonne or more per year.
Responsibility for the registration falls to the manufacturer, if the goods are made in Europe, otherwise to the importer if they are made outside the EU. Those responsible have to present a package of data on the substance concerned to the European Chemicals Agency (ECHA). Once a product has been through the registration process it is allocated a specific number. This number then has to appear on all Material Safety Data Sheets (MSDS) to confirm that the product has been through the process and is registered with the ECHA.
Enforcement is the responsibility of the Health & Safety Executive. Manufacturers and Importers have had a period of several years’ grace for getting their substances registered so there are no more excuses, the crunch is coming and as the government REACH web site boldly states, after June 2013…. “If you do not register your substances……you will no longer be able to manufacture or supply the legally, ie NO DATA, NO MARKET!”
According to the HSE web site, www.hse.gov.uk/reach, REACH will have an impact on most businesses in some way.
The web site also states “If you obtain your substances from another EU based company, you should contact them to check that they have fulfilled any registration duties appropriate to them.”
What has REACH got to do with me? I hear you ask, Well, good question, which is answered in the previous statement from the HSE. There are several products used in the manufacturing process, sealant and Molecular sieve or desiccant that are used to make sealed units (IG), these as substances, are affected by the REACH regulations.
As Sealed Unit (IG) manufacturers, you need to be sure that your supplier of sealants and desiccant and other chemically based substances comply, and clearly state the REACH registration number on all material safety data sheets. These documents should be provided, by your supplier, for all products where required. These documents then should be included as part of your Factory Production Control (FPC) or your overall quality manual, and checked and updated, if required, on a regular basis. This process could be included as part of your EN1279 audit.
If any of the products you are currently using are not registered, the manufacturer or importer will not be allowed to continue making or importing them. If that happens, what have you got as an alternative or replacement?
REACH is a regulation that can not be ignored and it is not going to go away. Your responsibilities are relatively straightforward, ensure the products you are currently using comply, if they do not, then obtain an alternative that does.
Don’t get caught with your pants down – check with your current supplier that what you are buying conforms to the REACH regulations that will be implemented in June of this year and get the written confirmation logged into your manual.
SUPASIV specialist IG molecular sieve (desiccants) from Ashton Industrial, including revolutionary new SUPASIV NANOMOL, meet all these regulations since the manufacturer, Nedex had the foresight to ensure compliance when REACH regulations were first introduced
National Sales Manager