So you are in total compliance with Legislation in all your processes, Or are you?
This Blog was written by Colin Thirlaway at the request of McHugh Consulting. This is yet another area that we are skilled to be able to support you in Consultancy. We will also be asking experts like Colin to give you their views and knowledge. Consultancy in this field is not very common in many Countries and therefore businesses are vulnerable to being held up as being non-compliant. In McHugh Consulting we have the skills to support you.
The European REACh Regulations (1907/2006/EC) have been with us since 2007 and is one of the tools used by the European Union to manage the risks associated with Chemicals and Substances that are either manufactured inside the EU or brought into the European Union either as chemicals and substances themselves or contained in articles i.e. the products we use on a daily basis.
REACh bases its framework around substance toxicity levels and the quantity of substances placed onto the European market in a calendar year. Initially this was set out an 11 year plan such that by 2018 would ensure that Substances of Very High Concern that were placed onto the EU Market at over 1 in weight per year were identified, registered and assessed where appropriate so that any control measures could be identified and set out for implementation.
This distinctive process set out by REACh starts by identifying Substances of Very High Concern and depending on the identified risk levels, follows this up with the potential for authorisation and restriction ultimately leading to a sunset date when restricted substances are no longer allowed to be placed on to the EU market
The list known as the Candidate list of Substances of Very High Concern was born in 2007 and contained some 15 substances that were identified because of their toxic qualities such as being carcinogenic, mutagenic or toxic to reproduction. Over the past seven years this list has been updated by the European Commission in conjunction with the European Chemicals Agency and with the addition of four new substances in mid June 2014 now stands at 155.
The four new substances and their potential uses are:
Cadmium chloride (CAS 10108-64-2)
While several other cadmium compounds have already been identified as Substances of Very High Concern, Cadmium Chloride is used primarily as a process chemical, so is very unlikely to occur in finished products. Its uses include the production of pigments (which are restricted by REACH), electroplating (also restricted by REACH, but there are exclusions), manufacture of cadmium telluride photovoltaic modules and as a laboratory reagent. Historical uses include photography, photocopying and dying.
1,2-Benzenedicarboxylic Acid, Dihexyl Ester, Branched and Linear (CAS 68515-50-4)
This is also called dihexyl phthalate and so is another phthalate plasticizer added to the candidate list. It will have similar uses to other phthalates with similar alkyl chain lengths (e.g. dipentyl) so may be used in flexible PVC, rubbers, inks, lacquers, etc. The Annex XV dossier includes uses in automobile parts such as battery covers and air filters, tool handles, dishwasher baskets, PVC flooring, notebook covers, traffic cones, gloves, toys, shoes and conveyor belts.
Sodium Peroxometaborate (CAS 7632-04-4):
This substance is used as a source of hydrogen peroxide so is used as bleach and in some laundry products such as washing powder and dishwasher tablets. It may also be used in some cosmetics.
Sodium Perborate, also called Perboric Acid, Sodium Salt (this substance has no CAS number, but EC numbers are 239- 172-9 and 234-390-0):
This substances main uses are in detergents for laundries and dishwashers, in denture cleaners and stain removers and in some cosmetics
Those included under the scope of REACh are reminded that should a Substance from the Candidate list of Substances of Very High Concern be present in a article above the 0.1% weight per weight threshold then under article 33 of the REACh Regulations they have a duty to provide their industrial customers sufficient information to allow safe use of the article including as a minimum the name of that substance present.