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Implementing REACH using your EMS

Implementing REACH using your EMS. Dr Diana Montgomery Director of Technical Affairs. The UK Chemical Industry. Turnover of around £50 billion Trade surplus of around £4.5 billion Direct employer of around 200,000 Significant foreign ownership Ongoing restructuring

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Implementing REACH using your EMS

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  1. Implementing REACH using your EMS Dr Diana Montgomery Director of Technical Affairs

  2. The UK Chemical Industry • Turnover of around £50 billion • Trade surplus of around £4.5 billion • Direct employer of around 200,000 • Significant foreign ownership • Ongoing restructuring • Essential cornerstone of UK economy

  3. UK Chemical Industry Activities

  4. The UK Chemical Industry • Major reputation challenge • Highly regulated due to high hazard nature of business • More recent concerns over product safety • Remoteness from “consumer” • The “Millwall” of UK industry? (no one likes us!)

  5. Problem Child or Solution Provider? • Industry reputation challenge rooted in fundamental questions of sustainability • How to retain licence to operate, be globally competitive and respond to consumers increasing demands • Sustainability agenda presents great opportunity to position industry as solution provider • Building on established Sustainable Development goals from 2004 • Today’s opportunity to highlight industry’s contribution to Climate Change challenge

  6. The Chemical Industries Association • The premier trade association and employers federation for chemical businesses in the UK • London based with 40 staff • Split focus between lobbying and bespoke technical advice/support • Manages Responsible Care for the Chemical industry and produces indicators of performance. • Manages the Chemical Industry Climate Change Agreements • Key members of European Chemical Industry Council (CEFIC)

  7. REACH “possibly the most complex & controversial piece of legislation in European history” EU Industry Commissioner Mr Verheugen

  8. REACH is… Regulation (EC) No 1907/2006: Registration Evaluation Authorisation (and restriction) of Chemicals

  9. REACH: Background • Primary aim to safeguard human health and environment of European citizens and foster innovation • Industry support from the outset • Marathon legislative challenge • Shift from regulators to industry in terms of responsibility (burden of proof) • Political agreement in late 2006 • Entry into force in June 2007 • Regulation not Directive • Time to act!

  10. Anticipating REACH? CIA work to date • 2004 goal to establish database of chemicals marketed by CIA members in the UK (threshold of above 1 tonne per company) • Database published in 2006 and includes EU number, substance name, tonnage band, hazard codes and risk phrases • Establishment of formal dialogue with retailers • Agreed statement on substitution with CBI and Greenpeace • CIA engagement in UK Chemicals Stakeholder Forum • CIA support for Sustainable Production and Consumption initiative

  11. REACH: Key Steps

  12. REACH in a nutshell • Pre-Registration (1 June to 1 December 2008): Minimual data on substance identity • Registration(circa 30,000 substances over ‘phase-in’ period) if > 1 tonne (per year/ per manufacturer or importer) ‘substances’ – on their own, in preparations and intentionally released from articles if > 10 tonnes (per year/ per manufacturer or importer) requires a Chemical Safety Assessment then if ‘dangerous’ requires an ‘Exposure Scenario’ detailing measure for safe use • Classification & Labelling Inventory notification on C&L if > 1 tonne or if dangerous seeks to standardise/ harmonise C&L of substances

  13. REACH continued… • Evaluation(relatively small proportion of substances) regulatory review of registration data if identified as of concern • Restrictions restricted uses (e.g. current bans) • ‘Candidate List’ of Substances of Very High Concern (unknown number of substances – up to several thousand) triggers a notification procedure for articles requires communication if present in an article above 0.1% w/w consumers may request such information • Authorisation (unknown number of substances – perhaps several dozen per year) substance and use-specific authorisation procedure decision-making depends on availability of ‘substitutes’

  14. Overview of the Key Implementation Stages

  15. REACH: Key industry challenges Manufacturers, importers and downstream users • Need to understand your role • Will I be able to source my key substance/ingredient? • Will my substance appear on the candidate list for authorisation? • If so, what are the implications? • Do I have the capacity to deal with the requirements? Manufacturers/importers • How will REACH be enforced? • Roles for industry, authorities and customers • How much will it cost me to comply? • How will I protect my intellectual property?

  16. REACH: Key industry challenges (cont’d) Downstream users • Will I have to get directly involved in registration for uses of substances that manufacturers wont be addressing? • What about “substances in articles”?

  17. Preparing for REACH Products • Review products and establish role & responsibilities Supply Chain • Establish company contacts through the supply chain (e.g. ‘REACH operations co-ordinator’ for each customer/ supplier)

  18. Chemical Reaction, 2007

  19. Preparing for REACH Products • Review products and establish role & responsibilities Supply Chain • Establish company contacts through the supply chain (e.g. ‘REACH operations co-ordinator’ for each customer/ supplier) Risk Management • Identify best practice & existing legislative compliance – this can form a basis for Exposure Scenarios Record-keeping • Document your actions!

  20. Management Elements Policy Reviews Organisation & Personnel Audits Legislative check Operational controls Objectives & Targets Implementation/ decisions Programme

  21. Management Elements What is your company’s policy on REACH? – What about your customers, and the final end-user/ retailer? Policy Reviews Organisation & Personnel Some processes and procedures may need to change – even products may need to be reformulated Audits Legislative check Operational controls Objectives & Targets Implementation/ decisions Programme REACH is complex: it may require expert decisions to be made – various forms of guidance are becoming available How will REACH be prioritised over the 11+ implementation timeline? Have the key variables been assessed?

  22. REACH, EMS and QMS REACH combines elements of both EMS and QMS: • EMS to identify & manage environmental impacts - with inclusion of OHS REACH is chemical specific includes impact on site and through the supply chain • QMS for product compliance REACH focuses on chemical content of products requires supply chain communication & product standards

  23. Environmental Aspects Assessment of significance/ reduce impact/ review: • Hazard • Environmental conditions • Exposure (e.g. size & frequency) • Stakeholder values • Other relevant legislation

  24. Environmental Aspects Assessment of significance/ reduce impact/ review: • Hazard • Environmental conditions • Exposure (e.g. size & frequency) • Stakeholder values • Other relevant legislation DIRECT and INDIRECT ASPECTS

  25. REACH: Further considerations… REACH Help • Need for Help on REACH – practical-based solutions Tools & Formats • Many tools & formats for REACH implementation still under developments Audits • Increasing interest in ‘audits’ through supply chain (e.g. on-site checks of materials by final product producer) Compliance statements/ certifications • Methods for providing re-assurance of compliance: - company, site or product level

  26. REACH: Broader considerations For international companies or those with international supply chains (almost everyone)! • Compatibility of REACH with other international obligations (e.g. US/Mexico/Canada Chemicals Management Programme) • Synchronisation of the Globally Harmonised System for classification and labelling (GHS) with REACH

  27. REACH: Some conclusions • Start thinking about this now! • Strategic business decision to be made • Plenty of scope for confusion, mischief making and mistakes! • New mind set and realistic approach from all required • Opportunity for much better supply chain communication and relationships • Opportunity to build into Management Systems & hence demonstrate compliance • Plenty of practical advice out there • Up to European business to take the lead and gain first-mover advantage as innovative, customer-focussed and citizen-sensitive industry • Only possible with support of others

  28. For Guidance and Company specific help “The foremost place to go for help with REACH” Providing tools and advice to companies in all industries across the globe to save them time, trouble and money

  29. advocacy, authority, action

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