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Filename. 2. Rolls-Royce plc. Power for air, sea and landCustomers; 500 airlines, 4,000 corporate and utility aircraft and helicopter operators, 160 armed forces and more than 2,000 marine customers, including 50 navies. Energy customers in nearly 120 countries. Annual sales over $10 billion3
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1. Registration, Evaluation, Authorisation and Restriction of Chemicals RegulationsREACH Cathy Phillips CEng IMechE CMIOSH AIEMA
HSE Materials Manager, Corporate HSE Name
Who work for and what we doName
Who work for and what we do
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2 Rolls-Royce plc Power for air, sea and land
Customers; 500+ airlines, 4,000 corporate and utility aircraft and helicopter operators, 160 armed forces and more than 2,000 marine customers, including 50 navies. Energy customers in nearly 120 countries.
Annual sales over $10 billion
35,000 employees; 21,000 in UK, 8,000 in North America and 5,000 in rest of Europe
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3 REACH and YOU Overview of REACH
Legal obligation 1 – pre-registration through to authorisation
Pre-registration
Registration
Authorisation & restriction
Legal obligation 2 - Declaration
Business Risk
Action Plan / Governance
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4 Objective To identify the business and legal risks associated with REACH.
To assess the overall scale of the task for each of your legal entities.
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5 REACH Regulation (EC) No 1907/2006:
Registration
Evaluation
Authorisation
(and Restriction)
of Chemicals
Entered into force on 1 June 2007
Registration begins 1 June 2008 Materials / substances will have to be registered for use. The use must be defined e.g. spray application, immersion
Explanation of ECHA (European Chemical Agency). Local authorities will work together with ECHA.Materials / substances will have to be registered for use. The use must be defined e.g. spray application, immersion
Explanation of ECHA (European Chemical Agency). Local authorities will work together with ECHA.
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6 Business Costs & Benefits Inputs:
Registration costs, inc. testing estimated EUR 2.8 – UR 5.2 billion
Outputs:
Health benefits. Savings of EUR 50 billion over 30 years.
Prevention of occupational skin and respiratory diseases. Savings of EUR 90 billion over 30 years.
Benefits to the environment. Savings of at least EUR 9 billion. Registration costs includes downstream users and costs depend on the extent to which registration costs will increase prices of chemicals and on the cost of substituting chemicals.
Health benefits are by reducing chemical related diseases by 10%Registration costs includes downstream users and costs depend on the extent to which registration costs will increase prices of chemicals and on the cost of substituting chemicals.
Health benefits are by reducing chemical related diseases by 10%
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7 Business Risks and REACH REACH will have BENEFITS for human health, and the environment because some really hazardous chemicals in use on their sites will not be allowed in future.
More information will be available about the hazards and how to manage them (on the MSDS)
Most risk assessments will be easier to put together and to audit against – Users are required to follow the Risk Management Measures on the MSDS
REACH is a Supply Challenge
Substance obsolescence
Product availability
Knock-on effect on Prices
Specificity to our sector: Change cannot be done quickly for Product Safety reasons (high level of requirements)
REACH is a Supply Challenge
Substance obsolescence
Product availability
Knock-on effect on Prices
Specificity to our sector: Change cannot be done quickly for Product Safety reasons (high level of requirements)
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8 Business Risks and REACH
REACH could result in some of the substances used to make manufactured products being:
Unavailable, if suppliers (manufacturers / importers) do not register the substances.
Increasingly difficult to obtain in the long term, if they are hazardous.
More costly to buy (because of the registration and authorisation costs). REACH is a Supply Challenge
Substance obsolescence
Product availability
Knock-on effect on Prices
Specificity to our sector: Change cannot be done quickly for Product Safety reasons (high level of requirements)
REACH is a Supply Challenge
Substance obsolescence
Product availability
Knock-on effect on Prices
Specificity to our sector: Change cannot be done quickly for Product Safety reasons (high level of requirements)
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9 Business Risks and REACH SO…
It can – if not managed well – be a business continuity issue.
It can be a compliance issue
So REACH is NOT “just another HSE issue”. It is a purchasing, manufacturing, design and strategic issue that just happens to originate in the field of HSE. REACH is a Supply Challenge
Substance obsolescence
Product availability
Knock-on effect on Prices
Specificity to our sector: Change cannot be done quickly for Product Safety reasons (high level of requirements)
REACH is a Supply Challenge
Substance obsolescence
Product availability
Knock-on effect on Prices
Specificity to our sector: Change cannot be done quickly for Product Safety reasons (high level of requirements)
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10
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11 REACH applies to…. All Chemicals
All uses
All stages of a chemical’s life cycle
(unless specific equivalent legislation exists)
Ignoring REACH could effectively put us out of business. We have to take action !
REACH has an effect on business continuity Life cycle means from cradle to grave. E.g. Materials dug out of the ground –processed-manufactured-used-treated-disposal.
Materials that are not registered for Rolls-Royce use e.g. R-R apply paint using spray technique and the registered use is for brush technique only, then R-R will not be able to use the paint spray technique in future.
Small chemical companies may be out of buisness.
R-R must contact the supply chain and inform them of the way we use materials. Should the person responsible at site be pin-pointed ?Life cycle means from cradle to grave. E.g. Materials dug out of the ground –processed-manufactured-used-treated-disposal.
Materials that are not registered for Rolls-Royce use e.g. R-R apply paint using spray technique and the registered use is for brush technique only, then R-R will not be able to use the paint spray technique in future.
Small chemical companies may be out of buisness.
R-R must contact the supply chain and inform them of the way we use materials. Should the person responsible at site be pin-pointed ?
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12 REACH Key Words Substance: A basic chemical, like iron, nickel, trichloroethylene, lead oxide
Preparation: A mixture of chemicals, like steel, adhesive, resin, paint, an etchant, an NDT fluid
Article: An object where the shape is more important than its chemical composition: A billet, a rod, a diesel engine, a gasket, a spare part, a submarine, a valve, a second hand product Make the participants write this down themselves !
Make sure that they understand that a substance is a part of the Substance-definition.Make the participants write this down themselves !
Make sure that they understand that a substance is a part of the Substance-definition.
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13 Who does REACH apply to? Any Company (LEGAL ENTITY) producing, importing, using or placing a substance, preparation or article on the EU market must comply with REACH.
Covers EU manufacturers, including chemical suppliers, distributors and downstream users.
Covers EU enterprises importing products to the European Community Make the participants themselves write down the definitions of manufacturer, importer, DownstreamuserMake the participants themselves write down the definitions of manufacturer, importer, Downstreamuser
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14 REACH – legal overview Drawing on flip-over is very good !
To draw the time scale and graf related to the Effort is also very good ! (Pre-registration…)
Explaination concerning 45 days is really a eye-opener concerning the time schedule.Drawing on flip-over is very good !
To draw the time scale and graf related to the Effort is also very good ! (Pre-registration…)
Explaination concerning 45 days is really a eye-opener concerning the time schedule.
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15 REACH Initial requirements Pre-registration for phase-in:
Pre-registration starts 1 June 2008 and ends 1 December 2008
Minimum data (substance name, EC or CAS Number)
When uncertain pre-register
Registration:
Starts 1 June 2008
A central inventory will be created of all substances produced or sold in the EU >1 tonne per annum
Substance-specific, Use-specific
Applies to substances in products, articles and preparations
In order to avoid duplication of work, and in particular to avoid duplication of testing, registrants of phase-in substances should pre-register as early as possible with a database managed by the Agency. Pre-registration period is between June and December.
In cases where a substance has not been pre-registered, measures should be taken to help downstream users find alternative sources of supply.
Any one who has not pre-registered can enquire from the Agency if registration has been submitted for the same substance. The Agency will inform the enquiring company if the substance has been pre-registered or not. Where it has been pre-registered the company making the enquiry will have to provide information about the substance and share information with the other registrants. If the substance has not been pre-registered the company cannot rely on phase-in registration.
Manufacturers and importers of a substance on its own or in a preparation should be encouraged to communicate with the downstream users of the substance with regard to whether they intend to register the substance. Such information should be provided to a downstream user sufficiently in advance of the relevant registration deadline if the manufacturer or importer does not intend to register the substance, in order to enable the downstream user to look for alternative sources of supply or register themselves.In order to avoid duplication of work, and in particular to avoid duplication of testing, registrants of phase-in substances should pre-register as early as possible with a database managed by the Agency. Pre-registration period is between June and December.
In cases where a substance has not been pre-registered, measures should be taken to help downstream users find alternative sources of supply.
Any one who has not pre-registered can enquire from the Agency if registration has been submitted for the same substance. The Agency will inform the enquiring company if the substance has been pre-registered or not. Where it has been pre-registered the company making the enquiry will have to provide information about the substance and share information with the other registrants. If the substance has not been pre-registered the company cannot rely on phase-in registration.
Manufacturers and importers of a substance on its own or in a preparation should be encouraged to communicate with the downstream users of the substance with regard to whether they intend to register the substance. Such information should be provided to a downstream user sufficiently in advance of the relevant registration deadline if the manufacturer or importer does not intend to register the substance, in order to enable the downstream user to look for alternative sources of supply or register themselves.
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16 Time-line Time-line showing registration according to hazard and tonnage of substance used / manufactured / importedTime-line showing registration according to hazard and tonnage of substance used / manufactured / imported
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17 REACH Legislation Legislative text organised into fifteen ‘Titles’
1st eight refer to registration, evaluation, authorisation and restriction processes
Remaining seven detail administration elements of REACH
Help to businesses for implementation of REACH technical guidance notes are being written - RIPs ADMINISTRATION ELEMENTS: Establishment of the European Chemical Agency, confidentiality of data, and 4enforcement issues.
RIPs – REACH Implementation Projects – 7 of them. 1. REACH process description
2. REACH-IT (Launched IUCLID5 International Uniform Chemical Information Database) Software tool for entering and storing information on chemicals, as well as for preparing and submitting dossiers to fulfil legislation requirements.)
3. Technical guidance document for industry (guidance on completed registrations, performing chemical safety assessments, managing data sharing, specifying requirements for articles)
4. Guidance for regulatory authorities HSE
5 & 6 Setting up the European chemical agency and pre-agency
7. Commission preparations for REACH
Further info on RIPs European Chemicals Bureau website
Define the abbrevatiion RIP.ADMINISTRATION ELEMENTS: Establishment of the European Chemical Agency, confidentiality of data, and 4enforcement issues.
RIPs – REACH Implementation Projects – 7 of them. 1. REACH process description
2. REACH-IT (Launched IUCLID5 International Uniform Chemical Information Database) Software tool for entering and storing information on chemicals, as well as for preparing and submitting dossiers to fulfil legislation requirements.)
3. Technical guidance document for industry (guidance on completed registrations, performing chemical safety assessments, managing data sharing, specifying requirements for articles)
4. Guidance for regulatory authorities HSE
5 & 6 Setting up the European chemical agency and pre-agency
7. Commission preparations for REACH
Further info on RIPs European Chemicals Bureau website
Define the abbrevatiion RIP.
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18 Supply chain communication
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19 REACH – legal overview Drawing on flip-over is very good !
To draw the time scale and graf related to the Effort is also very good ! (Pre-registration…)
Explaination concerning 45 days is really a eye-opener concerning the time schedule.Drawing on flip-over is very good !
To draw the time scale and graf related to the Effort is also very good ! (Pre-registration…)
Explaination concerning 45 days is really a eye-opener concerning the time schedule.
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20 Pre-Registration in REACH Manufacturers and IMPORTERS (M/I) of substances have to register them.
This will MAINLY be chemical manufacturers and suppliers.
Many substances can benefit from an 11 year phase in of registration, if they are Pre-registered BETWEEN JUNE AND END NOV.
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21 Continuity of supply:
Will your suppliers (particularly distributors and stockists who are importers) meet their legal obligations?
Continued legal use:
Will the manufacturer or importer (who could be several tiers up), include your use in their registration?
Implications of Registration on Downstream Users…
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22
Safety Data Sheets
inversion of Sections 2&3 + email contact
Persistent, Bioaccumulative and Toxic substances (PBT) and very persistent / very bioaccumulative substances (VPVB) will NOT be shown (initially)
Will require an “extended SDS” following registration (e-SDS) which will MANDATE the way in which the substance / preparation is used.
Title 6Title 6
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23
DUs need to: communicate use upstream
(min 12 months prior to phase-in registration deadline)
distributors have responsibility to pass information up and down between DUs and manufacturers / importers
DU Chemical Safety Assessment
for uses outside an Exposure Scenario (or use & exposure category)
DU exceptions (e.g. <1 tonne per year)
General compliance (max 12 months)
Reporting of information (max 6 months)
Good example used = Nail polish on metalGood example used = Nail polish on metal
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24 The Evaluation in REACH Once pre-registered, manufacturers and importers of substances have to prepare DOSSIERS that will be EVALUATED by the REACH Agency in Helsinki.
This will decide whether registered substances are ‘nasties’(substances of very high concern). If they are, then the European Commission could require them to go through Authorisation or Restriction.
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25 REACH – legal overview Drawing on flip-over is very good !
To draw the time scale and graf related to the Effort is also very good ! (Pre-registration…)
Explaination concerning 45 days is really a eye-opener concerning the time schedule.Drawing on flip-over is very good !
To draw the time scale and graf related to the Effort is also very good ! (Pre-registration…)
Explaination concerning 45 days is really a eye-opener concerning the time schedule.
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26 “Substances of Very High Concern” Carcinogens, mutagens and reproductive toxins (CMRs)
Persistent, Biocumulative and Toxic (PBT)
Very persistent and very bioaccumulative (vPvB)
Substances of equivalent concern (endocrine disruptors)
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27 This list is intended to:
Help companies make product and process decisions, whilst complying with regulatory and customer requirements.
Enable the business risk from these substances to be managed throughout a supply chain
It is intended primarily for the aerospace defence sector
http://www.asd-stan.org
TR 9535 and TR 9536
The Declarable Substances list
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28 Substances in our Products and Processes Use estimated number of substancesUse estimated number of substances
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29 The Declarable Substances list A compilation of all the substances that have been identified as being…
CMRs category 1& 2 (annex 1 of directive 67-548 as amended)
Substances defined as vPvB or PBT (OSPAR listed substances)
Ozone Depleting Substances as defined by Montreal Protocol
Persistent Organic Pollutants as defined by the Stockholm Convention, etc.
Substances listed within Annex XVII (restricted substances)
Definition on abbravations are neededDefinition on abbravations are needed
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30 Substances in our Products and Processes Don’t use blue on black background !Don’t use blue on black background !
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31 REACH – legal overview Drawing on flip-over is very good !
To draw the time scale and graf related to the Effort is also very good ! (Pre-registration…)
Explaination concerning 45 days is really a eye-opener concerning the time schedule.Drawing on flip-over is very good !
To draw the time scale and graf related to the Effort is also very good ! (Pre-registration…)
Explaination concerning 45 days is really a eye-opener concerning the time schedule.
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32 Articles Registration = if intended release
Notification = if ‘Candidate List’ & >0.1% w/w
& cannot excluded exposure
unless already registered for that use
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33 Requirement to Inform Customers and the Consumer You have a legal obligation to INFORM Customers about SVHCs contained within YOUR product (Article 33(1))
> 0.1% w/w
“sufficient information, available to the supplier, to allow safe use of the article including, as a minimum, the name of that substance”.
Same information to be available free of charge to consumers on request (within 45 days)
Your suppliers also have this obligation if they are located in the EU. The aerospace defence sector is developing a Euronorm and SAE standard which will help the information flow up and down supply chains, by stipulating a common data format.
When this is available, hopefully next year, well before the requirements concerning SVHCs start to bite, suppliers will get requests from customers for the information, and it will be able to be sent to all customers in the same form.
The aerospace defence sector is developing a Euronorm and SAE standard which will help the information flow up and down supply chains, by stipulating a common data format.
When this is available, hopefully next year, well before the requirements concerning SVHCs start to bite, suppliers will get requests from customers for the information, and it will be able to be sent to all customers in the same form.
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34 Requirement to Notify of SVHCs You have a legal obligation to NOTIFY the REACH Agency (ECHA) AND Customers about SVHCs contained within YOUR product (REACH Article 7(2)) if the following apply:
>0.1% w/w AND
> 1 tonne sold (of SVHC per year) AND
Cannot show that the substance will not be released at any point in the life cycle (including disposal)
This is a subset of the information needed for the customer
The aerospace defence sector is developing a Euronorm and SAE standard which will help the information flow up and down supply chains, by stipulating a common data format.
When this is available, hopefully next year, well before the requirements concerning SVHCs start to bite, suppliers will get requests from customers for the information, and it will be able to be sent to all customers in the same form.
The aerospace defence sector is developing a Euronorm and SAE standard which will help the information flow up and down supply chains, by stipulating a common data format.
When this is available, hopefully next year, well before the requirements concerning SVHCs start to bite, suppliers will get requests from customers for the information, and it will be able to be sent to all customers in the same form.
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35 REACH and business risk…
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36
Issues within the Supply Chain We identified at first sight some issues which can occur with our supply chain
Due to non-registration of a substance,
supplier of a preparation will have to change its form or simply to stop producing it
recertification,
WE NEED TO MAINTAIN OUR PRODUCT SUPPLY TO REDUCE THE USE OF HAZARDOUS MATERIALS AT A CONTROLLED PACE, ADAPTED TO OUR R&D CAPABILITIES.We identified at first sight some issues which can occur with our supply chain
Due to non-registration of a substance,
supplier of a preparation will have to change its form or simply to stop producing it
recertification,
WE NEED TO MAINTAIN OUR PRODUCT SUPPLY TO REDUCE THE USE OF HAZARDOUS MATERIALS AT A CONTROLLED PACE, ADAPTED TO OUR R&D CAPABILITIES.
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37 Issues within the Supply Chain
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38 Issues within the Supply Chain Legal info to customer:
Sufficient info to ensure safe usage of the article>
This includes the list of substances > 0.1% weight
45 days timescale
Legal info to customer:
Sufficient info to ensure safe usage of the article>
This includes the list of substances > 0.1% weight
45 days timescale
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39 ACTIONS: Hold your own internal workshops: Dealing with the Registration process:
Manufacturer, importer or downstream user?
What do you buy from where?
What action is needed prepare for preregistration/registration?
What are the SVHCs used in your factories?
Dealing with the “Declaration” part of REACH:
What are the declarable substances (as a surrogate for SVHCs) in your products?
What are the risks from REACH to you?
Continuity of supply?
Ability to adapt to the loss of substances?
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40 Step 1: What are YOUR responsibilities in REACH? What substances / preparations do you use?
Which of these are imported?
Find out if what you are buying is imported by YOUR company or someone else.
If it is YOU, ask the non-EU supplier if they intend to have an ‘only representative’. YOU have a legal obligation to pre-register if you import! YOU NEED TO ACT NOW!
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
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41 Step 2: Engagement with Suppliers If you want to maintain access to chemicals & raw materials, it is vital that the supplier understands their responsibilities. DEFRA estimates that more than 60% of businesses have not even heard of REACH.
What should you do about it?
Most of your supply chain is probably unaware about REACH. So TELL THEM.
Are they organised for REACH?: Check!
EXAMPLE LETTERS ARE AVAILABLE
Will your supplier take care of you?: ASK! ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
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42 ACTION: Have the suppliers you deal with heard of REACH?
Compile a list of your suppliers, and where they are. Include addresses.
Write to all your suppliers telling them about REACH.
Ask each supplier who their REACH FOCAL POINT is.
Keep a record on who has replied, and the names / email addresses of the focal points.
ANSWERS WILL BE:
? “Don’t worry, we will pre-register/register”. - You are OK!
? “We will not be registering” - You need to change supplier / product!
? “Silence”: we don’t know what you are talking about - You need to educate your supplier! Step 2: Engagement with Suppliers
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43 ? Dealing with “silence”!
Recommend that your suppliers go on a training day on REACH.
Most sectors offer training on REACH – they should go on one relevant to them.
EEF,
HSE,
British Coatings Federation,
Institute of Metal Finishing etc.
Step 2: Engagement with Suppliers
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44 Step 3: Estimate the risk EU stockists / distributors / agents…
Most distributors and stockists who are importers ARE UNAWARE OF THEIR OBLIGATIONS (according to UK HSE & DEFRA).
Many smaller stockists intend to stop supplying, because of the costs!!
Will this be the case for your supply chain?
What is the threat to your continuity of supply?
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
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45 Step 3: Estimate the risk EU manufacturers of substances, formulators of preparations…
If the substance is a small sales stream for them, it may not be cost effective for them to keep making it.
Does this affect any substances, or constituents in preparations, that you need?
Will formulators change the ingredients in the preparations they sell you (do you care?)
What is the threat to your continuity of supply?
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
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46 Step 4: Record what you learn For substances & preparations, make a spreadsheet of…
The tradenames / specs of the chemicals you buy
Where and who you buy them from (import?)
How much you buy
Whether the supplier knows about REACH
Who their focal point is
Their contact details
Whether we are the importer
If there is an only representative
To prove ‘due diligence’ to regulators
To help senior managers make decisions!
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
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47 Step 5: Up to date COSHH inventories CHECK that all substances / preparations you buy are supplied with a MSDS, and check that it goes to your HSE people.
Are there people outside purchasing that have delegated authority to purchase substances and preparations?
How do you ensure these people get the MSDS to the HSE team?
Tighten up these processes!
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
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48 Step 6: SVHCs
Your company needs to be able to tell customers and ECHA about all SVHCs within the products you make.
To do this, you need the information for all products you BUY, where they are…
PREPARATIONS that we incorporate into the product
ARTICLES that we incorporate into the product
In the absence of any other list, you can use the ‘declarable substances list’ from the SAE standard.
Watch for the issue of the first ‘candidate list’! ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
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49 Step 7: Authorisation
From next year, your company will need an ‘authorisation’ for continued use of SVHCs put onto the candidate list and transferred onto ANNEX XIV of REACH.
50,000 Euros per authorisation per use
Paperwork (Like COMAH) for the application process
The need for this will be stated on the MSDS.
For these substances, substitution plans are mandatory.
Start planning for these changes ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
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50 Other sources of guidance and advice http://www.reachready.co.uk
General Manufacturing Industry:
http://www.orgalime.org/publications/guides/reach.htm
Aviation/Automotive Industry:
http://www.asd-europe.org/Content/Default.asp?PageID=41
http://www.sbac.co.uk/community/cms/content/preview/news_item_view.asp?i=17018&t=0
Chemicals Industry:
http://www.reachcentrum.org/
Coatings Industry: ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
ASD: AeroSpace and Defense Industries Association of Europe
Large Companies:
Aeronautical (Airbus, Smith Aerospace, Eurocopter…)
Automotive (Volvo, Renault…)
CBI: Confederation of British Industry
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51 Official sources of guidance and advice ECHA WEBSITE:
http://ec.europa.eu/echa/home_en.html
European Commission:
http://ecb.jrc.it/reach/
DEFRA:
http://www.defra.gov.uk/corporate/consult/reach-enforce/index.htm
HSE: THE UK ‘Competent Authority’:
0845 408 9575
UKREACHCA@hse.gsi.gov.uk
The above list shows the official EU and UK websites where you can get more information about REACH and find contact names for help and advice.The above list shows the official EU and UK websites where you can get more information about REACH and find contact names for help and advice.