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IMF REACH Symposium Organic Coatings - Keeping up appearances after REACH

IMF REACH Symposium Organic Coatings - Keeping up appearances after REACH. Jim Casper Manager, Product Stewardship – Europe PPG Industries. REACH COMPLIANCE. THREE LEGS: SUBSTANCE SUPPLIER IDENTIFIED USE. REACH COMPLIANCE. THREE LEGS: SUBSTANCE SUPPLIER IDENTIFIED USE.

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IMF REACH Symposium Organic Coatings - Keeping up appearances after REACH

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  1. IMF REACH SymposiumOrganic Coatings- Keeping up appearances after REACH Jim Casper Manager, Product Stewardship – Europe PPG Industries

  2. REACH COMPLIANCE THREE LEGS: • SUBSTANCE • SUPPLIER • IDENTIFIED USE

  3. REACH COMPLIANCE THREE LEGS: • SUBSTANCE • SUPPLIER • IDENTIFIED USE

  4. REACH - Registration SUBSTANCE • REACH is a SUBSTANCE Regulation • Estimated 30,000 substances used in Europe • Toluene is a substance Xylene is a mixture of substances • most “raw materials” will be mixtures • Polymers do not have to be registered (provided the monomers are registered)

  5. WHAT IS PAINT? • PIGMENT – for colour and opacity • BINDER – for physical performance • SOLVENT – to aid/allow application

  6. WHAT IS PAINT? • PIGMENT • BINDER • SOLVENT and: • FLOW ADDITIVE • THICKENER • WETTING ADDITIVE • CATALYST • UV STABILISER • SLIP/ANTI-SCRATCH ADDITIVE • BRIGHTENER • SPECIAL EFFECT ADDITIVE • SLOW/FAST SOLVENT TO CHANGE DRYING SPEED • FLEXIBILISER • ……………………………….

  7. PAINT – RAW MATERIAL LEVEL

  8. PAINT – SUBSTANCE LEVEL (1)

  9. PAINT – SUBSTANCE LEVEL (2) > 30 CHEMICAL SUBSTANCES

  10. REACH COMPLIANCE THREE LEGS: • SUBSTANCE • SUPPLIER • IDENTIFIED USE

  11. REACH COMPLIANCE SUPPLIER • Manufacturer/Importer of Substance is responsible for REGISTRATION • Most users of chemicals are “Downstream users”, according to REACH • Your Supplier may not be the person responsible for Registration • Requires communication up/down supply chain

  12. REACH COMPLIANCE IMPACT THROUGH THE SUPPLY CHAIN Chemical Manufacturer Chemical Manufacturer Chemical Manufacturer Chemical manufacturer Raw Material Supplier Paint Manufacturer MSDS Recommended protection methods Identified Use Exposure data Customer (Paint User)

  13. REACH COMPLIANCE THREE LEGS: • SUBSTANCE • SUPPLIER • IDENTIFIED USE

  14. REACH COMPLIANCE IDENTIFIED USE • Identified Use must be included in the registration • Downstream user (e.g. PAINT) can only use the substance if his use is identified • Requires communication up/down supply chain • Identified Use not yet defined! (RIP 3.5 – Dec07/Jan08)

  15. MAJOR THREATS • Increased price of raw materials – as REACH COST is passed on down the supply chain • Substances which may not be supported by the supplier - REFORMULATION • Substances of high risk that will require AUTHORISATION - use in your factory - se by your customers • Workload/cost of collating data through the supply chain – PAPERWORK

  16. >1000tonnesCMR 1, 2 > 1 tR50/53 > 100t 100-1000 tonnes 1-100 tonnes 1 June 2007 1 June 2008 1 December 2010 1 June 2018 1 June 2013 1 December 2008 REACH - TIMELINE Registration of new Substances Agency start-up Pre-registration Phase-in substances registration

  17. SO WHAT SHOULD I DO? • AWARENESS: • All key staff aware of REACH • Impact on business understood • ANALYSIS: • Number of materials used understood • Suppliers position recorded • Business impact understood • ACTION • Product-specific actions (No change, Stop Sales, Re-formulate………….)

  18. ACTIONS REQUIRED NOW (1): RAW MATERIALS SOURCED IN EUROPE • Catalogue all raw materials used in products you manufacture • Identify the supplier for each raw material • Contact suppliers – confirm: • pre-register • Register • include your identified use

  19. ACTIONS REQUIRED NOW (2): CONSIDER OTHER MATERIALS • Products/Resins/Raw materials you import into Europe • Substances you manufacture • Ancillary chemicals (cleaning materials….)

  20. ACTIONS REQUIRED NOW (3): AUTHORISED SUBSTANCES • Consider options: • Reformulate • Seek Authorisation (with supplier) • Stop sales (from 2010……)

  21. Examples of CMR 1&2 • Strontium Chromate / Zinc Chromate • Lead pigments (colour pigments, lead silicate) • Di-Octyl Phthalate • Dibutyltin compounds (new classification) • N-methylPyrrolidine (new classification)

  22. ACTIONS REQUIRED NOW (4): COMMUNICATION WITH CUSTOMERS • Prepare to answer questions from your customers (continuity of supply…) • Prepare to discuss “identified use” • MSDS • New requirements from 1 June 2007 (Email address, Section 2 & 3 reversed) • Check and implement the changes

  23. SUMMARY • Know your formulations • Talk to your suppliers • Anticipate questions from your customers • COMMUNICATE!

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