REACH High time to prepare for REACH

1. REACH High time to prepare for REACH Marian Byron

2. Potential for Industry to be in complete turmoil in 2 years time. • Will come into force 2007/2008 • The scope for chaos is immense if all stakeholders not prepared.

3. Why do we need REACH? • Current system of chemicals management inefficient • 40 different pieces of legislation • different rules for new and existing substances • national public authorities responsible • lack of information about 30,000 (existing) substances • concerns about the impact of substances on public health and the environment

4. Changes • Before : legislation related to assessment of hazard and conveyance of hazard as part of label and in data sheet prior to placing on the market. Other legislation to cover the carriage, transport and use of these materials • Now: related to manufacture, importation, distribution and use of chemicals and articles containing chemicals and goes further than conveyance of data but implies duty of care from cradle to grave. • One piece of legislation to cover all. • Before: responsible for providing information on hazard. • Now: must provide information on Risk. Need to get information from down the supply chain

6. Aeronautic Industry Agriculture Aquaculture Automotive Industry Chemical blenders and Importers Construction Industry Healthcare Hygiene and Cleaning Products Manufacturers Maintenance Activities, e.g. Paint shops, Motor Repairs Man-made Fibres Marine Industry Mechanical Workshops Medical Devices Metal Workshops Mining and Extraction Packaging and Labels manufacturers Pest Controllers Defense Dry cleaning Electronics and electrical industry Optical manufacturers Pharmaceuticals Photographic industry Glass, Plastic, PVC, Plastic Component Manufacturers Printing Pulp and Paper Semi-conductorsTelecommunications, Cable manufacturers Textiles Toys Utilities – Energy Production, Water Treatment, Transport

7. Basic overview of REACH Elements • Pre-registration (18 months) Basic Information • Registration – Submission of full dossier. Amount of information depends on the tonnage and the level of risk. • Safety Assessment and Report (10t) • Substance and Dossier Evaluation • Authorisation • Restriction

8. Challenges for Each Player in the REACH Arena • Manufacturer (may end up having responsibility beyond their control) • Importer Distributor – providing/ accessing information • Downstream user (uses, safety report, supporting uses, authorisation ) • Companies may be caught in number of Categories • Competent Authority

9. Key concerns • Who is going to provide the know how (practical information) • How to get the information up and down the supply chain • Where is the competency to be sourced to make registrations, do safety reports etc. • Downstream Users – what is required of them?? • Where does REACH end and Chemical Agents take over??? • Authorisation? What is going to be taken out of the market. How to identify substitutes???

10. GHS – Also coming down the track • All materials which will be covered by REACH will need to be re-labelled according to new scheme. • Different / additional label elements, i.e.. • pictograms, signal words, hazard statements and codification, precautionary statements and codification; examples: No indications of danger, but signal words „Danger“ and „Warning“ • Hazard and precautionary statements and their codifications are currently under discussion at the UN SCE

11. Risks for SMEs and DUs • Increased costs • Withdrawal of substances • Disclosure of confidential business information • One more task in compliance with a large legislation burden.

12. Work • We have one year to get ready • Huge amount of work. • Who is to do what? • RIPs work to be finalised • Guidance documents to be put in place • Help desk established. • Roles of Trade Associations/Competent Authorities • How to • Get in contact with other registrants • Get information up and down the supply chain • Prepare dossier for registrations • Prepare CSRs • Prepare dossiers for authorisation • Prepare for classification and labelling under GHS

13. Concerns • Confusion • Complexity • Costs • Capacity • Co-operation/Competition • Competence • Conveyance of Information • Constancy of Raw Material Supply • Contained in Articles • Complementary Legislation • Compliance!!!! • Conveying/Sharing Information. • Conversation – translating into different languages

14. See the Opportunity not the Challenge • Opportunity • Improve chemicals management • Improve confidence in chemicals and industry.

17. Element: WomanSymbol: WoDiscoverer: AdamAtomic Mass: Accepted as 50 Kg, but varies from 45 Kg to 250 KgPHYSICAL PROPERTIES. 1.- Surface usually lined with painted film (in the order of 0-6m to 0-3m).2.- Boils at nothing, freezes without reason.3.- Melts if given special treatment.4.- Bitter if used incorrectly.5.- Found in various states ranging from virgin metal to common ore.6.- Yields to pressure applied at the correct points. CHEMICAL PROPERTIES. 1.- Has great affinity for gold, silver, platinum and precious stones2.- Absorbs large quantities of expensive substances.3.- May explode spontaneously without prior warning and for no reason.4.- Insoluble in liquids, but alcohol saturation increases activity.5.- Most powerful income-reducing agent known to man. COMMON USE. 1.- Highly ornamental, especially in sports cars.2.- Can be a great aid to relaxation.4.- Useful for general cleaning, scrubbing, washing, rubbing, etc. TEST. 1.- Pure specimen turns pink when discovered in the natural state.2.- Turns green when placed next to a better specimen.HAZARDS. 1.- Highly dangerous except in experienced hands.2.- Illegal to possess more than one.

18. Element: ManDiscoverer: God ( responsibility rests with producer) • Atomic Mass: Accepted as 75 Kg, but varies from 65 Kg to 250 KgPHYSICAL PROPERTIES. 1.- Varies from irregular, smooth, toned and covered with bristles. • 2.- Slow to react and quite inert unless suitably activated (going for a pint?) • 3.- Melts when appropriately flattered and adored4.- Bitter if impeded in forming mixtures with similar bodies (i.e. drinking/football buddies) • 5.- Found in various states from immobile, intoxicated, dormant, at work. • 6.- Impervious to pressure of any subtle variety, need strong pressure of very clear intent.CHEMICAL PROPERTIES. 1.- Has great affinity for alcohol, rounded polymeric materials, non ionizing radiation (TV) • 2.- Absorbs large quantities of carbonaceous materials, and OH molecules.3.- May explode after long latency periods of inertia, without prior warning 5.- Most powerful labour demanding agent known to woman COMMON USE. 1.- Highly effective particularly in commenting on global and national affairs (late at night particularly) • 2.- Can be a great aid to encouraging exercise (cleaning etc) • 4.- Useful for (still to be fully identified) • TEST. 1.- Pure specimen reacts violently to saline (particularly tears) which can promote direct repellant reaction2.- Turns green when placed next to man attached to better female specimen or CAR.HAZARDS. 1.- Highly dangerous except in experienced hands.2.- Impossible to handle more than one.