At Lucite International we have been preparing for the introduction of REACH since 1998. Our preparations have involved working closely alongside trade associations in Europe, the USA and Japan to track developments and to ensure that we fully understand the implications for both our raw materials and the products we sell. Here, we share our understanding, and explain what REACH will mean for LI and our partners in the supply chain.
Responsibility lies with manufacturers and importers
In a nutshell, REACH will provide a single, standardised framework for the safe management of chemicals within the EU. It places responsibility on manufacturers, like ourselves, and importers to ensure that the substances, in quantities greater than 1 tonne per year, do not adversely affect human health or the environment. A core part of this responsibility requires industry to provide comprehensive documented information for all qualifying substances. The availability of this transparent and uniform information will enable users to assess potential risks and ensure adequate controls are in place. It will also create a robust platform from which the industry can innovate and grow safely in the world arena.
Registering chemicals and use scenarios
In the first instance, chemicals must be pre-registered to take advantage of the phased introduction of the regulation. The next step is to prepare use scenarios and to assess the exposure associated with the use of the individual substances against given toxicology data. Development of use scenarios will mean close collaboration with customers to fully understand how a substance progresses through the supply chain and how it is placed on the market. This is also key to ensuring that all uses for products are included in the final registration dossier. LI is already engaged with its customers in this respect to try and understand how this may work. Once assessed and approved, uses will all be summarised on the safety data sheet for that chemical and any restrictions highlighted. If a data sheet does not cover a particular application, then there is an obligation for the user to review that with the supplier to get it included and the registration updated or to register it separately if they wish to keep it confidential
Preparations underway at LI
To date, a substantial amount of work has been done with suppliers to ensure that key raw materials will be supported and that LI’s manufacturing processes will not be affected. As part of this work, our business systems are being upgraded to ensure that we will be able to demonstrate that the materials we purchase are registered for our own and, where appropriate, our customer uses, and that our products are fully registered for customers needs.
Dates, weights and special concern product
The deadline for registration is phased according to the quantity of the substances being manufactured or imported. Chemicals of 1000 tonnes or more per year (which includes methylmethacrylate), or those of highest concern, must be registered by December 2010. Substances 100-1000 tonnes per annum must be registered by June 2013, and all substances of 1 tonne or above must be registered by June 2018. REACH may also require authorisation for manufacture or use of substances of highest concern. These are cancer-forming chemicals (category 1 or 2 carcinogens or mutagens), chemicals hazardous to reproduction (reprotoxins) or substances with high environmental impact (either persistent, bio-accumulative and toxic or very persistent and very bio-accumulative). The commission will develop and manage the list and authorise the use of these chemicals on a case-by-case basis.
Dedicated resource
In recognition of the wide-ranging impact REACH will have across our business, LI has established a multi-disciplined project team to handle both the strategic and day-to-day management of the changes that must be made to ensure compliance with the new legislation. Sponsored by the Company’s Executive, the REACH team draws on the knowledge and experience of people from each of our manufacturing sites as well as purchasing and sales. The team is there to provide practical help and advice both internally to colleagues and externally to customers, partners and suppliers on any issue relating to REACH.
Find out more about the legislation and its implications for your business in FREFLOW REACH, our new mini guide that can be downloaded from this site or follow the useful links to other authorities. For more specific details on LI’s approach, please contact Fiona Smith at: reach.info@lucite.com
