REACH stands for the Registration, Evaluation, Authorisation and Restriction of Chemicals, and is an EU regulation for the control of chemicals in Europe.
The aims of REACH are:
Companies who manufacture or import substances at 1 tonne or more per year are required to 'register' that substance with the European Chemicals Agency (ECHA), and this must be done by 31st May 2018. This is the final deadline for pre-registration for substances in the 1-100 tonnes per annum brand.
Manufacturers and importers have the most duties under REACH; you can find out more information about the roles and duties of REACH on the HSE website. For this article we are going to focus on the duties of organisations that use chemicals under REACH.
A downstream user is any company that uses chemicals under REACH and CLP located within the European Union. Downstream users also use a substance / substances individually or as part of a mixture, in work-based processes.
In order to prepare for this deadline, here’s what you should be doing:
1. Develop a schedule of the substances that your organisation uses.
This should list each chemical or substance that your organisation uses, where they are used and how, the amounts used and the frequency of use along with the name and details of the supplier so those outside of the EU can be identified.
2. Determine which substances are essential and which are not.
When considering how essential a substance is to the activities undertaken by your company, you may find that those which are harmful could be replaced for non- or less harmful substances with little or no impact on productivity.
3. Contact your suppliers.
You should contact the suppliers of your substances in order to determine whether or not they have been registered, or will be by the deadline, and request updated Safety Data Sheets (SDS). If your supplier will not be registering the substance, consider reviewing your processes and procedures. If the substance is imported from outside of the EU you may wish to determine whether your supplier has appointed a representative for the EU, as if not you may be responsible for reporting it.
4. Once SDSs are updated, review your risk assessments.
Updated SDS may include new information, such as exposure scenarios or risk management measures. If new information is relevant to the ways in which your company uses the substance in question you will need to assess whether or not your existing controls are suitable and sufficient. If not, new control measures will need to be considered and your risk assessments will need to be reviewed and amended accordingly.
5. Finally, consider Brexit.
If you are purchasing substances from a company in the UK as or for any manufacture outside of the EU, you should ask them to clarify what their plan is regarding UK customers post Brexit.
If you have any questions about your duties under REACH we are here to help. Do not hesitate to contact us on 01394 389683 or firstname.lastname@example.org.