Guidance: what you need to know
REACH
Headlines
- Allergies, asthma, reproductive disorders and certain types of
cancer are on the rise in Europe. It's thought that chemicals may
be contributing to this increase
- The European Trade Union Confederation suggests that a third of
all recognised occupational diseases in Europe are related
to chemical exposure
- The European Commission estimates that there isn't enough
information about effects and safe handling for 99 per
cent of chemicals
- Only chemical substances that have been pre-registered with
REACH can now be legally imported or manufactured in quantities
over 1 tonne a year
What is it?
REACH is a European Community Regulation which replaced several
European directives and regulations with a single system for
managing chemical hazards. It's not new - it took effect
from 1 June 2007 - but many organisations are still in
the dark over its implications and effects, and in particular may
have missed the 1 December 2008 deadline for pre-registration.
REACH stands for the registration, evaluation, authorisation and
restriction of chemicals.
The Department for Environment, Food and Rural Affairs gives
this explanation of REACH:
Registration of basic information of substances
to be submitted by companies, in a central database
Evaluation of the registered information to
determine hazards and risks
Authorisation requirements and restrictions
imposed on the use of high concern substances. This process will be
used for both new and old...
CHemicals.
The European Chemicals Agency, based in Helsinki, will
co-ordinate registration of an estimated 30,000 chemicals over the
next decade.
The Health and Safety Executive is the competent authority for
REACH in the UK.
Why has it been introduced?
The key aim behind the new regulation is to improve
communication between manufacturers and downstream users to help
protect people and the environment. The idea is to share better
knowledge of the nature and impact of chemical substances across
manufacturers, importers and users. Manufacturers and
importers are responsible for understanding and managing the risks
of using the chemicals they supply and providing information to
users.
What does it cover?
'Chemicals' may exist as substances (a chemical element and its
compounds in a natural state or as a result of manufacturing),
preparations (a mixture or solution of two or more substances) and
articles (items containing substances which will be released when
they're used). Normally, it's the individual chemicals in a
preparation or an article that need to be registered.
Nearly every organisation is a downstream user, as chemicals are
found in paint, glue and cleaning materials.
If you buy the chemical from outside the EU (in sufficient
quantities) you also count as an importer for REACH purposes, even
if you only use the chemical within your organisation.
If your organisation makes chemicals to supply to others, or to
use within the organisation, you're considered a manufacturer under
REACH.
Chemical substances manufactured or imported under 1 tonne don't
need to be registered. Annex IV of REACH lists chemicals (such as
distilled water and carbon dioxide) which don't need to be
registered. The annex was amended in October 2008, and may change
again in the future.
What difference will it make?
Many organisations are still unaware of the effect that REACH
could have on them. For example, chemicals that REACH categorises
as 'substances of very high concern' are subject to extra
controls, and in the long term may become illegal. Some chemicals
you use may disappear from the supply chain. Risk assessments will
also be affected, with additional information provided to users in
safety data sheets.
Manufacturers and importers now have to provide and share
information on the hazards of chemicals they manufacture or import
from outside the EU.
What do I need to do now?
Decide whether your organisation is a manufacturer, importer or
downstream user (remember, you may fall into more than one
category) and read the appropriate HSE guide for users, importers
or manufacturers.
In brief, manufacturers and importers should have pre-registered
information about chemical substances with the European
Chemicals Agency before 1 December 2008. If your organisation
hasn't done this, you need to contact the UK REACH compliance
team.
For the time being, downstream users should continue to follow
the Control of Substances Hazardous to Health Regulations, making
sure that each chemical used is risk assessed, taking account of
safety data sheets and looking at how the chemical is used within
the job.
If your organisation uses chemicals in an unusual way, you
should contact your supplier to make sure they are aware of how you
use them. If you don't want to let your supplier know how you use
chemicals (for example, because of the need for commercial secrecy)
you should contact the European Chemicals Agency direct
to make sure that your method of use is registered, and that hazard
information is shared.
Watch this space
In June 2009 the European Chemicals Agency will
publish its first recommendation of priority substances for
authorisation, and an inventory of restrictions. Deadlines for
registration and decisions on further substances stretch as far
into the future as June 2022.
In future issues of Connect, we'll look in more detail at the
responsibilities of manufacturers, importers and downstream users
under REACH.
IOSH viewpoint
IOSH welcomes REACH, seeing it as having a positive effect on
health and safety by improving communication between chemical
suppliers and users, making manufacturers and importers take more
responsibility for the substances they market, and steering
employers in their duty to control exposure risks.
But to achieve this, we believe it's essential that the HSE has
the right resources to carry out its role properly in the UK - for
example covering extra training for inspectors.
We've also recommended that 'Chemical essentials', an online
guidance tool for health, safety and environmental advice on using
chemicals at work, should be used to store information about
exposure scenarios and risk management measures from manufacturers
and suppliers.
IOSH events
The following branches are holding events on
REACH:
Related links: