REACH Consulting Services
REACH is very complex and presents an enormous challenge for US chemical companies doing business in the EU. If you need help unraveling the complexities of REACH we can help.
Background
In June of 2007 the new EU (European Union) REACH (Registration, Evaluation and Authorization of Chemicals) came into force. This regulation will require the registration of all chemical substances imported into or manufactured in the EU in quantities of 1 metric tonne per year (TPY) or more unless exempted. All new chemicals will require immediate registration after June 1, 2008. Chemicals already on the market can take advantage of phased-in registration by pre-registering those substances during the period of June 1 – December 1, 2008.
Important Facts
All registrations are legal entity specific – every importer/manufacturer must file their own registration.
- Registrations can only be filed by an EU legal entity
- US exporters can designate an “only representative” to register their chemicals (this makes their EU importers downstream users – not subject to registration)
- Data requirements for registration are dependent on the quantity manufactured/imported.
- Certain specified substances are exempt (naturally occurring, food, medicinals (drugs), pesticides.
- Chemical intermediates may be partially exempt (if used under strict control)
Phase-In Registration Dates
November 30, 2010 >=1000 TPY, >= 100 TPY and classified as N R50/53 (very toxic to the aquatic environment with long-term effects) and all CMR (carcinogens, mutagens, reproductive toxins – Category 1 and 2) >= 1 TPY
May 31, 2015 >=100 TPY (not registered above)
May 31, 2018 >=1 TPY (not registered above)
How IHSC can help
- Advise management and technical staff on the REACH regulation.
- Assist in determining what chemicals may require registration under REACH
- Identify how you can assist your EU importer to comply with REACH
- Assist in identifying an “only representative” in the EU to register your chemicals
- Prepare responses to customer inquiries
- Assist in the preparation of the Chemical Safety Assessment (CSA) and exposure scenarios (e-SDS)
Chemical Safety Assessment/Chemical Safety Report
Chemicals manufactured or imported in amounts of 10 TPY or more require a Chemical Safety Assessment to determine if the chemical is (a) hazardous, (b) what the safe levels of exposure are for humans and the environment and (c) what risk management measures are required to handle the chemical safety. These risk management measures are use-specific and must be appended to the safety data sheet (SDS) as exposure scenario and passed on to downstream users.
As a full-service industrial hygiene-consulting firm, IHSC can assist your company in developing the exposure data necessary for the Chemical Safety Assessment. With more than 30 years of chemical exposure control experience, our professional staff of certified industrial hygienists can assist your company in developing the use-specific exposure control recommendations needed for the SDS. Our staff of MSDS and Hazard Communication professionals can work with you to develop format and content for the required e-SDS.
