REACH PRESENTATION The Heath

Wed 4th June

• Graham Bayliss

• Reagent Chemical Services Ltd trades under the brand of Reagent

• SME of approx. 30 employees

• Based on Whitehouse Industrial Estate in Runcorn

Introduction

• Founded by Derek Millard and his wife Norma in 1979.

• Ex ICI employee who bought out the old Standards Laboratory at Winnington, Northwich.

• Initially local business, mainly ICI.

• Developed into multi-million pound turnover.

• ReAgent is now in the third generation of management.

• Recent success due largely to website and e-commerce.

Company History

• Core business is chemical blending

• Highly accurate standard solutions and general chemical reagents

• Strength is flexibility to manufacture bespoke products to customers individual needs.

• Supply automotive, aerospace, pharmaceutical industry and MoD

• Batch manufacture size from millilitres to several thousand litres.

• Facilities to fill sachets and ampoules

What services Does ReAgent Offer?

Certification

• ISO 9001 Quality Standard

• ISO 14001 Environmental Standard

• Investors in People

• Working towards OHSAS 18001

• Home Office and Local Authorities

My Role at ReAgent

• Trainee laboratory technician progressed to supervisory and managerial roles

• Part-time study to achieve MRSC CChem status

• Works Manager then switched to Quality Manager

• Systems Manager responsible for QHSE management systems to ISO standards, compliance with relevant legislation and Investors in People.

• Implementation of new EU legislation, CLP 1272/2008 and of course REACH.

How Does REACH Affect ReAgent?

• We are a Downstream User (DU)

• Not classed as a manufacturer so no duty to register products

• NOT REMOVED FROM DUTIES UNDER REACH

• Supply of information up and down the supply chain

• Only use substances registered with our intended uses

• Provision of Safety Datasheets (SDS) with our products

• Ensure supplier SDS are made available to all who need them

• Implement the necessary Risk Management Measures

How Does ReAgent Comply?

• Identification of all raw material suppliers and notification of our intended uses with standard Descriptor Codes.

• All supplier details are held on company intranet system

• Only REACH compliant companies are used

• Simple questionnaire to identify compliance

• Safety Datasheets are generated from software linked to the product classification

• Consider restrictions on use and SVHC’s

Problems Meeting Compliance

• Time and resources

• Fitting in between other responsibilities

• FAILURE TO COMPLY IS NOT AN OPTION

• Label classification and SDS generation

• Finding sources of information

• Communication within the business

• Maintaining awareness of the directors when making future business decisions

• Integration with other legislation, CLP etc

• Consistency between information sources

Effects of CLP on ReAgent

• Impact has been as big if not greater than REACH

• Several hundred products to be re-classified by June 2015

• Large changes to label design and SDS format

• REACH and CLP legislation is massive and time consuming to understand

• Increase in the amount of hazard categories

• Choice of most appropriate P statements

• Under new classification criteria there are potentially more products that will be classed as hazardous.

• Effect on transportation costs eg. Corrosive products.

Information Sources and Inconsistency

• In theory REACH and CLP (GHS) are designed to achieve consistency, in practice still far from this

• Available sources of Information

Supplier SDS

ECHA website

ESIS (European Substances Information System) website

The CLP Regulation

• If the theory worked then all the above would agree, however this is not the case

• Substance classifications can differ between a) Suppliers

b) Suppliers and ECHA c) ECHA and ESIS

• The CLP Regulation only contains Partial classifications

Information Sources and Inconsistency

• Headache for SDS compilation, especially mixtures

• Which one is correct?

• Under REACH downstream users must compile their SDS and classify products on information received from suppliers.

• Discrepancies can be passed further down the supply chain

• Personal experience has indicated the greatest potential for difference is in self classification from set criteria

Information Sources and Inconsistency

• Tin Dichloride Dihydrate or Stannous Chloride

• Supplier

H314 – Causes severe skin burns and eye damage

• ECHA

H315 – Causes skin irritation

H317 – May cause an allergic reaction

H319 – Causes serious eye irritation

H332 – Harmful if inhaled

H335 – May cause respiratory tract irritation

H341 – Suspected of causing genetic defects

H361 – Suspected of damaging fertility or the unborn child

H373 – May cause damage to organs

H410 – Very toxic to aquatic organisms with long lasting effects

Information Sources and Inconsistency

• Third party supplier

H302 – Harmful if swallowed

H314 – Causes severe skin burns and eye damage

Toxicological and Ecotoxicological Data

• Required for sections 11 and 12 of the SDS

• Again information can be different between suppliers and ECHA

• Which do we use?

• ECHA score data with a reliability rating of 1 to 4

• Should use supplier data but ECHA often has information quoted with a lower LD50 value – more appropriate?

Information Sources and Inconsistency

• SDS Format

Many are still in the older format

Incomplete

Include the statement ‘No information available’

• The whole process of classification and SDS generation can be difficult and confusing

• Contradicts what it sets out to achieve

Overcoming Problems of REACH and CLP

• Unfortunately there is no easy answer

• Generic e-mail sent to all suppliers with intended uses and check our sales to customers were for registered uses

• Product classification and SDS generation assisted by software

• This must be updated and installed before June 2015

• Best to classify from scratch applying the new criteria rather than use the translation table

• Software manufactures have released a new package but it comes at a price

• IT staff have helped to design new label templates

• Training has been a key issue throughout the business

• Several hundred products have been removed

• Where possible generic SDS are used

Do SDS serve their purpose?

• Probably not taken as seriously in the past

• Since introduction of REACH this appears to be changing

• More customers actually question the content than in the past

• The answer must be ‘Yes’

• This places pressure on the authors to get information correct

• Risk assessments rely on their content

• Misleading information may have serious consequences

Future Outlook and Conclusion

• NO OPTION BUT TO COMPLY – TIME, MONEY AND EFFORT

• ReAgent will continue to introduce new products and remove those that are uneconomical

• To achieve consistent information transfer I estimate about 10 years

• Exposure scenarios are currently very limited and will need to be included as part of the SDS

• REACH and CLP must be good for the chemical industry but can be a real burden

• Our own SDS will need to be constantly updated as more Registration Numbers become available

Future Outlook and Conclusion

• In the short-term REACH will be costly and a drain on resources

• With threats of prosecution and damage to company image pressures to comply increase

• In the long-term REACH can only be beneficial to us all for identification of chemical hazards

Contact Us

For more information about ReAgent, please visit www.ReAgent.co.uk

We’d love to hear from you. Send us an email at enquiries@reagent.co.uk or call us on 0800-9555-798