Just been walloped with getting my head round this latest load of old tosh. Does anyone have any idea what it means?????
See here :-
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REACH Legislation WTF?
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Posted 3 years ago #
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i think the HSE site is fairly self explanatory. I think there's still a bit of toing and froing as the central commision, for REACH, was running behind with building and staffing HQ in Finland.
Posted 3 years ago # -
You reckon ?
Generally, it applies to all individual chemical substances on their own, in preparations or in articles (if the substance is intended to be released during normal and reasonably foreseeable conditions of use from an article).
Items defined as being an article are and I quote again
a car, a battery and a telephone.
So I presume from that that these items are deemed to fall within the scope of REACH, (as otherwise who in their right mind would use them as examples of things that do?), so the way I would read that is that as everything is either a chemical, a preparation or an article as defined by the HSE website that the legislation therefore applies to absolutely everything which is either manufactured or imported in volumes greater than one tonne per annum.In which case thats rather a lot of work frankly!
G
Posted 3 years ago # -
yes and no. By setting up a central register, each chemical substance would only have one REACH assement. So if someone has already registered it & your company mfgs or imports more than a tonne, you use the assesment for your registration.
Our company started looking at it a while ago and quickly scanned our BOMS and discovered that we only imported a handful of items within scope.
Posted 3 years ago # -
If you don't mind me asking Lobby, how big is your company?
G
Posted 3 years ago # -
I work for a big chemical co and yes, this is a very real (and worrying in some cases) development.
For the consumer of finished goods, either domestic or industrial, it will mean very little but for users of chemicals in processes or for making downstream articles then it could do.
The definition of article is correct but you did cut the definition off in its prime (it went on to say "if the substance is intended to be released during normal and reasonably foreseeable conditions of use from an article") So a battery is reasonably expected to be recycled and release a certain amount of let's say cadmium during that process. The battery importer therefore picks up an obligation for the amount of cadmium that they have caused to be in the European community as a result.
If you need a more expert opinion I can put you in touch with a guy who consults on the process. What business are you in, by the way?
Posted 3 years ago # -
lobby dosser - you're right that you can enter consortia with other importers to pool and share data etc. but you still have to do your own registrations and pay your share of the data costs. You can't just assume that because someone else has registered it and stumped up the cash to support the registration that you can freeride (yes that is the term) on their registration
Posted 3 years ago # -
The definition of article is correct but you did cut the definition off in its prime
I've just spent an hour on the phone to the HSE helpline discussing just that very point, and apparently my reading is correct, in that an assumption is not acceptable, therefore if I bring in a car and it contains less than 0.1% of a substance of very high concern everything is cushty. However, if that substance is in a gear knob and I then import that as a spare I have to know and have to have dealt with it in advance. Ergo I have to go through the process for everything that passes through my business regardless of that definition, components, spares, finished goods, packing tape, absolutely everything!
Personally, I am a partner in a small business importing and distributing products, and employing 5 people, two of which are part time. We are still reeling from the ROHS regulations, the net result of which was to ratchet up all our costs by 15% with no discernable benefit to anyone.
What I don't quite grasp is how such a far reaching and costly piece of legislation can appear over the horizon and we ahve not heard a dicky bird until today!
And breath.....
G
Frankly does my bloody head in, and quite honestly I'd love to have the twonk who came up with this, which is apparently to track done a whole 15 substances and eventually do something about them.
Posted 3 years ago #
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