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Deurowood REACH Newsletter 1

Please also find additional information in our Deurowood REACH Newsletter 2

On 1^st of June 2007 the new European chemicals regulation REACH 1907/2006 entered into force. To ensure a smooth implementation within the supply chain - suppliers, Deurowood and their customers - Deurowood has started to work on this subject in 2005.

We will have all substances contained in our products preregistered (by our suppliers or ourselves) by 30^th of November 2008 to be able to keep within the transitional periods for the registration following. This will guarantee that no modifications to our products will be necessary as a result of REACH until at least 2010.

We have been frequently asked to confirm that our products comply with this regulation and that they can also be supplied in future. All transitional periods will end on 31^st of May 2018 - after that date there will only be REACH-registered product components in the market.

It will not be necessary to modify existing material safety data sheets (MSDS) due to the formal changes required by REACH. The existing MSDS that comply with the regulations of directive 91/155 may also be used after 1^st of June 2007. According to the new regulation the chapters 2 and 3 of new MSDS will be mentioned in reverse order. We will immediately modify existing MSDS if new risk management measures are announced.

Deurowood aims at an efficient implementation of REACH. With regards to our customers and suppliers we consider the implementation to be a part of our service. Therefore feel free to send your questions to REACH@deurowood.at. We will keep our business partners informed about future changes or developments by the Deurowood REACH Newsletter.

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REACH – a challenge for you and us

European chemical law is being fundamentally revised when the so-called  "REACH Directive" R(EC) 1907/2006 of 30.12.2006 comes into force. This change will not only affect companies in the chemical industry, but also almost all economic sectors as users of substances.

Although the abbreviation REACH stands for "Registration, Evaluation and Authorisation of Chemicals", this acronym for the new directive is misleading, as it is concerned with all materials in the entire value added chain. It makes no difference whether these materials are chemical substances, metals, plastics or natural substances or whether these substances are used as such, as preparations (e.g. varnishes, cleaning agents, cosmetics,…) or in products (e.g. motor vehicles, clothing machines, furniture…). REACH therefore not only affects large companies in the chemical industry, but also many small and medium-sized companies which use chemicals.

Registration
Registration means that all substances manufactured in or imported into the EC must be reported to a central agency (based in Helsinki) by electronic means.

The obligation to registration affects every manufacturer of substances and interim products and each importer (from outside the EC) of a substance (also in a preparation) from one ton per year upwards; substances in products are also to be registered if they are intentionally released (e.g. pigments in an ink cartridge) - this registration is therefore related to the use.

It demands determination of data on the properties of a substance and the assessment of the risk in each use - for which intensive communication between the supplier (manufacturer, importer) and the customer (formulator, commercial final user, manufacturer of products) along the entire value added chain right down to waste is necessary.

In three quantity-dependent phases, this registration extends across more than a decade; however, these transitional periods can only be made use of if a so-called preliminary registration has been carried out.

Evaluation
The data reported in the registration are subjected to an official assessment (evaluation) depending on the annual quantity or properties of the substance, in which context the authority verifies the correctness of the data and the measures proposed, which are intended to guarantee the safe use of the substance in each application.

In the course of this assessment, holding of additional tests and the improvement of the risk management measures in manufacture or use can be demanded.

Authorisation
In addition to registration, an admission procedure, authorisation, has been planned for particularly worrying substances. This is to ensure that substances with a high risk potential (for man and/or the environment) are only used under strict control or are replaced by alternatives.

Potential candidates for authorisation are the so-called CMR substances (carcinogenic, mutagenic, reproduction-toxic) or those which can lead to large problems in the environment (so-called PBT and vPvB substances) due to bad decomposability and a high enrichment ability or also toxicity.

For the authorisation, examination of possible alternatives and also, if applicable, examination of the socio-economic significance of these substances in their use have been planned. Existing bans on the substances or limitations of use are transferred to REACH and also be extended even further.

Communication
As in existing law, the material safety data sheet is provided as the central instrument of communication across the entire delivery chain from the manufacturer down to the commercial final user.

With REACH, it gains in importance and is extended by the results of the safety assessment; over and above this, forwarding of information according to REACH can become necessary for non-dangerous substances (and preparations) as well.

In addition, the databases to be produced by the central agencies will also create transparency for the public.

REACH & Deurowood
We accept the challenge and will remain up with the state of play: by Autumn 2007, Deurowood will extend its competence by completing the certified training as a "REACH Multiplier"[1], in order to guide Deurowood and its partners in the delivery chain securely through the imponderables of new chemical management.

Deurowood Produktions GmbH
deurowood@deurowood.at
www.deurowood.at