For general queries regarding REACH please e-mail REACH@Schloetter.co.uk
The REACH (Registration, Evaluation, Authorisation & restriction of Chemicals) regulations are now in the phase-in period for registration, which takes place between 2010 and 2018, depending upon volume or classification.
The regulation impacts on all actors (a legal term used in the legislation, meaning companies) involved in the paint and metal finishing supply chain in the European Union. It will require the joint collaboration of all actors, especially in the flow of information,
The European Chemicals Agency (ECHA) has issued Chapter R12 guidance on the “Use Descriptor System” and actions required from our customers are now clearer.
Schloetter has Pre registered relevant pure chemicals that we manufacture and have received assurances that all our suppliers of raw material chemicals have done the same. It is as the REACH process goes into the individual chemical registration phase that the downstream uses will be sought.
Schloetter and our customers will be Downstream Users with the following effects:-
To date some substances supplied by the Schloetter group have ingredients listed on the candidate list and supplementary guidance is available as follows:
|WI REACH 004||SVHC Boric Acid|
|WI REACH 005||SVHC Disodium Tetraborate|
|WI REACH 008||SVHC Lead Methane Sulphonate|
Chromates and Chromic Acid has progressed on to the full Annex XIV SVHC list and given a sunset date, beyond which authorisation will be required for their use. Details of the sunset date, how authorisation works and alternative products are covered in the following guidance notes.
|WI REACH 003||SVHC Chromating|
|WI REACH 007||SVHC Chromic Acid|
All customers purchasing products listed on these SVHC supplementary sheets will automatically receive the appropriate guidance. If further substances used as Raw Materials by the Schloetter group appear on the candidate list then supplementary sheets will be produced and circulated.
As a company, our own efforts are in harmony with the whole of the European finishing industry through ongoing discussions with our raw material suppliers and trade associations. Particularly important is the need for us to relay information on the working conditions and exposure levels in the workplace and on emissions to the environment, along with the risk management measures currently in use during the application of our products.
Using the standard descriptors the following are two examples:
|A solvent for mixing into Paint for spraying onto glass bottle||A Raw Material for an electroplating additive|
|Use is ........||SU 10 "Chemical Formulation"||SU 10 "Chemical Formulation"|
|Process is .....||PROC 5 "Mixing and blending in batch processes"||PROC 5 "Mixing and blending in batch processes"|
|Environmental Release Category is....||ERC 2 "formulation into materials"||ERC 2 "formulation into materials"|
|The Product Category is........||PC9a "Coating and Paints, thinners, paint removers"||PC14 "Metal surface treatment products, including galvanic and electroplating products"|
|Use is ........||SU 3 "Industrial Manufacturing"||SU 3 "Industrial Manufacturing"|
|Process is .....||PROC 7 "Spraying in an Industrial Setting"||PROC 13 "Treatment of articles by dipping and pouring"|
|Environmental Release Category is....||ERC 5 "Industrial use resulting in inclusion into matrix" and
ERC 4 "Industrial use of processing aids and products not becoming part of articles"
This represents the extracted VOC element.
|ERC 4 "Industrial use of processing aids and products not becoming part of articles"|
|The Final Article is....||AC 4 "Glass and Ceramic Products with no intended release"||Varied|
Once these basic downstream coded uses are into the system then the SIEF (Substance Information Exchange Forum) for that particular solvent or raw material will develop it’s Exposure Scenario. At this stage application information will be gathered from as many places as considered necessary to evaluate exposure.
Schloetter at this stage will input information from our customers, each substance will have it’s own reasoning, but it could be as simple as needing confirmation that the paint is sprayed in an industrial environment in a similar manner to several hundred other paint sprayers in the EU. The Exposure scenario for spray painting will then be a supported use for that solvent.
In most cases Schloetter will already know and declare the customer use (as stated in our Operating Data) automatically, without reference to the customer. For instance, professional electroplaters buying a proprietary Zinc Brightener will be using it in an industrial environment for Zinc Plating.
When an Extended MSDS is produced including an Exposure Scenario for a particular chemical, Schloetter as the immediate downstream user has a duty to pass it down the "use chain", which will be done via a dedicated section on this website When the user receives it, they have a duty to ensure it forms part of their COSHH assessment. As most of our customers are professional users already applying best practice in handling and PPE then REACH is likely not to require any changes in practice.
Schloetter is continually being asked whether a particular formula is REACH compliant, we can assure all our customers that every substance will continue to be compliant. All our safety data sheets are in the process of being changed to match REACH standards by re-numbering paragraphs and adding extra contact information well ahead of any deadlines.
The deadlines will arrive with Schloetter as a downstream user, product by product, and as the requests arrive we will ask our specific customers, that take blends containing that specific chemical for their uses. If the SIEF requests it, detailed usage and safe handling information to help them prepare their exposure scenario.
Schloetter will not be asking general questions about general applications at general times. The downstream chain is encouraged by the raw material chemical suppliers to adopt the 3 P principal. Patience, Proportion and not to Panic.
Please rest assured that we will ask our customers, specific questions at specific times and until we write to you about a specific product, you will not need to do anything related to products supplied by Schloetter.
Schloetter are also asked for substance registration numbers. The legislation does not require these to be relayed up and down the supply chain and a major chemical supplier is issuing the following statement. “In line with CEFIC’s recommendations, it has been decided not to communicate pre-registration numbers since a pre-registration number alone is not sufficient to guarantee compliance within REACH”.
We have created a specific e-mail address to process all REACH data as follows: firstname.lastname@example.org
There is a lot of guidance published on the ECHA website: In the meantime please contact us if you would like to discuss any aspect of this subject, where we shall endeavour to assist.
Further information on REACH regulations is also available at the HSE Website