REACH Compliance

Many American manufacturers believe the have nothing to worry about regarding REACH because they don't export to the European Union. That's a mistake and potentially a big one!

 Although the biggest impact will be felt by those who import products into the EU, the global supply chain is effected by every substance that is or will be regulated. Twenty-nine (29) substances are currently listed as SVHCs and eight more are currently under review. ECHA has indicated that it plans to expand its list of potentially highly dangerous chemicals to 135 from a current 29 by the year 2012. This is too slow for the NGO's like Greenpeace and to fast for industry company executives. What is evident is that momentum for regulation is building. Of more concern for American companies are the legislative initiatives that have been fueled by the EU initiatives like REACH, ROHS, EuP and more. States have begun to pass their own laws that address similar substances like BPA and the EPA has begun to move forward on a TSCA reset and more. Suppliers to large multi-national companies are beseiged with requests for detailed material declarations for the products they supply.

Do you know your obligations when you receive a request to provide a detailed materials analysis of your products?  Are you obligated to provide proprietary information? Do you have a standard format for supplying the requested information?  

Confusing, friegthening, costly, distracting? Help is available.

Most of the current REACH compliance firms can be classified into two categories; international testing labs that hope to drive materials testing business to their labs by offering REACH consulting services and supply chain consulting companies that view REACH as a risk management exercise and emphasize tools like contract management. Tanzco has unique ability to provide both the technical and supply chain management expertise to provide a comprehensive customized solutions in a cost effective manner. Through our network of associates we can provide the full spectrum of services to meet your company's REACH compliance needs. We offer:

 

1. Training (on-site)      

 i. Management Overview      

 ii.  Employee Awareness Training

2.  REACH Scan – To help define and understand your risks and obligations and develop alternative   courses of actio

          i. Gap Analysis       

ii. Action Plans      

iii. Process Mapping      

iv. Chemicals Review

3.  BOM Scrubbing

4.  Compliance Programs     

  i.     Environmental Strategies

  ii.    Design and Implementation of Chemical Management Programs that are REACH and  ROHS Compliant

  iii.   Third Party Audits            

a. Letters of Assertion that your firm is REACH compliant       

iv. Correspondence Programs           

a. Policy Statements            

b. Website Statements           

c. Response forms for customer information requests

5.  Integration with ISO 14001

6.  SIEF Representation w/Tox Focus

7.  Dossier Preparation w/Tox Focus

8.  Update Services      

i.    Subscriptions of various lengths that provide legislative updates and change notices       

ii.   Period reviews of all new products and chemicals added to customers data bases. Also subscription based.

9.  Supply Chain Risk Assessment (Exposure)      

 i.   Identification of potential shortages and supply chain interruptions      

ii.  Identification of substitute materials or components             

 A call to Tanzco today could prevent a disruption in your company's sales!

There Is No Internationally Recognized Standard for REACH Compliance

If you are like most other companies, you will be requested to provide some evidence of product environmental compliance by customers, non-governmental organizations, or governmental enforcement authorities. On occasion, you may also be asked for demonstrate - through documentation - that you have the proper controls in place to ensure that compliance is an on-going process, not a one-time event. The quality of the conformance assurance system that you establish may determine whether or not you are subject to further scrutiny.

It would be easier if there were a standard to certify to. There are many claiming that they offer a certification but they are still hollow claims for now. Software companies claim that they have the solution and can manage all your materials composition data, check against the SVHCs and provide notifications. Nice to have but it doesn't manage processes and is not a certification.

Others claim that a third party audit can certify your company for REACH. How? There is not overall certifying body authorizing them to do so like an RABQSA for example. Still others claim that QC 080000 IECQ HSPM - Hazardous Substances Process Management should be used but it only deals with electronics.

So what are you to do? How about looking at the bigger picture and adopting a socially responsible corporate strategy. The best way to do that would be to become certified to ISO 14001. To obtain that certification you would have to be REACH compliant as well as compliant to all applicable environmental standard. More importantly you would be addressing your company's overall impact on the environment and making a continuous effort to reduce it.

Ready to make the right move and become certified to an already accepted international strategy to shows that your company cares about the world it lives in, call us. We can help you obtain ISO14001 certification.

The EU REACH Committee achieved agreement on two key issues during its meeting on 28-29 September. In addition to voting unanimously to list eight substances proposed by the European Chemicals Agency in REACH Annex XIV, the Committee also agreed a package of restrictions on substances classified as carcinogenic, mutagenic or reprotoxic (CMR).

The eight chemicals were proposed by ECHA in December 2010, and the Committee's decision means that companies will have to seek authorization for these substances in future. The substances include:

  • Di-isobutylphthalate (DIBP)
  • Diarsenic trioxide
  • Diarsenic pentaoxide
  • Lead chromate
  • Lead sulfochromate yellow (CI Pigment Yellow 34)
  • Lead chromate molybdate sulphate red (CI Pigment Red 104)
  • Tris(2-chloroethyl)phosphate (TCEP)
  • 2,4-dinitrotoluene (2,4-DNT)
The Committee also agreed a package of restrictions for substances placed on Annex VI of the CLP Regulation with a harmonized classification of category 1a or 1b carcinogen under the first Adaptation to Technical Progress (ATP) in 2009 Under the procedure, the restriction of substances with such a classification will apply to consumer applications under Annex XVII sections 28-30 of REACH.
The agreed texts must now be translated and passed on to the European Parliament for its three-month scrutiny before being published in the EU Official Journal.
For more information contact your Tanzco representative for assistance.



Current Issues

With No Clear Standard to Certify for REACH What Will Your Company Do?