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#1 Posted : 19 June 2007 08:10:00(UTC)
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Posted By John Jones
I seem to be struggling researching the new REACH Chem policy, we are quite a large manufacturer of UPVC window, doors and conservatory panels. I've read a bit literature on REACH and the way I see it is the producers and importers of chemicals are required to register them along with the information needed to use them safely. Currently we do use chemicals within one of our production process, which obviously comes under COSHH. Will REACH affect downstream to the manufacturers that use chemicals within their process?????

I have requested info from one of my HSE subscriptions, they seem to be a tad confused too. (So I'm not the only one)....

Thanks

John
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#2 Posted : 19 June 2007 08:15:00(UTC)
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Posted By Larry Shannon
may i suggest you check out Reach.ie and hsa.ie, the Irish equalivent to HSE, we seem to be ahead of UK on this, and as its EU leglisation been enacted we should all be similar.

I ahve a good presentation from the Inspector here for the layman and REACH.

PM me.













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#3 Posted : 19 June 2007 08:59:00(UTC)
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Posted By Raymond Rapp
John

Agreed, the REACH EU directive (or is it regulation) is a bit confusing. My understanding is that it is unlikely your company will be affected by REACH. The principle is that manufacturers and importers into the EU will have to register quantities of hazardous materials (CMRs). These quantities are generally large amounts and there is a hierarchy and time scale, which it must be said means little sense to me, but again, I doubt if you will need to concern yourself with at least for the time being.

Ray
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#4 Posted : 19 June 2007 09:09:00(UTC)
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Posted By Chris Packham
REACH is a lot more comprehensive than Raymond suggests. In fact, REACH will affect all users of chemicals (excluding cosmetics and biocides, which come under other regulations). Whilst it will initially mainly affect importers and manufacturers of substances, downstream users will ultimately be involved through exposure scenarios, risk management measures, etc. The BOHS recently held a one day seminar on REACH and it is proposed to repeat this, so I suggest you might keep an eye on the BOHS website events section.

With any regulation running to 849 pages (and at the last count over 3,500 pages of guidance notes!) there is bound to be some confusion. In fact, in my particular area of interest (skin issues) there are technical factors that make the implementation of REACH as it is currently written technically impossible.

So watch this space

Chris
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#5 Posted : 20 June 2007 09:20:00(UTC)
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Posted By Jim Masson
As I understand the Regulations, manufacturers, or importers, have a duty to produce a Chemical Useage Safety Assessment for for each anticipated 'use' of their product.

If a user is not covered by one of these they either have to get the manufacturer to produce one, or create it themselves and register it with the European Chemical Agency (which isn't operational until June 2008!)

Be interesting to see how soon our suppliers amend their MSDS to list the intended uses!
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#6 Posted : 21 June 2007 09:44:00(UTC)
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Posted By Chris Packham
Jim

Actually, there will be few changes to the safety data sheet, mainly limited to the order in which items appear. What will change is that the supplier will have to attach to the safety data sheet and Exposure Scenario covering safe use of the product for the particular application and an indication of the risk management measures that will be needed.

Actually, in the U.K. this is not a new requirement. If you consult the Health and Safety at Work etc. Act 1974 you will see that in section 6-1 the supplier already has a duty to do this - additional to the information on the safety data sheet (which is for CHIP, not COSHH).

Chris
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#7 Posted : 21 June 2007 10:23:00(UTC)
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Posted By GJB Davis
Hi all,

Sorry to go slightly off topic but does anyone know where I can find some brief guidance on REACH rather than the reams mentioned above. I would like to know the definition of 'high concern' and other info so that I can reply to a client's request. I know 'high concern' refers to carcinogens, mutagens and teratogens but would like to see the whole definition.

I've tried the HSE website and DEFRA but only found very basic info.

Regards

Giles
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#8 Posted : 21 June 2007 11:43:00(UTC)
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Posted By Chris Packham
Giles

Not an easy one to answer. REACH is extremely complex, with many aspects still to be properly clarified.

If you care to contact me direct I may be able to provide some help (01386 832 311)

Chris
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#9 Posted : 21 June 2007 12:37:00(UTC)
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Posted By Mike
Giles

If the REACH pages at http://www.hse.gov.uk/reach/index.htm do not meet your needs the REACH helpdesk UKREACHCA@hse.gsi.gov.uk, tel 0845 408 9575 would probably like to know so they can make improvements.
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#10 Posted : 21 June 2007 13:20:00(UTC)
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Posted By GJB Davis
Thanks to those who have responded both via the forum and direct via email. I'm happy with the info I've got now, cheers.

Mike, the HSE link is a whole lot better than the page I was looking at (which in fact was directing me to the DEFRA site). I always have problems finding what I want off the HSE website! I'm sure I can't be the only one that finds it a pain.

regards

Giles
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